March 31, 2021



U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3720



Larry Spirgel


Kathleen Collins


Alexandra Barone


Rebekah Lindsey



TuSimple Holdings Inc.


Registration Statement on Form S-1


Filed March 23, 2021


File No. 333-254616

Ladies and Gentlemen:

We are submitting this letter on behalf of TuSimple Holdings Inc. (the “Company”), in connection with the review by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) of the above-referenced Registration Statement on Form S-1 filed on March 23, 2021 (the “Registration Statement”).

Because of the commercially sensitive nature of information contained herein, this submission is accompanied by a request for confidential treatment for selected portions of this letter. The Company has filed a separate letter with the Office of Freedom of Information and Privacy Act Operations in connection with the confidential treatment request, pursuant to Rule 83 of the Commission’s Rules on Information and Requests, 17 C.F.R. § 200.83.



[*] Confidential material redacted


Securities and Exchange Commission

March 31, 2021

Page 2





Preliminary Initial Public Offering (“IPO”) Price Range

The purpose of this letter is to notify the Staff that, based on current market conditions, the presently anticipated price range to be included on the cover of the Company’s preliminary prospectus is expected to be within a range of $[*] and $[*] per share (the “Preliminary Price Range”). We are providing this information in order to enable the Staff to complete its review of the Company’s option pricing and fair value determinations.

This Preliminary Price Range was determined based, in large part, on discussions among the Company and representatives of the underwriters for the IPO that took place on March 30, 2021. Prior to March 30, 2021, the underwriters and the Company had not engaged in any formal discussions regarding the valuation of the Company or a proposed price range for the Company’s IPO. As discussed in more detail below, the Preliminary Price Range is informed by several factors, including, the current conditions in the U.S. equity capital markets, sector-wide outperformance in the electric vehicles/autonomous vehicles space, the unprecedented levels of fiscal stimulus, the near all-time high of the Nasdaq Composite Index in 2021, the feedback received during testing-the-waters meetings, the exercise of warrants by two key strategic partners, Traton International S.A. and Navistar, Inc., and the significant investor demand to participate in the Company’s Series E redeemable convertible preferred stock financing, which included more than 20 sophisticated and independent financial and strategic investors, that initially closed in December 2020 and included subsequent closings in January 2021.

The Preliminary Price Range noted above has not been conclusively determined to be the price range that will be included on the cover of the Company’s preliminary prospectus and is subject to further revision based on market conditions, business developments and other factors. The Company does not expect to implement a stock split in connection with the IPO.

Valuation of December 2020 Grants

On February 16, 2021, in response to prior comment six from the Staff’s letter dated January 19, 2021, the Company provided the Staff with information regarding options, restricted share units (“RSUs”) and share value awards (“SVAs”) granted between January 1, 2020 and December 24, 2020. On December 24, 2020, the board of directors of the Company (the “Board”) granted options to purchase 3,425,803 shares of common stock, 1,100,000 RSUs and 163,549 SVAs (the “December 2020 Grants”).

As described beginning on page 93 of the Registration Statement, the Company has regularly performed contemporaneous valuations of the Company’s common stock to assist the Board in its determination of the common stock’s fair value for purposes of granting stock options. In its determinations, the Board has considered numerous objective and subjective factors, including the factors set forth beginning on page 93 of the Registration Statement, the status of the Company’s progress towards commercialization of its technology for autonomous trucks, its growth and progress towards an IPO and the most recent valuation report prepared by a third-party valuation specialist. The Board, as applicable, also determines that the assumptions and inputs used in connection with such contemporaneous valuations reflect the Board’s and management’s best estimate of the business condition, prospects and operating performance of the Company at each valuation date.



Securities and Exchange Commission

March 31, 2021

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The Company determined the fair value of its common stock to be $8.24 per share as of December 24, 2020. The Company based its determination on several factors, including a contemporaneous third-party valuation report valuing the Company’s common stock (“December 2020 Valuation Report”). The December 2020 Valuation Report used a hybrid method utilizing a combination of the option pricing method (“OPM”) and a probability-weighted expected return method (“PWERM”). The value of the Company’s common stock was determined by applying a weighted probability of 50% to an IPO scenario and 50% to a non-IPO scenario, respectively. Additionally, there was a contemporaneous issuance of the Company’s Series E redeemable convertible preferred stock to new and existing investors, of which the Company issued 25,695,018 shares at a price of $14.1401 per share for aggregate proceeds of $363.3 million in December 2020 and January 2021, including approximately $322.0 million from new investors. The participating investors were large, accredited institutional investors and the issuance price was determined to represent the fair value of the Series E redeemable convertible preferred stock at such date since it was issued in an arm’s length transaction with independent third parties. The Company believes that the per share price of the Series E redeemable convertible preferred stock represents a cap on the maximum value of the Company’s common stock at December 24, 2020 given that standard, widely-used valuation methodologies determine that shares of redeemable convertible preferred stock with liquidation preferences and other rights are more valuable than shares of common stock without the rights and preferences typically associated with preferred stock.

While preparing the Company’s financial statements with a retrospective view, the Company estimated the fair value of the common stock of the Company on December 24, 2020 for accounting purposes. Given the proximity of the December 2020 Grants to the Preliminary Price Range, the Company reassessed the fair value of the common stock for financial reporting purposes using the $14.1401 original issue price of the Series E redeemable convertible preferred stock, which was sold in transactions that closed in December 2020 and January 2021. The Company believes that this fair value was appropriate for the December 2020 Grants considering the contemporaneous issuance of the Series E redeemable convertible preferred stock in an arm’s length transaction with sophisticated, independent accredited investors, the fact that the Series E redeemable convertible preferred stock is currently convertible into common stock on a one to one basis automatically upon the Company’s IPO, the estimated timing of the Company’s IPO and the inherent uncertainty and market risk related to IPOs generally.

Using this fair value of $14.1401 per share results in the measurement of additional stock-based compensation of approximately $26.7 million compared to the value implied in the December 2020 Valuation Report, including approximately $228,000 of stock-based compensation attributable to fiscal year 2020 that is not material. This additional stock-based compensation will be recognized over the requisite service period for awards with service-based vesting conditions and upon IPO for awards with performance-based vesting conditions. The incremental stock-based compensation expense to be recognized upon IPO related to these performance-based awards is $4.7 million. The Company will update the subsequent events footnote in an amendment to its Registration Statement to provide additional information regarding the December 2020 Grants.



Securities and Exchange Commission

March 31, 2021

Page 4





Valuation of February and March 2021 Grants

Since December 24, 2020, the Board granted options to purchase 365,968 shares of common stock and 60,360 RSUs on February 4, 2021 (the “February 2021 Grants”). Our letter dated February 16, 2021 inadvertently referenced 75,360 RSUs instead of the 60,360 RSUs that were granted on February 4, 2021. In addition, on March 4, 2021, after the Company domesticated from the Cayman Islands to Delaware (as described in the Registration Statement), the Board granted options to purchase 2,300,000 shares of common stock (the “March 2021 Grants”).

For financial reporting purposes in connection with the Company’s IPO process and due to the proximity of the February 2021 Grants and March 2021 Grants to the determination of the Preliminary Price Range, for purposes of recognizing stock-based compensation expense in its financial statements for the quarter ending March 31, 2021 and on a going forward basis until the time that there is a public market for its common stock, the Company intends to assess the fair value of the Company’s common stock in connection with such grants using the initial public offering price disclosed in the final prospectus.

The Company will update the subsequent events footnote in an amendment to its Registration Statement to reflect that it will recognize stock-based compensation expense for the February 2021 Grants and the March 2021 Grants, which is expected to be recognized over the requisite service period.

Difference between Determined Fair Value of Common Stock and the Preliminary Price Range

The Company believes that the difference between the determined fair value of its common stock, including the $14.1401 per share as of December 24, 2020, and the $[*] per share midpoint of the Preliminary Price Range provided above is primarily the result of the following factors:

Business-related factors



The exercise of warrants held by Traton International S.A. and Navistar, Inc. in February and March 2021 for aggregate proceeds of $49.0 million and $134.0 million, respectively. Each of these warrant holders is a significant original equipment manufacturer (“OEM”) of semi-trucks and these exercises represent the most substantial OEM investment in the autonomous trucking space. Receiving such an investment from two of the five largest global OEMs has not to the Company’s knowledge occurred previously in the Company’s industry and represents significant validation of OEM support for the Company’s efforts to bring autonomous trucks to market.



Progress in the Company’s reservation program, which reached 5,700 trucks as of March 23, 2021, as described in the Registration Statement.



The Company announced its Executive Advisory Board in January 2021, consisting of CEOs of three of the largest trucking companies in the country, a CEO of a Class I railroad, a former Vice Chairman of General Motors, and two former members of Congress. The Company believes that this group of world class industry and regulatory leaders validates its leading position in the market, reflects its ability to appropriately navigate the regulatory landscape, and serves as a strong indicator of the traction that the Company gained leading up to the IPO.



The initiation of freight operations within two-thirds of the Texas Triangle in February 2021 (Dallas/Austin and Dallas/San Antonio corridors) and the expected commencement of freight operations in the final one-third in April 2021 (Dallas/Houston corridor), which validates the Company’s status as a first-mover in one of the most significant shipping corridors within the United States.



Securities and Exchange Commission

March 31, 2021

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On February 23, 2021, the Company changed its jurisdiction of incorporation from the Cayman Islands to the State of Delaware. Tusimple (Cayman) Limited deregistered as a Cayman Islands exempted company and continued and domesticated as a corporation incorporated under the laws of the State of Delaware. In connection with the domestication, Tusimple (Cayman) Limited changed its name to TuSimple Holdings Inc. U.S. investors are familiar and comfortable with Delaware corporations and the underlying corporate law. Following testing-the-waters meetings, the Company received positive feedback from prospective investors about the domestication in Delaware.

IPO/market-related factors



The initiation and successful completion of testing-the-waters meetings from late January 2021 to March 2021, which educated potential accredited investors about our technology, business model, and go-to-market strategy.



The unprecedented levels of fiscal stimulus and monetary policies, including quantitative easing, of the United States Federal Reserve Bank and other central banks globally. The electric vehicles/autonomous vehicles space in particular has remained bullish with continued investor interest and large trading volume. The equity markets have become increasingly receptive to stories like the Company’s, with the Nasdaq Composite index remaining at or near all-time highs for the entirety of 2021, and the Company would represent the only opportunity to invest publicly in a pure-play autonomous vehicle business.



The Preliminary Price Range assumes the conversion of all of the Company’s outstanding redeemable convertible preferred stock into shares of common stock. The Company’s redeemable convertible preferred stock currently has substantial economic rights and preferences when compared to the Company’s common stock, including (i) the right to receive dividends in preference of the holders of common stock, (ii) liquidation payments in preference of the holders of common stock, and (iii) redemption rights after a specified date. In connection with the closing of the IPO, all outstanding shares of the Company’s redeemable convertible preferred stock will convert into common stock, thus eliminating the superior rights and preferences of the redeemable convertible preferred stock as compared to the common stock.



In March 2021, the Company received the requisite consent to proceed with its IPO from significant stockholders that needed to approve the transaction in order to proceed with an IPO and the public company governance documents. Prior to this, it was uncertain whether the requisite stockholders would agree to proceed with an IPO.

Based on the analysis above and in our February 16, 2021 letter, the Company respectfully submits to the Staff that it has complied with the applicable rules and regulations for the determination of fair value. The Company advises the Staff that the Company intends to use the midpoint of the Preliminary Price Range to value for financial reporting purposes any additional equity awards granted until the time that there is a public market for the Company’s common stock.




Securities and Exchange Commission

March 31, 2021

Page 6





Please contact the undersigned at (650) 463-5335 if you have any questions with respect to this letter.


Very truly yours,

/s/ Jeffrey R. Vetter, Esq.

Jeffrey R. Vetter, Esq.



Cheng Lu

Patrick Dillon

James Mullen, Esq.

TuSimple Holdings Inc.

Zhen Liu, Esq.

Richard Chang, Esq.

Colin Conklin, Esq.

Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP

Richard Truesdell, Esq.

Stephen Byeff, Esq.

Davis Polk & Wardwell, LLP

Jean Stadwiser




TuSimple Website Privacy Policy



This is TuSimple’s Website Privacy Policy (“Privacy Policy”). To TuSimple (“we” or “us” or “our”), your privacy is of the utmost importance. This Privacy Policy explains how we collect, use, disclose, share, and safeguard your personal information when you visit our website. at, engage with our marketing operations, or when you contact us, including through email or social media. For simplicity, in this Privacy Statement we call all of these activities “interacting with TuSimple.” Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access this website.

This Privacy Policy applies to information we collect when you use our websites and other products and services that link to this Privacy Policy (collectively, the "Services"). We may supply a different privacy policy in relation to some of our Services, and that policy will apply to any information provided to or collected by us pursuant to those Services.This Privacy Statement does not apply to personal information we obtain from individuals interacting with other TuSimple products and services such as vehicles or mobile applications. 

We operate in the United States and this Privacy Statement is intended for users located in the United States. If you are located outside of the U.S., please be aware that the information we collect will be processed in the U.S. and will be subject to U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under local law.


Personal Information We Collect and How We Use and Share It

Presently, the personal information we may collect includes:

  • Information You Provide. This information may include personally identifiable information, such as your name, address, email address, phone number, and demographic information, such as your age, gender, hometown, and interests. 
    • This information may be collected when you choose to interact with our website, as well as with third-party websites that are linked with our website, including social media. 
    • We may also collect information disclosed when entering contests, sweepstakes, or submitting surveys we, or a third-party on our behalf, may run. 
    • Data provided by you from communications and other feedback, including questions, vulnerability reports, and other messages you address to us directly such as email or online forms may also be collected. 
  • Automatically Collected Information. When you visit our website, we may use automatic data collection technologies to collect certain information, such as: 
    • Access times;
    • The pages you have viewed directly before and after accessing the website.
    • Internet Protocol (“IP”) addresses of the devices you're using to interact with us online; 
    • Tools such as cookies and other local storage used by websites and web browsers to maintain information regarding your previous activities on a site;
    • Information regarding your internet connection including your Internet Service Provider, connection type, and approximate city level location of your internet connection based on IP address; 
    • Information about how the device is interacting with our Website and social media accounts;
    • Type and version of your device’s operating system and web browser;
    • Specific interactions with our Website (such as which pages you viewed, in what order, and how long you engaged with each page); and
    • Error logs.

The technologies we use for this automatic data collection may include cookies, web beacons, tracking pixels, and other tracking technologies on our website, including:

  • Google Analytics. We use Google Analytics to help us understand your use of our website and the popularity of certain content so we can improve your experience. You can learn about Google’s privacy practices at, and you can opt out of Google Analytics by downloading the Google Analytics opt-out browser add-on, available at
  • LinkedIn Insights Tag. We use LinkedIn Insights Tag to retarget our website visitors and learn insights about your interactions with our LinkedIn advertisements. You can learn about LinkedIn’s privacy practices at, and you can opt out of LinkedIn Insights Tag at
  • Google Ads. We use Google Ads to help us determine how effective our ad campaigns are. You can learn about Google’s privacy practices relating to Google Ads at, and you can prevent your participation in Google Ads conversion tracking by setting your browser to block cookies from the domain

Like many companies, we and our service providers may use "cookies" and other tracking technologies to gather information about your visit to our Website (see “Information We Collect” above). We use these tools to measure site activity, provide a better user experience, and to deliver, evaluate and tailor our marketing communications and online advertisements for you. Cookies are used by websites and web browsers to maintain information regarding your previous activities on a website, including what content has been displayed to you. Cookies are also used to optimize the performance of our Website.

Some content, including advertisements, on our website may be served by third parties, including advertisers and ad networks. These third parties may use cookies, alone or in conjunction with pixels, web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with personalized ads or other targeted content. You can generally opt out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt out pages on the NAI website and DAA website.

We may use the personal information you provide to us or that we collect about you to:

  • Respond to an email or other inquiry or request, including to fulfill your request to subscribe to a TuSimple newsletter;
  • Customize your experience on our website;
  • Deliver advertisements to you, including on other websites you visit;
  • Compile anonymous statistical data and analysis for use internally or with third parties;
  • Provide, maintain, analyze, and improve our Website;
  • Monitor and analyze usage and trends to improve the functionality of our website;
  • Perform other business activities as needed, such as for recruiting purposes; and
  • Fulfill any other purpose for which you provide your information or to which you otherwise consent.
  • Develop new products and services;
  • Communicate with you for a range of reasons (including providing information, including updates and notices, we think will be of interest to you, conducting surveys, and responding to your comments, questions, and requests);
  • Protect the rights and property of TuSimple, our users, and others; 
  • Detect, prevent, and respond to fraud, abuse, and security issues; and
  • Carry out any other purpose described to you at the time the information was collected.

We may aggregate or de-identify information such that it is no longer linked to you or your device. This notice does not limit our ability to use or disclose aggregated or de-identified information that is not linked to you.

We will not sell or rent your personal information to anyone.

At all times, TuSimple reserves the right to disclose your personal information where required by law or to comply with a valid legal process (such as a search warrant, subpoena, or court order), to investigate or remedy potential violations of our policies, to protect TuSimple’s rights or property, or during emergencies when personal safety is at risk.

We may also share your personal information with our third-party service providers (but only as necessary to provide services to us) and our affiliates, in which case we will require those third-party service providers and affiliates to keep such information confidential and use it only for the purposes for which we disclose it to them.

Among the third-party service providers that TuSimple uses, and which may collect your personal information on TuSimple’s behalf in order to provide services to TuSimple, are the following:

  • MailChimp. We use MailChimp to send newsletters and related communications when you sign up for a newsletter subscription or otherwise opt into communications from us. You can review MailChimp’s privacy policy at
  • Greenhouse. We use Greenhouse to assist with our employee recruitment and hiring process. You can review Greenhouse’s privacy policy at

Finally, we may share your personal information with a buyer or other successor company in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TuSimple’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by TuSimple about our website visitors is among the assets transferred.

Your Choices

If you have any questions as to how we collect and use your personal information, or would like to opt out of any future contacts from us, please contact us at In addition, to the extent required by applicable law, you may have the right to request access to or delete your personal information. If you wish to do any of these things, please contact us at the email address listed above.

Do Not Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. There is no final uniform technology standard for recognizing and implementing DNT signals. As a result, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

Links to External Websites

For your convenience and informational purposes, our Website may contain links to external websites that are not owned or controlled by TuSimple. TuSimple has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any external websites. If you visit such sites, your activities and the collection, use, and disclosure of information will be subject to the privacy policies and terms of the external websites or services, and not this Privacy Statement.

Children’s Privacy

TuSimple’s website is not intended for children. It is intended for adults. We do not knowingly collect personal information from children under the age of 13. If we find out that a child under 13 has given us personal information, we will take steps to delete that information.


We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. But no security measures are 100% secure and, thus, we cannot guarantee the security of your information. Any transmission of personal information is at your own risk. We are not responsible for the circumvention by any third party of any privacy settings or security measures we implement.

Job Candidate Privacy

For information regarding your privacy as a candidate for a position with TuSimple, please visit our Candidate Privacy Statement.

Privacy Inquiries and Information Requests

In some places you may have certain rights under privacy and data protection laws. These may include the right to request to have your personal information updated or deleted, to access your personal information, or to object to TuSimple using that personal information for certain purposes. These rights are subject to verification and certain exceptions. If you are a California resident, for instance, state law affords you certain privacy rights. You can learn more about these in the next section, “California Privacy Rights and Additional Information.”

No matter where you are from, if you have questions or concerns about TuSimple’s privacy practices or this Privacy Statement, please contact us at

California Privacy Rights and Additional Information

California Data Access and Deletion Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) allows you to make certain requests about your personal information (as defined in the CCPA). Specifically, the CCPA allows you to request that we:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third-parties with whom we share/disclose personal information. 
  • Provide access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have about you.
  • Provide you with information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide our Website to you.

  • Verification: Depending on the sensitivity of the information you are requesting and the type of request you are making, we will take reasonable steps to verify your identity based on the information that we currently possess. This may include, at a minimum, verifying your contact information and matching it with our records.
  • Authorized Agent: You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. 

The CCPA further provides you with the right not to be discriminated against (as provided for by applicable law) for exercising your access or deletion rights.

If you would like to exercise these rights please contact us as

California “Shine the Light” Disclosure

If you are a California resident you have the right to request information from TuSimple regarding the manner in which TuSimple shares certain categories of your personal information with third-parties, for the third-parties’ direct marketing purposes. We do not share personal information for such purposes.


We reserve the right to make changes to this Privacy Policy from time to time and for any reason. You should check this Privacy Policy regularly to see if there have been any changes. We will alert you about any changes by updating the “Updated” date of this Privacy Policy. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted changes in any revised Privacy Policy by your continued use of the website after the date the revised Privacy Policy is posted.

Questions and Comments

If you have questions or comments about this Privacy Policy, please email us at

TuSimple Privacy Statement for Applicants and Candidates

This Privacy Statement explains what information we collect during the application and recruitment process, how we use that information, and how you may access and update it.


TuSimple’s hiring process consists of multiple steps designed to evaluate your skills and qualifications for a particular position. When you choose to participate in the TuSimple hiring process, TuSimple may collect or obtain personal information about you. This information may include:

  • Name, address, email address, telephone number, and other contact information
  • Resume or CV and employment history
  • Driving history (where applicable)
  • Voluntary demographic information, including gender, race, ethnicity, citizenship, and/or nationality
  • Veteran status
  • Health information (only if required by law)
  • A government-issued ID (only where required by job responsibilities)
  • US Work Authorization Documentation

TuSimple will use the information that you provide to assist in our recruitment and hiring process, including the following:

  • Evaluating you for current and future job opportunities, including matching your skills and interests to applicable job requirements; 
  • Communicating with you throughout the hiring process; 
  • Complying with applicable laws, regulations, legal processes or government requests or inquiries; and 
  • Improving our hiring and/or recruitment processes, including improving our diversity and inclusion efforts. 
  • If you are offered and accept employment with TuSimple, information collected about you during the hiring process may become part of your employment record.

Data Retention and Deletion

We will retain your personal information for the period necessary to fulfill the purposes outlined in this statement unless longer retention is required by law or for auditing purposes. 

Privacy Inquiries and Correcting Your Information

If you have concerns or questions about this Privacy Statement for Applicants and Candidates or about TuSimple’s privacy practices, you may contact us at

In some places, you may have certain rights under data protection law. These may include the right to have your information updated or deleted, to access your information, or to object to TuSimple using it for certain purposes.

If you wish to access, correct, or delete your information, please contact We will process requests in accordance with applicable law, and there may be circumstances where we are not able to comply with your request.

Updates to Privacy Statement

We may update this Privacy Statement from time to time. We will post any changes to this policy to this page.