Privacy Policy

PRIVACY POLICY

  1. INFORMATION ABOUT THE COLLECTION OF PERSONAL DATA AND CONTACT DETAILS OF THE RESPONSIBLE PARTY

1.1 We are pleased that you are visiting our website and thank you for your interest. Below, we inform you about the handling of your personal data when using our website. Personal data refers to any data that can be used to personally identify you.

1.2 The responsible party for data processing on this website in the sense of the General Data Protection Regulation (GDPR) is [Shop Name]. The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data.

1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the responsible party). You can recognize an encrypted connection by the "https://" string and the lock symbol in your browser's address bar.

  1. DATA COLLECTION WHEN VISITING OUR WEBSITE

When using our website for informational purposes only, meaning if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called "server log files"). When you access our website, we collect the following data, which is technically necessary for us to display the website to you:

  • The visited website
  • Date and time of access
  • Amount of data sent in bytes
  • Source/referral from which you accessed the page
  • Browser used
  • Operating system used
  • IP address used (possibly in anonymized form)

The processing takes place in accordance with Art. 6 (1) (f) GDPR based on our legitimate interest in improving the stability and functionality of our website. Data will not be passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if there are concrete indications of illegal use.

  1. COOKIES

To make your visit to our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, meaning after you close your browser (so-called session cookies). Other cookies remain on your device and allow us or our partner companies (third-party cookies) to recognize your browser the next time you visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data, as well as IP address values.

Persistent cookies are automatically deleted after a specified duration, which can vary depending on the cookie. Some cookies serve to simplify the order process by storing settings (e.g., remembering the contents of a virtual shopping cart for a later visit to the website). If personal data is also processed by individual cookies we implement, the processing occurs in accordance with Art. 6 (1) (b) GDPR either for the performance of a contract or in accordance with Art. 6 (1) (f) GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit.

We may cooperate with advertising partners who help us make our online offering more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive (third-party cookies) during your visit to our website. If we cooperate with aforementioned advertising partners, you will be individually and separately informed about the use of such cookies and the scope of the information collected in the following paragraphs.

Please note that you can set your browser to be informed about the setting of cookies and decide individually on their acceptance or exclude the acceptance of cookies for specific cases or generally. Each browser differs in how it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find this information for the respective browsers at the following links:

  • Internet Explorer: [link]
  • Firefox: [link]
  • Chrome: [link]
  • Safari: [link]
  • Opera: [link]

Please note that if cookies are not accepted, the functionality of our website may be limited.

  1. CONTACTING US

When you contact us (e.g., via contact form or email), personal data is collected. The data collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in addressing your request in accordance with Art. 6 (1) (f) GDPR. If your contact aims to conclude a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR. Your data will be deleted after your request has been processed, provided that the circumstances indicate that the matter in question has been conclusively clarified and that no statutory retention obligations are opposed.

  1. DATA PROCESSING WHEN OPENING A CUSTOMER ACCOUNT AND FOR CONTRACT EXECUTION

According to Art. 6 (1) (b) GDPR, personal data will continue to be collected and processed when you provide us with this information to execute a contract or when opening a customer account. The data collected can be seen in the respective input forms. You can delete your customer account at any time by sending a message to the above address of the responsible party. We store and use the data you provide for contract execution. After full execution of the contract or deletion of your customer account, your data will be blocked in consideration of tax and commercial retention periods and will be deleted after these periods expire, unless you have expressly consented to further use of your data or we have reserved a legally permissible further use of data, which we will inform you about below.

  1. USE OF YOUR DATA FOR DIRECT MARKETING

6.1 Registration for our Email Newsletter

If you register for our email newsletter, we will regularly send you information about our offers. The only mandatory information for sending the newsletter is your email address. Providing additional data is voluntary and is used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an email newsletter once you have explicitly confirmed that you agree to receive the newsletter. We will then send you a confirmation email, asking you to confirm by clicking a corresponding link that you want to receive newsletters in the future. By activating the confirmation link, you give us your consent to use your personal data in accordance with Art. 6 (1) (a) GDPR. When you register for the newsletter, we store the IP address entered by your Internet Service Provider (ISP) as well as the date and time of registration in order to trace any potential misuse of your email address at a later date. The data collected during your registration for the newsletter will be used exclusively for the purpose of advertising through the newsletter. You can unsubscribe from the newsletter at any time via the designated link in the newsletter or by sending a corresponding message to the responsible party mentioned at the beginning. After unsubscribing, your email address will be deleted immediately from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve a further use of data that is legally permitted and which we inform you about in this statement.

6.2 Sending the Email Newsletter to Existing Customers

If you provided us with your email address when purchasing goods or services, we reserve the right to regularly send you offers for similar goods or services from our range via email. We do not need to obtain separate consent from you for this. Data processing is based solely on our legitimate interest in personalized direct advertising in accordance with Art. 6 (1) (f) GDPR. If you initially objected to the use of your email address for this purpose, we will not send you any emails. You have the right to object to the use of your email address for the aforementioned advertising purpose at any time with effect for the future by notifying the responsible party mentioned at the beginning. For this, you will only incur transmission costs according to basic tariffs. Upon receipt of your objection, the use of your email address for advertising purposes will be stopped immediately.

  1. DATA PROCESSING FOR ORDER PROCESSING

7.1 The personal data we collect will be shared with the transport company commissioned for delivery, as far as this is necessary for the delivery of the goods. Your payment data will be shared with the bank involved in payment processing, as far as this is necessary for payment processing. If payment service providers are used, we will explicitly inform you about this below. The legal basis for sharing the data is Art. 6 (1) (b) GDPR.

7.2 Use of Payment Service Providers

  • PayPal: When paying via PayPal, credit card via PayPal, direct debit via PayPal, or – if offered – "purchase on account" or "installment payment" via PayPal, we will share your payment data with PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal") as part of payment processing. The transfer is made in accordance with Art. 6 (1) (b) GDPR and only to the extent necessary for payment processing. PayPal reserves the right to conduct a credit check for the payment methods credit card via PayPal, direct debit via PayPal, or – if offered – "purchase on account" or "installment payment" via PayPal. For this purpose, your payment data may be shared with credit agencies in accordance with Art. 6 (1) (f) GDPR based on PayPal's legitimate interest in assessing your creditworthiness. The result of the credit check regarding the statistical likelihood of payment default is used by PayPal to decide on the provision of the respective payment method. The credit check may contain probability values (so-called score values). To the extent that score values are included in the result of the credit check, they are based on a scientifically recognized mathematical-statistical procedure. Address data is included in the calculation of score values, among other factors. Further data protection information, including information about the credit agencies used, can be found in PayPal's privacy policy: [link]. You can object to this processing of your data at any time by notifying PayPal. However, PayPal may still be entitled to process your personal data to the extent necessary for contractual payment processing.

  • SOFORT: If the payment method "SOFORT" is selected, the payment processing is carried out by the payment service provider SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany (hereinafter "SOFORT"), to whom we will provide your information shared during the order process along with the information about your order in accordance with Art. 6 (1) (b) GDPR. SOFORT GmbH is part of the Klarna Group (Klarna Bank AB (publ), Sveavägen 46, 11134 Stockholm, Sweden). Your data will be shared exclusively for the purpose of payment processing with the payment service provider SOFORT and only to the extent that it is necessary for this purpose. Further information about SOFORT’s data protection regulations can be found at the following Internet address: [link].

  1. CONTACTING US FOR REVIEW REMINDERS

Own Review Reminder (not sent by a customer review system): We use your email address to remind you once to submit a review of your order for the review system we use, provided that you have given us your explicit consent in accordance with Art. 6 (1) (a) GDPR during or after your order. You can withdraw your consent at any time by sending a message to the responsible party for data processing.

  1. USE OF SOCIAL MEDIA: SOCIAL PLUGINS

9.1 Facebook Plugins with Shariff Solution: Special additional customs clearance costs and/or import duties are not included in the price and are borne by the customer. Our website uses so-called social plugins ("plugins") from the social network Facebook, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA ("Facebook"). To increase the protection of your data when visiting our website, these buttons are not integrated as unrestricted plugins, but are instead embedded using an HTML link on the page. This type of integration ensures that when you access a page of our website that contains such buttons, no connection to Facebook's servers is established yet. When you click the button, a new browser window opens and calls the Facebook page, where you can interact with the plugins there (possibly after entering your login details). Facebook Inc., based in the USA, is certified under the US-European Privacy Shield agreement, which ensures compliance with the data protection level applicable in the EU. The purpose and scope of data collection, the further processing and use of the data by Facebook, as well as your related rights and settings options for the protection of your privacy can be found in Facebook's privacy policy: [link].

9.2 Google+ Plugins as Shariff Solution: Our website uses so-called social plugins ("plugins") from the social network Google+, operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). To increase the protection of your data when visiting our website, these buttons are not integrated as unrestricted plugins, but are embedded using an HTML link on the page. This type of integration ensures that when you access a page of our website that contains such buttons, no connection to Google+ servers is established yet. When you click the button, a new browser window opens and calls the Google+ page, where you can interact with the plugins there (possibly after entering your login details). Google LLC, based in the USA, is certified under the US-European Privacy Shield agreement, which ensures compliance with the data protection level applicable in the EU. The purpose and scope of data collection, the further processing and use of the data by Google, as well as your related rights and settings options for the protection of your privacy can be found in Google's privacy policy: [link].

9.3 Instagram Plugin as Shariff Solution: Our website uses so-called social plugins ("plugins") from the online service Instagram, operated by Instagram LLC, 1601 Willow Rd, Menlo Park, CA 94025, USA ("Instagram"). To increase the protection of your data when visiting our website, these buttons are not integrated as unrestricted plugins, but are embedded using an HTML link on the page. This type of integration ensures that when you access a page of our website that contains such buttons, no connection to Instagram's servers is established yet. When you click the button, a new browser window opens and calls the Instagram page, where you can interact with the plugins there (possibly after entering your login details). Instagram LLC, based in the USA, is certified under the US-European Privacy Shield agreement, which ensures compliance with the data protection level applicable in the EU. The purpose and scope of data collection, the further processing and use of the data by Instagram, as well as your related rights and settings options for the protection of your privacy can be found in Instagram's privacy policy: [link].

10) ONLINE MARKETING

10.1 DoubleClick by Google

This website uses the online marketing tool DoubleClick by Google, operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("DoubleClick"). DoubleClick uses cookies to display relevant ads to users, improve campaign performance reports, or prevent users from seeing the same ads multiple times. Through a cookie ID, Google tracks which ads are served in which browser and can thus prevent them from being shown repeatedly. The processing is based on our legitimate interest in optimally marketing our website according to Art. 6 (1) (f) GDPR. Furthermore, DoubleClick can capture so-called conversions related to ad requests using cookie IDs. This occurs, for instance, when a user views a DoubleClick ad and later visits the advertiser's website using the same browser and makes a purchase there. According to Google, DoubleClick cookies do not contain personal information. Due to the marketing tools used, your browser automatically establishes a direct connection with Google’s server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our knowledge: By integrating DoubleClick, Google receives the information that you have accessed the corresponding part of our online presence or clicked on one of our ads. If you are registered with a Google service, Google can associate the visit with your account. Even if you are not registered with Google or logged in, there is a possibility that the provider can learn and store your IP address. If you wish to object to participating in this tracking process, you can deactivate cookies for conversion tracking by configuring your browser to block cookies from the domain www.googleadservices.com, https://www.google.de/settings/ads; however, this setting will be deleted if you clear your cookies. Alternatively, you can inform yourself about cookies and make settings at the Digital Advertising Alliance at www.aboutads.info. Finally, you can configure your browser to notify you when cookies are set and to decide individually on their acceptance or to exclude the acceptance of cookies for certain cases or generally. If you do not accept cookies, the functionality of our website may be limited. Google LLC, based in the USA, is certified under the US-European data protection agreement "Privacy Shield," which ensures compliance with the level of data protection applicable in the EU. More information about DoubleClick by Google's privacy policy can be found at: https://www.google.de/policies/privacy/

10.2 Use of Google AdWords Conversion Tracking

This website uses the online advertising program "Google AdWords" and, as part of Google AdWords, the conversion tracking of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use the Google AdWords service to draw attention to our attractive offers on external websites using advertisements (so-called Google AdWords). We can determine how successful individual advertising measures are in relation to the campaign data. Our goal is to display ads that are relevant to you, make our website more interesting for you, and achieve fair calculation of advertising costs. The conversion tracking cookie is set when a user clicks on an ad served by Google AdWords. Cookies are small text files that are stored on your computer system. These cookies usually expire after 30 days and do not serve for personal identification. If the user visits certain pages of this website and the cookie has not expired, Google and we can recognize that the user has clicked on the ad and has been redirected to this page. Each Google AdWords customer receives a different cookie. Cookies cannot be tracked across the websites of AdWords customers. The information collected by the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive information that can personally identify users. If you do not wish to participate in tracking, you can block the use by deactivating the Google conversion tracking cookie through your internet browser under user settings. You will then not be included in the conversion tracking statistics. We use Google AdWords based on our legitimate interest in targeted advertising according to Art. 6 (1) (f) GDPR. Google LLC, based in the USA, is certified under the US-European data protection agreement "Privacy Shield," which ensures compliance with the level of data protection applicable in the EU. More information about Google's privacy policy can be found at: https://www.google.de/policies/privacy/ You can permanently disable cookies for ad preferences by preventing them through a corresponding setting in your browser software or by downloading and installing the browser plug-in available at the following link: https://www.google.com/settings/ads/plugin?hl=en Please note that certain features of this website may not be available or may be limited if you have disabled the use of cookies.

11) WEB ANALYSIS SERVICES

Google (Universal) Analytics - Google Universal Analytics

This website uses Google Analytics, a web analysis service from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses so-called "cookies," text files that are stored on your computer and allow for an analysis of your use of the website.


The information generated by the cookie about your use of this website (including the truncated IP address) is generally transmitted to and stored on a server of Google in the USA. This website uses Google Analytics exclusively with the "_anonymizeIp()" extension, which ensures the anonymization of the IP address by truncation and excludes direct personal reference. Through this extension, your IP address is truncated by Google within member states of the European Union or in other contracting states of the agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a server of Google in the USA and truncated there. In these exceptional cases, this processing is carried out in accordance with Art. 6 (1) lit. f GDPR based on our legitimate interest in statistical analysis of user behavior for optimization and marketing purposes. On our behalf, Google will use this information to evaluate your use of the website, compile reports on website activities, and provide other services related to website use and internet use.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. You can prevent the storage of cookies by adjusting your browser software; however, we would like to point out that in this case you may not be able to use all features of this website to their full extent. Additionally, you can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: Google Analytics Opt-out Plugin.

As an alternative to the browser plugin or within mobile device browsers, please click on the following link to set an opt-out cookie that will prevent future collection by Google Analytics on this website (this opt-out cookie works only in this browser and only for this domain; if you delete your cookies in this browser, you will need to click this link again): Disable Google Analytics.

Google LLC, based in the USA, is certified under the US-European Privacy Shield agreement, which ensures compliance with the data protection level applicable in the EU. This website also uses Google Analytics for cross-device analysis of visitor flows, conducted through a user ID. Upon the first visit to a page, a unique, permanent, and anonymized ID is assigned to the user, which is set across devices. This allows for interaction data from various devices and sessions to be attributed to a single user. The user ID does not contain any personal data and does not transmit such data to Google. The data collection and storage via the user ID can be objected to at any time with future effect. For this, you must deactivate Google Analytics on all systems you use, for example, in another browser or on your mobile device. You can deactivate it using a Google browser plugin (Google Analytics Opt-out Plugin).

As an alternative to the browser plugin or within mobile device browsers, please click on the following link to set an opt-out cookie that will prevent future collection by Google Analytics on this website (this opt-out cookie works only in this browser and only for this domain; if you delete your cookies in this browser, you will need to click this link again): Disable Google Analytics.

For more information on Universal Analytics, you can find it here: Universal Analytics Information.

12) RETARGETING/REMARKETING/ADVERTISING

Facebook Custom Audience via Pixel Method: This website uses the "Facebook Pixel" from Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). With your explicit consent, this allows for tracking user behavior after they have viewed or clicked on a Facebook advertisement. This process serves to evaluate the effectiveness of Facebook advertisements for statistical and market research purposes and may help optimize future advertising efforts. The collected data is anonymous to us and does not allow conclusions to be drawn about the identity of users. However, the data is stored and processed by Facebook, allowing it to connect to the respective user profile and use the data for its own advertising purposes according to Facebook's data usage policy (Facebook Privacy Policy). You can enable Facebook and its partners to show ads on and off Facebook. Additionally, a cookie may be stored on your computer for these purposes. These processing activities only occur with your explicit consent in accordance with Art. 6 (1) lit. a GDPR. Consent to use the Facebook Pixel may only be given by users older than 13 years. If you are younger, please ask your guardians for permission.

Facebook Inc., based in the USA, is certified under the US-European Privacy Shield agreement, which ensures compliance with the data protection level applicable in the EU. To disable the use of cookies on your computer, you can configure your internet browser to prevent future cookies from being stored on your computer or to delete already stored cookies. Disabling all cookies may, however, lead to some functionalities on our websites no longer being executable. You can also disable the use of cookies by third parties like Facebook on the Digital Advertising Alliance website: Digital Advertising Alliance Choices.

Google AdWords Remarketing: Our website uses the features of Google AdWords Remarketing, advertising for this website in Google search results as well as on third-party websites. The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). For this purpose, Google sets a cookie in your browser, which automatically enables interest-based advertising based on a pseudonymous cookie ID and the pages you have visited. Processing occurs based on our legitimate interest in optimal marketing of our website in accordance with Art. 6 (1) lit. f GDPR. Further data processing only takes place if you have consented to Google linking your internet and app browsing history with your Google account and using information from your Google account to personalize ads you see on the web. If you are logged into Google during your visit to our website, Google uses your data along with Google Analytics data to create and define audience lists for cross-device remarketing. Your personal data is temporarily linked by Google with Google Analytics data to form audiences. You can permanently disable the setting of cookies for ad preferences by downloading and installing the browser plugin available at the following link: Google Ads Settings.

Alternatively, you can learn about setting cookies and make settings through the Digital Advertising Alliance at Digital Advertising Alliance. Finally, you can configure your browser to inform you when cookies are set and decide individually on their acceptance or exclude the acceptance of cookies for specific cases or in general. If you do not accept cookies, the functionality of our website may be limited. Google LLC, based in the USA, is certified under the US-European Privacy Shield agreement, which ensures compliance with the data protection level applicable in the EU. Further information and the privacy policy regarding advertising and Google can be viewed here: Google Ads Policies.

13) Rights of the Data Subject

13.1 The applicable data protection law grants you comprehensive rights concerning the processing of your personal data in relation to the controller, which we inform you about below:

Right to Access under Art. 15 GDPR: You have the right to obtain information about your personal data processed by us, including the purposes of processing, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned retention period or the criteria for determining the retention period, the existence of the right to rectification, deletion, restriction of processing, objection to processing, lodging a complaint with a supervisory authority, the source of your data if it was not collected from you, the existence of automated decision-making, including profiling, and, if applicable, meaningful information about the logic involved and the significance and expected consequences of such processing, as well as your right to be informed about the guarantees in accordance with Art. 46 GDPR when your data is transferred to third countries.

Right to Rectification under Art. 16 GDPR: You have the right to obtain the immediate rectification of inaccurate data concerning you and/or to complete any incomplete data stored by us.

Right to Deletion under Art. 17 GDPR: You have the right to request the deletion of your personal data where the conditions of Art. 17 (1) GDPR are met. However, this right does not exist in particular if processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims.

Right to Restriction of Processing under Art. 18 GDPR: You have the right to request the restriction of processing of your personal data as long as the accuracy of your data, which you contest, is being verified; if you refuse the deletion of your data due to unlawful processing and instead request the restriction of processing; if you need your data for the establishment, exercise, or defense of legal claims after we no longer need it for processing purposes; or if you have lodged an objection for reasons relating to your particular situation, as long as it has not yet been determined whether our legitimate grounds override yours.

Right to Notification under Art. 19 GDPR: If you have asserted the right to rectification, deletion, or restriction of processing against the controller, they are obligated to notify all recipients to whom your personal data has been disclosed of this rectification or deletion of data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.

Right to Data Portability under Art. 20 GDPR: You have the right to receive your personal data that you have provided to us in a structured, commonly used, and machine-readable format, or to request the transfer to another controller, insofar as this is technically feasible.

Right to Withdraw Consent under Art. 7 (3) GDPR: You have the right to withdraw any consent you have given for data processing at any time with effect for the future. In the event of withdrawal, we will immediately delete the affected data, unless further processing is based on a legal ground for processing without consent. The legality of processing based on consent prior to withdrawal remains unaffected.

Right to Lodge a Complaint under Art. 77 GDPR: If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority, particularly in the member state of your residence, your workplace, or the place of the alleged infringement, without prejudice to any other administrative or judicial remedy.

Right to Object: If we process your personal data based on our legitimate interests in the context of a balancing of interests, you have the right to object to this processing at any time on grounds relating to your particular situation, with future effect. If you exercise your right to object, we will cease processing the affected data. Further processing may still be permitted if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or if the processing serves to establish, exercise, or defend legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purposes of such marketing. You can exercise this right to object as described above. If you exercise your right to object, we will cease processing the affected data for direct marketing purposes.

Duration of Storage of Personal Data: The duration of the storage of personal data is based on the respective statutory retention periods (e.g., commercial and tax retention periods). After the retention period has expired, the corresponding data will be routinely deleted, unless it is no longer required for contract fulfillment or pre-contractual measures and/or we have no legitimate interest in retaining it further.