Privacy policy

Last updated - 1st January, 2022

 

Welcome to our website, www.mararhomberg.com.

www.mararhomberg.com (hereafter also named the “Website”) is a site operated by Mara Is Not Limited (“Mara Rhomberg,” “we,” “us,” or “our”). Mara Is not Ltd. is a company incorporated and registered in Hong Kong under company registration number 2366324, with registered offices at Suite 3401, 34/F, One Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong.

 

At Mara Rhomberg, we value the protection of privacy and how personal information is protected and shared. This privacy policy (“Privacy Policy” or “Privacy Statement”) has been created to ensure the appropriate measures are in place so that we are able to responsibly process all personal information you share with us. This Privacy Policy sets out clear guidelines on how your personal information is processed and for you to understand the policies we maintain. We take your privacy seriously and we appreciate that you care about how information you provide to us is used and shared. It is important that you read this privacy policy in conjunction with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully informed on how and why we collect and use your information. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

Mara Is Not Limited (collectively referred to as “Mara Rhomberg,” “we,” “us,” or “our” in this privacy policy) is the controller and responsible for the collection and management of your personal data and takes specific measures designed to keep your personal data secure.

This Privacy Statement relates to the information collection and use practices of Mara Rhomberg in connection with our online services, including through our Website www.mararhomberg.com and all corresponding web pages thereof, applications, features, functionality, information and services made available by us on or through any of the foregoing (collectively known as, the “Website”). This Privacy Statement describes the types of personal information that we collect, how we use it, how and when it may be shared, and the rights and choices you have with respect to your information. It also explains how we communicate with you and how you can make requests or submit inquiries to us about your information. Our goal is to help you understand all of this, as part of our commitment to maintaining your trust. Please also use our Glossary to understand the meaning of some of the terms used within this document.

By using our Website, you agree to the terms set out in this Privacy Policy.

 

 

1 - Information we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. When you use our Website, we may collect, use, store and transfer different kinds of personal information about you and your use of the Website. This information collection falls under two main categories: 

 

Information you voluntarily provide us - When submitting information, you will always be informed either the input is voluntary or a requirement for the implementation of the desired action (e.g. completing a transaction on the website). 

Form submissions - Information that you provide by filling in forms that we make available on the Website, such as to contact us to request information or assistance, or subscribing to our newsletter and when creating a customer account on the Website.

Technical support and customer service - When you report a problem with the Website or otherwise communicate with us by email, via our Website, or through other means, we process the personal information you provide us with, including any records and copies of your correspondence that you provide.

Purchase information - As part of the buying and selling process, we collect the personal information necessary to complete and execute your purchase such as given name and surname, email address, shipping and billing address, telephone numbers and payment details.

Marketing and communications information - Includes your preferences in receiving marketing materials from us and our third parties, as well as your communication preferences. With your permission, we may send you emails about new products and other updates.

 

Information we collect from you automatically - As you navigate through our Website or otherwise interact with us, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns.

Information about your use of the services - When you browse our Website, our systems automatically collect information such as your web request, login data, Internet Protocol (“IP”) address, browser type, browser language, time zone setting and location, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request.

Device information - If you access the Website through a mobile device (e.g., a smartphone or tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system and platform, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID. However, this information resides in server logs and is not used for advertising or marketing purposes.

Performance data - We may collect information about your preferences to make your use of the Website more productive and for our internal analytics.

 

We also collect, use and share aggregated data such as statistical and demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any ‘Special Categories of Personal Data’, which may include details about your race or ethnicity, religious or philosophical beliefs, sexual orientations, political opinions, information about your health and genetic or biometric data. Nor do we collect any information about criminal convictions and offences.

If you fail to provide the data when requested, where we need to collect personal data by law or under the terms of a contract we have with you, we may not be able to perform our contractual obligations nor complete the contract we are trying to enter with you. In this case, we may have to cancel the product or service you are attempting to obtain from us and will notify you of such cancellation.

 

 

2 - How we collect your information

We use different methods to collect information from and about you including:

Direct interactions - You may give us information concerning your identity, contact and financial data by filling in forms or by corresponding with us. This includes personal information you provide when you inquire about our products or services, create a user account on our Website, subscribe to our newsletter, request marketing materials to be sent to you, enter any competition, promotion or survey, or give us feedback and contact us.

Automated interactions - As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this information by using cookies and other similar technologies. Please read the section in this document concerning our Cookies Policy to find out more.

 

 

3 - How we use your information

We will only use your information as permitted by law. Most commonly, your information will be used in the following circumstances:

- Where we need to perform the contract, we are about to enter into or have entered with you.

- Where it is necessary for our legitimate interests(or those of a third party) and your interests. Fundamental rights do not override those interests.

- Where we need to comply with a legal obligation.

 

Generally, we do not rely on consent as a legal basis for processing your personal information. When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return of a purchase, you confirm giving your consent to our collection of your information and using it for that specific reason only. If we require your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, and deletion of your information at any time  by contacting us at customerservice@mararhomberg.com.

Please refer to our Glossary to find out more about the types of lawful basis on which we will process your personal information.

 

Purposes for which we will use your personal information

A description of all the ways we plan to use your personal information, and which of the legal bases apply is summarised in the table below. Our legitimate interests have also been indicated where appropriate.

Please note that we may process your personal information for more than one lawful basis depending on the specific circumstance for which we are using your information. Please contact us if you require details about the specific legal circumstance we are relying on to process your personal information where more than one basis has been set out in the table below.

  

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

  

Marketing

We may use your identity, contact, technical, usage and profile information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which product, services and offers may be relevant to you.

We do our best to provide you with choices regarding certain personal information uses, particularly concerning marketing and advertising. You will receive marketing communications from us if you have requested information from us or have made a purchase with us and you have not opted out of receiving our marketing communications.

Third-Party Marketing

We will request for your direct consent before sending third party direct marketing communications to you. If you have given permission, we may share your personal data with organisations who are our business partners and we, or they, may contact you, unless you have asked us or them not to do so in writing via email about e.g. products, services, promotions, special offers, charitable causes that may be of interest to you. If you prefer not to receive any further direct marketing communications from us, or our business partners, you can opt out at any time. See further ‘Opting Out’, below.

Opting Out

You can ask us or third parties to stop sending you marketing communications at any time. Please contact us at customerservice@mararhomberg.com or directly follow the opt-out links indicated within the marketing communications you have received. Where you opt out of receiving marketing communications, this will not apply to the collection of personal information as a result of a product or service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note, if you disable cookies, some parts of this website may become inaccessible or not function properly. For further information, please read our Cookies Policy.

Change of Purpose

Your personal information will only be used for the purpose collected, unless we consider that it needs to be used for another purpose and that purpose is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal information for an unrelated purpose, you will be notified and explained the legal basis which allows us to do so.

 

 

4 - Disclosure of your information

Under the following circumstances, we will transfer your personal information to other parties:

- Share aggregated, anonymised or other de-identified information with advertisers, advertising networks and social networks that require the information to select and serve relevant adverts to you and others. We will also use aggregate information to help advertisers reach the kind of audience desired to target.

- Make use of the personal information we have collected from you to help our advertisers display their advertisement to a targeted audience and to present our promotional materials to you. This means you will be presented with advertisements that are more accurately relevant to you.

- Share your personal information with and access information from analytics and search engine providers that assist us in the improvement and optimisation of our Website and for better personalisation of content and advertising.

We share your information with certain contractors or service providers, which may include marketing and advertising agencies, IT suppliers, database providers, backup and disaster recovery specialists, and email providers.

Our suppliers and service providers will be bound to meet our policies on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purpose other than those outlined within this privacy agreement.

Please note, certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you proceed with a transaction that involves the service of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that provider or its facility is located.

 

We also share your information with certain third parties. We will only do this once we have received your consent or because we need them to see your information so that we may provide you with the products or services requested. These include:

- Our payment processing service provider Shopify Payments (view Shopify Payment’s Terms of Service)

- Our shopping platform provider Shopify (view Shopify’s privacy statement)

- Our operations and logistics partner 

If you do not agree to share your information with these third parties, you will not be able to buy products on our Website.

 

Your personal information may be transferred to other third parties under the following circumstances:

- If we discuss selling or transferring part or all of our business, then the new owners may use your personal information as set out in this privacy agreement.

- If we are reorganised and sold, your personal information may be transferred so that the new owner can continue providing services to you.

- If we are required to by law, or under any regulatory code or practice we follow, or if we are required to do so by any public or regulatory authority.

- If we are defending a legal claim, your personal information may be transferred as required in connection with defending such claim.

- If there is an emergency which requires us to share your personal information to protect the health and safety of our website’s users or the general public.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specific purposes and in accordance with our instructions.

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

Your personal information may also be shared with third parties if it is made anonymous and aggregated. In such circumstances, the information will cease to be personal information.

  

 

5 - International transfers

We share your personal information with our suppliers and service providers, many of which are based outside the EEA. Therefore, their processing of your personal information will involve a transfer of information outside the EEA.

When transferring your personal information out of the EEA, we ensure a similar degree of protection is provided by ensuring at least one of the following measures is implemented:

- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.  

- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further detail, see European Commission: Model contracts for the transfer of personal data to third countries.

- Where we use providers based in the US, we may transfer information to them if they are part of the Privacy Shield, which requires them to maintain similar protection measures to personal information shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

- In the absence of an adequacy decision or appropriate contractual safeguards we may rely on derogations for specific situations. For further details, see GDPR Article 49: Derogations for specific situations

Please contact us if you require further information on the specific mechanism used by us when transferring your personal information out of the EEA.

  

 

6 - Security

We have tasked ourselves to implement appropriate security measures to maintain the security of your personal information. Such measures prevent your personal information from being inappropriately lost, misused, accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to only those employees, agents, contractors and other third parties who have the need to know. They will only process your personal information upon our instructions and are subject to a duty of confidentiality.

In addition, we also have measures in place to maintain any suspected breach of personal information and will notify you and any applicable regulatory authorities of a breach where we are legally required to do so.

 

 

7 - Retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period of personal information, we consider the amount, nature and sensitivity of such information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purpose for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We are required by law to maintain basic information about our customers including contact, identity, financial and transaction information for 6 years after they cease being customers for tax purposes.

In some circumstances, you have the right to request us to delete your information. Please review the ‘Your rights and revoking consent’ section below for more information.

In some circumstances, we will anonymise your personal information, so that it may no longer be associated with you, for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

 

8 - Cookies Policy

Cookies are used almost by all websites and are in many cases necessary to deliver a given service on the website. Cookies are small text files that are stored on your browser or the hard drive of your computer when you visit a website, so that your device can be recognised the next time you visit the website. Cookies are used for the purposes such as compilation of statistics about visitors’ use of the website to assist in the optimisation of site content. Cookies are safe, passive and reliable files that are unable to run programming code, unable to spread viruses and do not provide information about other usages of your device. 

 

There are three main types of cookies:

Session cookies - Specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so that you don’t have to re-enter information when navigating to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;

Persistent cookies - Records information about your preferences and are stored in your browser cache or mobile device; and

Third party cookies - Placed by someone other than us. These other third-party websites may use cookies or similar technologies in accordance with their own separate policies. They may feature standard content, gather data across multiple websites or sessions and can also be used as analytical tools or embedded comment fields. For privacy information relating to these other third party websites, please consult their policies where appropriate.

 

Your consent is required for us to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested. You can withdraw your consent to the use of cookies or manage your cookie preferences at any time. Please note, that by withdrawing your consent that allows the use of cookies, it may have an impact on your purchasing experience.

We use cookies, including third party cookies, to personalise, enhance your experience on our site, as well as for analytical and advertising purposes. We do not use cookies to store or collect personal information.

 

Below is a detailed explanation of the cookies we use and how they work:

Strictly necessary (essential) cookies are required for the operation of our Website and enabling basic functions like page navigation, access to secure areas of our Website, use of a shopping cart or our check-out process. The Website can not function properly without these cookies and therefore we will not request your consent.

Analytical or performance cookies allow us to recognise and monitor the number of visitors on our Website, as well as their browsing behaviour. This information allows us to optimise our Website, for example, ensuring that users easily find what they are looking for. These cookies are sometimes placed by third party providers of web traffic and analysis services, over which we have no control. These named third parties may include advertising networks and providers of external services like web traffic analysis services.

Functionality cookies are used to recognise you when you return to our Website. This enables us to personalise our content for you (for example, your choice of language and location).

Targeting cookies collect information about your browsing behaviour and inferred interests to make advertising more relevant to you. They are also used to limit the number of times an advert appears to you and measure the effectiveness of an advertising campaign. These cookies are usually placed by third party advertising networks. They remember the other websites you visit and this information is shared with third-party organisations, such as advertisers.

When you visit other websites, you may see an advertisement by us because you visited our website. You may opt-out of network advertising programs that track your activities across multiple websites with the aim to deliver targeting advertising content to you.

Social media cookies allow users to share our Website content on social media such as Facebook, Instagram and Twitter. These cookies are not within our control. Kindly refer to the respective privacy policies of the social media providers for how their cookies work. 

All European websites are obliged to inform users about the type of cookies that are being placed on users’ devices. This information must be in accordance with the “Regulation on the requirements for information and consent for the storing of and access to information on end user’ terminal devices” (normally referred to as “the Cookie Order”).

We reserve the right to review the terms and conditions set forth in this agreement and may update this Privacy Policy from time to time. We will inform you of such changes via email or by placing a notice on the Website.

Please contact us at customerservice@mararhomberg.com if you have any questions regarding our cookie policy.

 

 

9 - Shopify 

Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.

We cannot be responsible for the privacy policies and practices of other third-party sites, even if you access them using links from our site and we recommend that you check the policies of each site you visit.

 

 

10 - Changes and updates to our privacy policy

We keep our Privacy Policy under regular review and reserve the right to modify this Privacy Policy at any time. The effective date of the revised terms and conditions will be stated at the top of this page. Changes and clarifications will take effect immediately upon their posting on the Website. If we make changes to this Privacy Policy, we will give you notice by posting a notice on our Website. Your continued use of our Website constitutes your agreement to such changes and it is your responsibility to ensure you review and understand the terms and conditions that apply at the time of use of our Website.

It is equally important that the personal data we hold about you is accurate and current. Please kindly inform us if your personal data changes during the course of our relationship.

 

 

11 - Age of consent

While our Website is designed for a general audience, we will not knowingly collect information from children under the age of 13 or sell products to children. If you are under the age of 18, you are not permitted to register an account, use or submit your data to this Website.

If we discover that we have collected personal information from a child under the age of 18, we will immediately suspend the associated account and remove that information from our database.

By using this site, you represent that you are at least the age of majority in your state, province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

 

 

12 - Your rights and revoking consent 

Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please click on the links below to learn more about these rights:

- Request access to your personal information

- Request correction of your personal information

- Request erasure of your personal information

- Object to processing of your personal information

- Request restriction of processing your personal information

- Request transfer of personal information

- Right to withdraw consent

 If you wish to exercise any of the rights set out above, please contact us at customerservice@mararhomberg.com.

 

No Fees Usually Required

You will not have to pay a fee to access your personal information or to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive and under these circumstances, we could refuse to comply with your request.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to obtain further information in relation to your request to assist in our process of a response. 

Time Limit to Respond  

We try to respond to all legitimate requests within 5 working days. In some instances, it could take us longer than the provided time frame, if your request is particularly complex or if you have a number of requests, in which case we will notify you of any delay and keep you informed.

 

 

13 - Contacting us

We welcome your questions, comments about our privacy practices and this Privacy Policy, or if you would like to exercise any of your applicable privacy rights. You may at any time contact us at customerservice@mararhomberg.com. You may also obtain a copy of your personal data at any time and can always ask us to rectify any incorrect information, delete or raise an objection or limit the processing of your personal information.

 

 

14 - Glossary

Lawful Basis 

- Legitimate Interest - The interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

- Performance of Contract - Processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

- Comply with a legal obligation - Processing your personal information where it is necessary for compliance with a legal obligation that we are subject to.

- Consent - Processing your information where you have freely given, specific, informed and unambiguous indication of your wishes.

 

Your Legal Rights  

- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

- Request correction of your personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

- Request erasure of your personal information enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

- Request transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

- Right to withdraw consent where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

- Request restriction of processing of your personal information enables you to ask us to suspend the processing of your personal information in the following scenarios:

- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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