© The Fine Art Ledger, LLC. V.01 July 2018
The Fine Art Ledger is a block-chain driven platform for Fine Art. Our mission is to make Fine Art ownership, buying and selling more transparent and accessible for Fine Art collectors.
Certain features of thefineartledger.com (the “Site”) are directly available to the public, while others are restricted to users of the Site (“Users”) approved by the Site’s administrators.
'The Fine Art Ledger' (“FAL” or “us” or “we”) is the trading name of The Fine Art ledger, LLC (a California limited liability company), which operates the Site and related domains.
D. Personal Information
By submitting any person’s Personal or other Information, you hereby confirm and undertake to FAL that you have that person’s permission to do so.
FAL collects, by input to its databases, all Personal Information uploaded to, posted on, shared or submitted through the Site in order to enable FAL to function.
E. Personal Information And the Blockchain
In addition, if FAL approves, certain Personal and other Information, which FAL collects, may be stamped into the blockchain for the purposes we more fully describe below.
The inherent nature of the blockchain is that it is immutable. All information stamped into the blockchain remains permanently, or at least for the life of the blockchain platform with which FAL operates. Personal Information stamped into the blockchain may include the name and address of the person in whose name a work of art is to be registered on the FAL.
YOUR USE OF FAL AND REGISTRATION AS A USER CONFIRMS YOUR AGREEMENT AND ACCEPTANCE THAT ANY PERSONAL OR OTHER INFORMATION YOU SUBMIT TO FAL MAY BE STAMPED INTO THE BLOCKCHAIN AND BE IMMUTABLE AND PERMANENTLY HELD WITHIN THE BLOCKCHAIN AND YOUR RELEASE OF FAL AND ITS AFFILIATES AND REPRESENTATIVES FROM ALL CLAIMS AND LIABILITY IN RELATION TO THIS IMMUTABILITY AND THE INABILITY TO REMOVE SUCH INFORMATION.
In the general nature in which all information is held on the blockchain, all Personal Information FAL stamps into the blockchain is encrypted and accessed through public and private keys maintained by FAL.
YOUR USE OF FAL AND REGISTRATION AS A USER CONFIRMS YOUR ACCEPTANCE THAT FAL DOES NOT EMPLOY MEASURES BEYOND THOSE INHERENT IN THE BLOCKCHAIN PLATFORM ON WHICH FAL OPERATES TO ENCRYPT OR CRYPTOGRAPHICALLY STORE INFORMATION ON THE BLOCKCHAIN AND YOUR RELEASE OF FAL AND ITS AFFILIATES AND REPRESENTATIVES FROM ALL CLAIMS AND LIABILITY IN RELATION TO ANY BREACHES, INTRUSIONS, HACKS OR OTHER VULNERABILITIES WHICH MAY EXIST ON THE BLOCKCHAIN PLATFORM OR IN RELATION TO FAL’S INTERFACE WITH THAT PLATFORM.
Currently, FAL works with the NEM blockchain platform. FAL may, within its discretion, change this and integrate with other blockchain platforms for the provisions of its service. Any information then existing on this or any other blockchain platforms will remain immutably stamped into those blockchains.
F. Collecting, Processing and Use of Personal Information
Submitting and sharing information with or on the Site, particularly Personal Information, is entirely voluntary on your part and you may elect not to do so by not registering with the Site, restricting or limiting the information you upload or otherwise submit or share on the site or the Users whom you contact on the site, or by deactivating your account.
As outlined below, FAL takes the protection and safeguard of your Personal Information very seriously, and does not share any personally identifiable Personal Information with any third party, except for the continued operation, and provision of the Site and its service, to enable FAL to use the services of certain of its vendors and/or contractors for the continued operation, and functioning of the Site and its service, for communications with its Users who have provided such information, with your consent, and for matters of legal and other compliance.
For example, you may wish, using FAL’s functionality, to transfer your title in a work of art, as recorded on the FAL platform, to a third-party or to otherwise disclose or publish a Letter of Authenticity produced on the FAL Platform. Doing so, will disclose your Personal Information as submitted to the Site to that third-party. Doing so, is entirely at your discretion and sole risk.
G. What Personal Information Do We Collect?
Broadly, we collect two types of Personal Information: (i) Personal Information you knowingly choose to disclose that is collected on an individual basis and, (ii) Site use information generated from your and/or others' use of the Site.
Personal Information You Choose to Provide
Sign Up or Log In. You may sign up or, once signed up and approved, log back into the Site. Once we approve your sign up request you will be given access to certain ‘User-only’ part of the Site. This includes the Site Ledger page and also your User Account pages within the Site. In signing up and logging back in we collect your email address, which may include your name, and the password you provide. We also provide the opportunity to sign up or log back in using Facebook or Google through OpenID protocols and interfaces which collects, and shares with FAL certain Personal Information. This is to make signing in or up easier for you. If you agree to use this feature, you consent to Facebook or Google providing us with the certain Personal and other Information which those sites provide to us in order for the Site to verify your credentials.
Completing your Profile. Once admitted as a User, you will have access to your private User account within the Site. This account consists of a number of separate pages. The first is your User Account, which includes input fields for your first and last name, email address and phone number. You may also wish to upload a profile picture. You may complete, edit or delete this Personal Information within your discretion through the controls within your User Account, although your login credentials may not be removed for so long as you remain a User. To delete your User Account and credentials from our system, see below.
Submitting Works to the Site. Through your User account, you are able to submit Works of fine art for FAL’s approval for submission to the blockchain. This is done through the ‘Submit Works’ page of your User account which contains a form that collects certain Personal Information, including but not limited to the full name of the person in whose name title to the work is requested to be stamped into the blockchain, her physical address and email address. On submission of this form, this Personal Information is held in FAL’s cloud servers maintained and controlled by its third party providers.
Approval and Stamping into the Blockchain. Following submission of a Work to the Site, FAL may review, in accordance with our criteria, the stamping of the Work into the blockchain. If approved, the Work will be stamped into the blockchain and a Letter of Authenticity will be generated. At this time, certain Personal Information, specifically the full name of the person recorded as holding title to the Work and her address (as provided pursuant to Paragraph A5 (or updated in the course of FAL’s further inquiries)) are stamped into the blockchain. This information is then held immutably in the blockchain.
Transferring Works. FAL will allow for the transfer of Works stamped into the blockchain on its platform (currently a pending feature). This will be effected through the ‘Transfer Works’ page in your User Account. We collect the full name and email address of the person to whom the Work is transferred, as submitted to us through the ‘Transfer Work’ form in your User Account. The information submitted in the ‘Transfer Work’ form is subject to FAL’s review and discretion approving the transfer.
FAL’s Review Process. In determining whether to stamp Works into the blockchain, FAL may contact you or the persons identified in submissions made through the ‘Submit Works’ or ‘Transfer’ forms in your User’s Account in order to receive further information or other details concerning the submitted Work or the title of the persons named in the forms. Providing FAL with these details or further information is entirely voluntary, but any failure or refusal to do so will naturally limit FAL’s ability to complete its review process and may result in the Work not being submitted to the blockchain.
Posting Comments. FAL collects, processes and uses information posted to areas of the Site viewable to some Users, or certain groups of Users or to the general public (such as Art Wire, our blog, the Art Market section of the Site or our social media pages, including Facebook and Instagram). Users are cautioned against posting confidential, proprietary or Personal Information to public forums. FAL may share and use for any purpose any information posted to these and other public forums.
Contact. Through the Site’s contact form, you may submit your name and email address in order to communicate with FAL. This form also provides for a general communication field. Any Personal Information you choose to share with us through field is within your own discretion.
Updates. You may choose to provide your name and email addresses to the Site through one of its forms for the purpose of receiving emails, news alerts and updates on the Site and its service. The Site provides forms to collect this information in its footer and though a lightbox pop-up.
2. Personal Information Generated From Your Use of FAL
IP Addresses, Log Files and Other Information. As with other website operators, FALreceives and collects information relating to your use of, and access to the Site, the devices which you used to access the Site as well as the websites you have visited before and after coming to our Site. FAL is able to do this as it automatically receives the 'internet protocol' ("IP") address of the computer or other devise or the server used to access the Site, as well as the URL of the site from which you came, and to which you go before and after visiting our Site. Through this access, FAL also knows additional information, including the type of operating system you are using to access the Site, as well as the details of your Internet Service Provider or the mobile or cell provider which carries your access to the internet. FAL also collects and shares your URL information with providers and advertisers on the Site for the purpose of tracking your use and interaction with those persons. In addition, FAL may also have information regarding your location where you have activated certain location tracking applications or devices offered by third party services.
Web Beacons. We or our third party advertising partners and/or other providers may employ a software technology known as web beacons that help us better manage content on our Site by informing us what content is effective. Web beacons are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are embedded invisibly on Web pages. We do not tie the information gathered by web beacons our customers' personally identifiable information, but can not guarantee that third party sites (such as Facebook) will not do so when you given them permission to share your Personal Information with the Site.
Interfacing with Third Party Websites and Applications. FAL interfaces with certain third party websites (for instance, Facebook, Google and Instagram) using third party sites' API's or other tools. These allow, by way of example, for easy sign in or sign up to FAL using your third party website credentials, but may provide for further functionality. These API tools enable FAL to collect information from your profile on the third party website and to obtain your 'member ID's' for these websites.Information gathered in this way is used to enhance your User experience, and to direct relevant services, products advertising and marketing to you, and may be shared by FAL with its affiliates and/or third parties. FAL is able to personally identify you to this information, but does not share information with third parties that may associate this information personally with you, subject as provided below. If you do not want FAL to collect or use this information, then please do not grant API access to FAL when requested.
Information gathered in this way is used to enhance your user experience, and to direct relevant services, products advertising and marketing to you, and may be shared by FAL with its affiliates and/or third parties. FAL is able to personally identify you to this information, but does not share information with third parties that may associate this information personally with you, subject to the exceptions detailed, below.
H. How Do We Process and Use the Personal Information We Collect?
Broadly speaking, we use Personal Information for purposes of administering our business activities, providing customer service, enhancing and improving the Site and use of it, making available products and services to Users, tracking commissions, fees and payments due to FAL and for directing marketing and advertising to the site and other sites. Occasionally, we may also use the information we collect to notify you about important changes to our Site, new services and special offers we think you will find valuable.
As a User, you may notify us of your desire not to receive promotional offers or non-service related updates. You may do so by unsubscribing from our emails or notifying us here or through the Site itself.
However, as more fully detailed, below, FAL does not share Personal Information with any third party, without the relevant User’s consent, subject to the following. The exceptions to this, as detailed below, are that FAL is required to share Personal Information where required to do so by law or for its compliance purposes, may do so in its review of title, provenance and other matters in determining whether to stamp Works into the blockchain or transfer Works pursuant to transfer requests, to ensure the continued operation of the Site and provision of its service , and may share Personal Information with its vendors and/or contractors necessary and in defined circumstances for the continued operation of the Site, the provision of its service or communications with Users, or to enable Users to use third party services available to them on, or through the Site (for instance, payment processing or chat services or other apps (see below)).
Submitting information, particularly Personal Information, is entirely voluntary on your part and you may elect not to do so by not registering with the Site, restricting or limiting the information you upload or otherwise submit or share on the Site, affiliated sires or social media outlets, or by deactivating your account. You may deactivate your account at any time by emailing us and requesting removal of your account.
FAL processes and uses of Personal Information, as follows:
Enhancing and Improving Your User Experience. FAL collects and processes your Personal Information (including, but not limited to first name, last name, address, email, phone numbers and URL's) in order to allow the Site to function correctly and provide the User experience for which it is intended. This Personal Information is revealed to FAL and (subject to our Terms and Conditions of Use) its site administrators and relevant employees and contractors who will use it to administer the Site. It also uses this information to vet registration and admission to the Site and to issue invitations to register with the Site, as applicable.
Approving Submissions to the Site. FAL reviews information submitted by Users in the ‘Submit Works’ and ‘Transfer’ forms in its Users’ accounts. This review is in support of FAL’s determination whether to submit Works to the blockchain or process transfers in Works. FAL may use this information, including Personal Information, to support its enquiries into title and provenance of a Work and in its general determination to submit works to the blockchain. FAL may also use this information to contact you or other persons named in the submissions or third parties in the course of its review process.
Communications. FAL may use your and other’s email and other contact details supplied on your registration, updating your User profile, submitting Works to the Site, on requesting transfer of a Work or contacting the site or otherwise provided to FAL to communicate with you about updates or interruptions to the Site, Site features, news, interactions with other Users, promotions being offered by FAL, its affiliates, third party providers or partners and other matters pertaining to FAL, its business and the site. These communications may be sent to the external email address provided or otherwise posted on your FAL account home page. You are advised to check your FAL account regularly to pick up any updates.You may opt out of receiving certain communications from FAL by visiting by contacting FAL through the Site emailing FAL at (in each case clearly specifying your requirement(s)) or by clicking on the un-subscribe link in promotional emails sent to you.However, you may not opt out of communications of a service nature which FAL requires that you be notified of in relation to the continued operation of the Site or its business. FAL also uses User contact details to facilitate communications and interaction between Users or other persons where consented to by the User, either through the ‘Transfer’ page of your User Account (when a User wishes to transfer title registered on FAL to another person or otherwise.
Content Relevance. FAL may use your Personal Information to help customize your User experience on the Site or affiliated sites. This may include directing content to you based on your location, areas of interest or focus or other aspects of your Personal Information. For instance, we may prioritize certain Works or providers in search results based on expressed preferences, circumstances or areas of interest or direct to you events, topics of interest, services or products which, based on these factors, we think may be of interest to you.
Search. FAL may provide a search feature to enables Users to search for content on the Site. A User’s Personal Information submitted through registration, in submitting or transferring Works to the Site, or as stamped into the blockchain is not searchable by another User. FAL’s search function may use or rely on Personal Information submitted by a User to refine search results for that User.
Advertisement and Marketing. FAL does not share Personal Information with any person (other than as set forth in this Policy or in the Terms and Conditions of Use).In particular, FAL will not disclose your email or other contact details to any third party for advertising or marketing purposes, other than third party services which FAL may use to send FAL, or its affiliates’ own marketing or information emails or newsletters and/or the like) to you.However, FALmay use and/or share for a fee or other consideration information which is derived from your Personal Information but which is not personally identifiable to you with third parties (for example third party advertisement networks or agencies) to direct our or our affiliates or third party advertising or other promotional materials to you, whether on the Site, on other sites or through social media outlets or otherwise.For example, FAL may direct banner or other advertisements to your account based on the general demographics underlying your Personal Information, general location or otherwise based on features or information disclosed in your registration or profile, and your use of, and activity on FAL. In addition by way of example, third parties (whose identities may not be known to us) may target your website usage disclosed to us through your use of FAL with advertisements or promotional information. We may also track your visits to our providers' or other third party sites using discrete URL links or other methods in order to account for commissions or fees due to FAL for introducing you to these providers or third parties through our Site. We may also share, for a fee or otherwise, statistical information for research or other purposes with third parties. We (our affiliates and third parties) may gather this non-personally identifiable Information through the use of Cookie and other similar technology as described above, as well as through surveys, feedback requests and information polls conducted on, or by FAL.If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by emailing us.
Payment Processors. Certain of the Providers on FAL may offer payment processing services to enable on-line payments for Works or products or tokens sold or to be sold, or services rendered or to be rendered through the Site. If you do so, YOU AGREE THAT NEITHER FAL NOR ANY FAL REPRESENTATIVE HAS ANY RESPONSIBILITY WHATSOEVER FOR, NOR DO ANY OF THEM VET OR MONITOR THOSE PROVIDERS' SERVICES, THE CONTRACTUAL RELATIONSHIP FOR THE PROVISION OF THE PAYMENT PROCESSING SERVICES BEING SOLELY BETWEEN YOU AND THAT PAYMENT PROCESSING PROVIDER. Requests for payment and payments made online through a payment processing Provider may be facilitated by FAL. In doing so, FAL merely provides the required links to the payment processing Provider and payment options, and through the payment processor’s API, may provide details of the User’s involved, including to facilitate the transaction. FAL does not collect, store, or process any payment information,(for instance credit card details) all such information being entered directly on the payment Processor or its contractor's gateway. When electing to use, or submit payment or other information to a payment processor provider on FAL, you are required to satisfy yourself as to the policies and practices of that payment processor with regard to the collection, processing and sharing of , including payment information, as well as the suitability of that payment processor for processing payments for Legal services. BY YOUR REGISTRATION, OR CONTINUED USE OF FAL YOU AGREE AND ACCEPT THAT THIS RESPONSIBILITY RESTS WITH YOU.
Third-Party Vendors. FAL uses certain third-party vendors to provide key elements of its service. For instance, it uses third-party controlled and managed blockchain platforms, ‘Cloud’ servers to store information and data relating to the site and its Users, third-party controlled and managed web applications, third party email services to communicate with its Users and independent contractor for the development of tis front, and back-end applications. In addition, it also engages contractors for the development of the site and for other business purposes.In each case, FAL is required to share Personal Information with those vendors in order to provide the service, including Personal Information. By way of example, FAL currently operates its blockchain platform on the NEM platform, FAL front-end Site is built in Wix, and FAL’s ‘Cloud’ server provider is Amazon Web Servers. These by definition, store all information, including User’s Personal Information submitted to them. In addition, FAL’s email solution and distribution vendors require an email address and name of addressees of emails, both promotional or service-oriented in nature. While it is generally understood that these providers do not process information submitted to them through the Site, FAL assumes no responsibility for any processing (if any) procedures or activities of these third-party vendors
Required Disclosure of Personal Information. All of FAL and its third party providers may be required to disclose information and other data on the Site servers, or as otherwise uploaded to, or shared with the Site, where required to do so by applicable law, including any statute, regulation, subpoena or court order. THESE SERVERS ARE KEPT AND MAINTAINED BY FAL’s VENDORS IN THE UNITED STATES OR ELSEWHERE, AND MAY NOT BE SUBJECT TO PROTECTIONS EQUIVALENT TO THOSE IN THE PLACES WHERE YOU RESIDE OR FROM WHERE YOU USE THE SERVICES OR WHICH YOU MAY OTHERWISE BE ACCUSTOMED TO. IN ADDITION, FAL MAY ACCESS, PROCESS, USE, SHARE OR DISCLOSE ANY DOCUMENT, INFORMATION OR OTHER DATA (WHETHER COMPRISING PERSONAL OTHER INFORMATION) ON FAL’S OR ITS VENDORS' SERVERS, OR AS OTHERWISE UPLOADED TO, OR SHARED WITH THE SITE), WHERE IT BELIEVES THAT IT IS NECESSARY TO DO SO TO INVESTIGATE ANY ABUSE OF THE SITE, TO COMPLY WITH ANY LEGAL PROCESS, INCLUDING, BUT NOT LIMITED TO ANY WARRANT, SUMMONS, CRIMINAL OR CIVIL SUBPOENA, COURT ORDER, GOVERNMENTAL OR OTHER COMPETENT AUTHORITY ENTITLEMENT AND/OR REQUIREMENT, TO PROTECT IT OR ITS AFFILIATES, AND THEIR RESPECTIVE EMPLOYEES, OFFICERS AND DIRECTORS', AND/OR ANY MEMBER OF THE PUBLIC'S RIGHTS, TO PROTECT OR SAFEGUARD ANY OF THE AFOREMENTIONED PERSON'S PROPERTY, TO DEFEND AND/OR ENFORCE ITS OR ITS AFFILIATES AND/OR THEIR RESPECTIVE EMPLOYEES, OFFICERS AND/OR DIRECTORS' INTERESTS IN ANY DISPUTE WITH ANY USER OR ANY THIRD PARTY, AND/OR IN RELATION TO THE PREVENTION OF PHYSICAL HARM TO ANY PERSON, DAMAGE TO PROPERTY OR THE COMMISSION OF ANY CRIME. Where we are entitled to notify, and it is practical and feasible in the circumstances for us to do so, we will give the affected User notification of our intention to disclose information, so that the User concerned may have the opportunity to raise any objections to the release of such information. Such notification may be sent to the User's email address provided to FAL or posted on the User's Account profile or as otherwise required by FAL. YOU HEREBY ABSOLVE AND RELEASE, INDEMNIFY AND AGREE TO HOLD FAL AND ALL FAL REPRESENTATIVES HARMLESS FROM AND AGAINST ANY AND ALL CLAIMS, RESPONSIBILITY AND/OR LIABILITY FOR SUCH DISCLOSURE, ABSENCE OF NOTIFICATION OR ANY SUCH NOTIFICATION NOT COMING TO YOUR ATTENTION IN RELATION TO ANY INFORMATION PROVIDED BY YOU TO THE SITE. YOU ALSO AGREE THAT ANY ACCESS OR DISCLOSURE BY FAL, AS DESCRIBED IN THIS PARAGRAPH H.10 FALLS OUTSIDE OF, AND IS AN EXCEPTION TO THE PROVISION REGARDING FAL’S ACCESS TO, AND DISCLOSURE OF YOUR PERSONAL INFORMATION, AND DOES NOT REQUIRE ANY CONSENT FROM YOU.
Surveys, Ratings, Feedback and Polls. FAL, may, or permit its affiliates and/or third parties (including other Users) to conduct polls or surveys on the Site, or request feedback on the Site,. Your selection for these polls may be based on your non-personally identifiable Personal Information, which FAL may share with third parties. The results of these polls, surveys and requests may be available to FAL, and may be processed and used by it to enhance User enjoyment and performance on the Site, to rate Providers and to place and offer advertisements and/or promotions on the Site or other sites or social media outlets or sent directly to Users of the Site by email or other methods of communication.FAL will not share or publish any results of the surveys, polls, or feedback which are identifiable individually to any User, or allow the sharing of any in these circumstances without the participating User opting to allow such publication or release. FAL may sell or market the aggregated, non-personally identifiable results of any polls, feedback requests or surveys to its affiliates and/or third parties for a fee, and may charge third parties or its affiliates.
Testimonials. With your consent we may post your testimonial along with your name.
I. International Privacy
FAL is located in the United States, and works with third party providers who have servers located in the United States. In addition, given the nature of the blockchain as a distributed ledger, Personal Information submitted to the Site and/or stamped into the blockchain may be held on servers located in the United States and a diverse array of other jurisdictions. Information, including Personal Information, may be transferred into and out of these jurisdictions without notice to you. The United States, on a federal or state level, may not have the level of data or privacy protection or safeguards that you are used to where you reside. Your registration with, and submission of information, including Personal Information to the FAL is entirely voluntary, and should not wish to have information held in countries other than where you live, please do not register with the FAL, or if already registered, please deactivate your User account.
The security of your Private Information is important to us. We encrypt the transmission of that information on our Site using secure socket layer technology (SSL) provided by Wix, and take certain other security precautions. In addition, as with the nature of most blockchain platforms, information stored on the NEM blockchain is cryptographically held and messages sent to the blockchain for FAL are encrypted.
We follow generally accepted standards to protect Personal Information submitted to us. No method of transmission over the Internet or on the blockchain, or method of electronic storage is 100% secure, or can be guaranteed, however. Accordingly we cannot, and do not guarantee that unauthorized access to the Site or the servers, blockchain platforms or systems on which the Site, servers or blockchain operates or on which user data is stored will not happen, or that there won’t be information leakage or loss or other breaches. If you have any questions about security on our site, you can contact us at email@example.com.
K. How Can You Access, Retrieve or Delete Your Information on The Fine Art Ledger?
FAL currently offers the following means of accessing, retrieving and deleting your Personal Information:
Accessing and Retrieving Information. As a User, you may log into your account and view the information, documents and other data in your profile.
Editing and Deleting Information. Your User account currently provides the ability to edit, update and delete your first and last name, contact email and phone number. You can also edit your profile name and photo. However you are unable through your account to change your login email address.
Deactivating or Deleting Your Account. Deactivation or deletion of your User account is currently by email to FAL at firstname.lastname@example.org. If you wish to deactivate or delete your User account, please email us with the request. We may, but shall not be required to follow up with you to confirm your request. Once deleted, your information will not be capable of being retrieved. NOTE: Information stamped into the blockchain is immutable and cannot be changed. The blockchain preserves a permanent record of information stamped into it. As noted, FAL does not stamp into the blockchain all information reflected on a Letter of Authenticity or other submissions to the blockchain. Some of that information is held ‘off-chain’ on cloud servers maintained by FAL’s third party providers. For example, thumbnail images and catalogue notes are kept ‘off-chain’ and so too are high resolution ‘raw’ image files used in digital editions. To the extent that any off-chain information or images relates to any information stamped into the blockchain, FAL will not permit the deletion of this off-chain information other than within its own discretion or as required by applicable law
L. When Can FAL Change This Policy and How Do You Contact FAL Concerning This Policy?
© The Fine Art Ledger, LLC. 2018 V.01 July 2018.