Privacy Statement

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Contents of our Privacy Statement

1       Information on this Privacy Statement
2       Terminology
3       Contact
3.1         The Controller
3.2         The Data Protection Officer
3.3         Security of Contact
4       Legal Basis for the Processing of Personal Data
5       Erasure of Data and Storage Period
6       Data Protection in Job Application Processes
7       Information on the Use of this Website
7.1         Cookies
7.2         The Collection of General Data and Information
7.3         Links / Redirection to Third-Party Websites
8       Rights of Data Subjects
8.1         Right of Access
8.2         Right to Rectification
8.3         Right to Erasure
8.4         Right to the Restriction of Processing
8.5         Right to Data Portability
8.6         Right to Object to Data Processing
8.7         Automated Decision-Making (including Profiling)
8.8         Right to Revoke Consent to Data Processing
8.9         Right to Lodge a Complaint with a Supervisory Authority
9       Use of Automated Decision-Making
10    Other Functions and Tools on this Website
10.1       Web Marketing
10.1.1        Google AdWords
10.1.2        Google Remarketing
10.2       Analytical Tools
10.2.1        Google Analytics (with Anonymisation Function)
10.3       Social Media
10.3.1        YouTube
10.4       WordPress Plug-Ins
10.4.1        AddThis

1       Information on this Privacy Statement

Thank you for your interest in our company. The management team at Schultheiß Projektentwicklung AG attaches great importance to data protection.

If you use certain services provided by our company (e.g. our website), we may need to process your personal data. You shall then be considered a “data subject” within the meaning of the relevant data protection regulations.

When processing personal data like the name, address, phone number or email address of data subjects, we shall always observe the provisions of the General Data Protection Regulation and the applicable data protection regulations in the relevant country.

If there is no legal basis for the processing of personal data, we shall generally obtain the consent of the data subject before carrying out processing.

The aim of this Privacy Statement is to inform the public about the nature, scope and purpose of the personal data that we collect, use and process. We would also like to inform data subjects about their rights.

Schultheiß Projektentwicklung AG takes various technical and organisation measures to ensure the best possible protection of the personal data it processes. Nevertheless, the transfer of personal data via the Internet may be affected by security issues, and so it is not always possible to guarantee complete protection. Each data subject is therefore free to transmit such data to us by other means, such as over the phone.

2       Terminology

The terminology below is used in accordance with the definitions set forth in Article 12(1) of the General Data Protection Regulation (GDPR) and Section 2 of the German Federal Data Protection Act (BDSG). The GDPR text can be accessed here: https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016R0679&from=DE. The BDSG text can be accessed here: https://www.bgbl.de/xaver/bgbl/start.xav?start=%2F%2F*[%40attr_id%3D’bgbl117s2097.pdf

3       Contact

The “controller” within the meaning of the General Data Protection Regulation (GDPR) and other data protection provisions is:

3.1      The Controller

The “Controller” within the meaning of the General Data Protection Regulation (GDPR) and other data protection regulations is:

Schultheiß Projektentwicklung AG.
Großreuther Straße 70
90425 Nürnberg
Germany
+49 (0)911-93425-0
Email: info@schultheiss-projekt.de
Website: www.schultheiss-projekt.de

3.2      The Data Protection Officer

Our Data Protection Officer is:

Jörg Stroh (external)
Großreuther Straße 70
90425 Nürnberg
Germany
+49 (0)911-93425-0
Email: datenschutz@schultheiss-projekt.de
Website: www.schultheiss-projekt.de

Data subjects can always contact our Data Protection Officer with any questions and suggestions they may have about data protection.

If a data subject contacts us via email or through the contact form on our website, we shall save this voluntarily provided information to process the enquiry and respond to any follow-up questions. We shall only save and use further personal data with the consent of the data subject, or if this is legally permissible without any special consent.

With the exception of any information required by public authorities and our external Data Protection Officer, this personal data shall not be disclosed to third parties.

3.3      Security of Contact

We make every effort to ensure the security of the personal data of data subjects within the scope of the applicable data protection laws and technical possibilities. Any personal data entered on our website shall be transferred to us in an SSL-encrypted format (Secure Sockets Layer).

Please note, however, that data transferred via the Internet (e.g. email communication) may be affected by security issues. Data cannot be completely protected against third-party access.

We shall safeguard your data by taking technical and organisational measures that are regularly updated to reflect the current state of the art. We cannot guarantee the uninterrupted availability of our website; faults, interruptions and failures cannot be ruled out. Regular and careful back-ups are carried out on our servers.

4       Legal Basis for the Processing of Personal Data

If we obtain the consent of data subjects to process their personal data, we shall do so on the basis of Article 6(1) (a) of the EU General Data Protection Regulation (GDPR).

If personal data is processed for the performance of a contract to which the data subject is party, the legal basis for this shall be Article 6(1) (b) GDPR. This shall also apply to any data processing required for the execution of pre-contractual measures.

If data processing is necessary for compliance with a legal obligation to which our company is subject, the legal basis for this shall be Article 6(1) (c) GDPR.

If data processing is necessary to protect the vital interests of the data subject or another natural person, the legal basis for this shall be Article 6(1) (d) GDPR.

If data processing is necessary to safeguard a legitimate interest of our company or a third party – and this interest is not outweighed by the interests and fundamental rights and freedoms of the data subject – data shall be processed on the basis of Article 6(1) (f) GDPR.

5       Erasure of Data and Storage Period

The personal data of the data subject shall be deleted or blocked as soon as it is no longer required for the purpose for which it was originally stored. Personal data may be stored beyond this period if this is stipulated by EU Law or national legislation through EU regulations, laws or other provisions that are legally binding for the data subject. The data shall then be deleted or blocked at the end of the storage period established by such regulations, unless the further storage of the data is necessary for the conclusion or performance of a contract.

6       Data Protection in Job Application Processes

We shall collect and process the personal data of job applicants during job application processes. Personal data may also be processed electronically. This shall especially be the case if applicants send us their application documents electronically, such as via email or through the online form on our website. If we conclude an employment contract with an applicant, the submitted data shall be stored in accordance with the statutory provisions in the interest of maintaining an employment relationship. If we do not conclude an employment contract with an applicant, the application documents shall be automatically deleted six months after the person has been informed of their rejection, unless such a deletion is prevented by our other legitimate interests. One such legitimate interest is the obligation to provide evidence in legal proceedings in accordance with the German General Equal Treatment Act (AGG).

7       Information on the Use of this Website

7.1      Cookies

Our website uses cookies. Cookies are text files that are saved on a data subject’s IT system via or by that person’s browser. If a data subject accesses our website, a cookie may be saved on the user’s operating system. This cookie will contain a string of characters that enable the unique identification of the browser when the website is revisited.

The legal basis for the processing of personal data using cookies is Article 6(1) (f) GDPR.

Cookies are used to simplify the use of websites for data subjects. Some features of our website cannot be offered without the use of cookies. These features can only function if the browser is recognised when changing from one page to another.

Cookies are saved on a data subject’s IT system and then transferred to our website. This gives data subjects full control over the use of cookies. Data subjects can disable or restrict the transfer of cookies by altering the settings in their browser. Saved cookies may be deleted at any time. This may also be done automatically. If cookies are disabled, it may not be possible to fully use all the features of our website.

The user data collected on this website is pseudonymised by technical means. This means the data cannot be associated with a particular user. The data is not stored alongside other personal user data.

When visiting our website, users are informed about the use of cookies for analytical purposes and are asked to consent to the processing of their personal data for such purposes. Reference is also made to this Privacy Statement.

If users consent to the processing of personal data using cookies for analytical purposes, this shall be done on the basis of Article 6(1) (a) GDPR.

Analytical cookies are used to improve the quality of our website and its contents. We use analytical cookies to find out how the website is used and constantly optimise our services.

Cookies are saved on a data subject’s IT system and then transferred to our website. This gives data subjects full control over the use of cookies. Data subjects can disable or restrict the transfer of cookies by altering the settings in their browser. Saved cookies may be deleted at any time. This may also be done automatically. If cookies are disabled, it may not be possible to fully use all the features of our website.

7.2      The Collection of General Data and Information

We collect information about data subjects when they use our website. We automatically collect information about their user behaviour and their interaction with us, and we record data concerning their IT system (computer or mobile device). We collect, store and use access data each time our website is visited (server logs). This access data includes the name and URL of the requested file, the date and time of the request, the volume of data transmitted, the notification of the successful request (HTTP response code), the browser type and version, the operating system, the referrer URL (the previously visited page), the IP address and the requesting provider.

This log data is not matched to a specific data subject or used for any other forms of profiling; we use it to carry out statistical evaluations in the interest of running, protecting and optimising our website, as well as to anonymously record the number of visitors to our website (traffic), to evaluate how and to what extent our website and services are used, and to measure the amount of clicks received by our cooperation partners and bill them accordingly. This information lets us provide personalised and relevant content for specific locations, analyse our traffic, carry out troubleshooting and improve our services. If there is concrete evidence to suggest the unlawful use of our website, we reserve the right to retrospectively inspect our log files. We store IP addresses in log files for a limited period whenever this is necessary to ensure security, provide our services or invoice for our services, e.g. when data subjects use one of our services. We shall also store IP addresses if we have a concrete reason to suspect a crime related to the use of our website.

7.3      Links / Redirection to Third-Party Websites

In accordance with Section 7 (1) of the German Telemedia Act, we are responsible, as a content provider, for our own content that we make available for use and can be held accountable in accordance with the general laws.

Our own content must be distinguished from cross-references (links) to third-party content made available by other providers.

When creating such links, we check whether any third-party content may infringe civil or criminal law.

While we regularly check for any changes to links to third-party content, we do not do this constantly. If we discover – or are notified by third parties – that one of our links infringes civil or criminal law, we shall remove the link.

8       Rights of Data Subjects

Data subjects may exercise the following rights by contacting us personally or by post at the address indicated above and by clearly proving their identity.

8.1      Right of Access

Data subjects may ask us to confirm whether we are processing their personal data. If we are processing such data, data subjects may ask us to provide the following information:

  1. The purposes of the processing;
  2. The categories of personal data concerned;
  3. The recipients or categories of recipient to whom the personal data has been or will be disclosed;
  4. The envisaged storage period for the personal data or, if exact information cannot be provided, the criteria used to determine the length of this period;
  5. The right to request the rectification or erasure of the personal data or the restriction of data processing, or the right to object to such processing;
  6. The right to lodge a complaint with a supervisory authority;
  7. Any available information regarding the source of the data if it was not collected directly from the data subject;
  8. The possible use of automated decision-making, including profiling, as described in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Data subjects have the right to obtain information as to whether their personal data is transferred to a third country or international organisation. If their personal data is transferred to a third country or international organisation, they have the right to be informed of the appropriate safeguards for the transfer pursuant to Article 46 GDPR.

8.2      Right to Rectification

If the personal data of data subjects is inaccurate or incomplete, they may ask us to rectify and/or complete this data. We must rectify the data without undue delay.

8.3      Right to Erasure

Data subjects may ask us to erase their personal data without undue delay, and we must then immediately erase their personal data, provided one of the following grounds applies:

  1. The personal data is no longer required for the purposes for which it was collected or otherwise processed;
  2. The data subject withdraws consent on which the processing is based according to Article 6(1) (a) or Article 9(2) (a) GDPR, and there are no other legal grounds for the processing;
  3. The data subject objects to processing in accordance with Article 21(1) GDPR, and there are no overriding legitimate reasons for this processing, or the data subject objects to processing in accordance with Article 21(2) GDPR;
  4. The personal data has been unlawfully processed;
  5. The personal data has to be erased to comply with a legal obligation in Union Law or the Member State legislation to which we are subject;
  6. The personal data has been collected in relation to the services provided by information societies described in Article 8(1) GDPR.

If we have made the personal data public and are obliged to erase it in accordance with Article 17(1) GDPR, we shall consider the available technology and implementation costs and take reasonable steps, including technical measures, to inform any controllers processing the personal data that the data subject has requested the erasure of all links to such personal data and the destruction of any copies and replications thereof.

8.4      Right to the Restriction of Processing

Data subjects may ask us to restrict the processing of their personal data under the following conditions:

  1. If they dispute the accuracy of their personal data for a period that allows us to verify its accuracy;
  2. The processing is unlawful and they oppose the erasure of the personal data and request the restriction of its use instead;
  3. We no longer need the personal data for the purposes of the processing, but they require the data to establish, exercise or defend legal claims; or
  4. They have objected to processing pursuant to Article 21(1) GDPR and it has not yet been decided whether our legitimate grounds override theirs.

If the processing of their personal data has been restricted, it shall only be processed (with the exception of storage) with their consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of an important public interest of the Union or a Member State.

If data processing has been restricted in accordance with the requirements described above, we shall inform data subjects before the restriction of processing is lifted.

8.5      Right to Data Portability

Data subjects may receive any personal data they have provided to us in a structured, commonly used and machine-readable format, and they may transmit this data to another controller without hindrance from us, provided:

  1. The processing is based on consent pursuant to Article 6(1) (a) or Article 9(2) (a) GDPR, or on a contract pursuant to Article 6(1) (b); and
  2. The processing is carried out by automated means.

In exercising their right to data portability pursuant to Paragraph 1, data subjects may have their personal data transmitted directly from us to another controller, provided this is technically feasible.

8.6      Right to Object to Data Processing

Data subjects may always object, on grounds relating to their particular situation, to the processing of their personal data which is based on Article 6(1) (e) or (f) GDPR, including any profiling based on those provisions. We shall then no longer process their personal data, unless we can demonstrate compelling legitimate grounds for processing which override their interests, rights and freedoms, or unless their personal data is processed for the establishment, exercise or defence of legal claims.

If we process personal data for direct marketing purposes, data subjects may always object to the processing of their personal data for such marketing, including profiling to the extent that it is related to such direct marketing.

8.7      Automated Decision-Making (incl. Profiling)

Data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or affects them in a similarly significant way. This shall not apply if the decision-making:

  1. Is necessary for the conclusion or performance of a contract between the data subject and us;
  2. Is authorised by Union Law or the Member State legislation to which we are subject and which also lays down suitable measures for the safeguarding of the rights, freedoms and legitimate interests of data subjects; or
  3. Is based on the data subject’s explicit consent.

8.8      Right to Revoke Consent to Data Processing

Data subjects may revoke their consent to the processing of their personal data at any time. The revocation of consent shall not affect the lawfulness of any processing carried out on the basis of their consent before its revocation.

8.9      Right to Lodge a Complaint with a Supervisory Authority

Data subjects may lodge a complaint with a supervisory authority – in particular in the Member State of their habitual residence, place of work or place of the alleged infringement – if they believe the processing of their personal data to be unlawful.

9       Use of Automated Decision-Making

The personal data we collect shall not be used to carry out automated decision-making.

10   Other Functions and Tools on this Website

10.1   Web Marketing

10.1.1 Google AdWords

We use Google AdWords as a web marketing tool on our website.

This allows advertisers to place advertisements in Google search engine results and in the Google Network.

Specific keywords are determined by the advertiser in advance. If a user searches for one of the keywords in the Google search engine, the advertiser’s advertisement will be displayed as part of the search results.

Advertisements are distributed on relevant websites in the Google Network using an automated algorithm and in accordance with the defined keywords.

Google AdWords is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

We use Google AdWords to advertise our website by displaying relevant advertising on third-party websites and in Google search engine results; we also use it to display third-party advertising on our own website.

Whenever data subjects access our website through a Google ad, a conversion cookie is placed on their IT system. This cookie loses its validity after 30 days and is not used to identify data subjects. If the cookie has not expired, it lets us see whether certain sub-pages have been accessed on our website (e.g. the shopping basket on our online store). The cookie also allows both us and Google to determine whether revenue has been generated by a data subject who accesses our website through an AdWords ad, i.e. whether the data subject has completed or cancelled a purchase.

The information and data collected through the use of the cookie are also used by Google to generate statistics on our website visitors. We then use these statistics to determine the total amount of users who have been redirected to us through AdWords ads. This allows us to measure the success of each AdWords ad and improve our AdWords campaign as a whole. Neither we nor any other Google AdWords advertiser shall receive any information from Google that might be used to identify data subjects.

The cookie described above is used to store personal data, such as the websites visited by each data subject. Each time our web pages are visited, personal data (including the IP address of the data subject’s Internet connection) is transferred to Google in the USA. This personal data is then stored by Google in the USA, and Google may transfer the personal data collected through this process to third parties.

Data subjects may prevent our website from placing a cookie at any time by configuring their web browser accordingly and/or permanently disabling the placement of cookies. If data subjects configure their web browser in such a way, Google will not be able to place a conversion cookie on their IT system. Data subjects can use their web browser or another piece of software to delete any cookies placed by Google AdWords on their IT system at any time.

Data subjects may also object to the use of relevant ads by Google. Data subjects can do this by opening the link www.google.de/settings/ads from every web browser they use and setting their desired configuration.

More information and Google’s privacy policy can be found at https://policies.google.com/privacy?hl=de&gl=de.

10.1.2 Google Remarketing

We use Google remarketing on our website. Google remarketing is a function of Google AdWords that lets us show advertising to Internet users who have previously visited our website. The integration of this service lets us tailor our advertising to users by showing them relevant advertisements.

Google remarketing is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

We use Google remarketing to display relevant advertisements. This tool lets us tailor our advertising to the interests of each user and display this through the Google Network or on other websites.

Google remarketing places a cookie on the data subject’s IT system. The placement of cookies allows Google to identify visitors to our website when they access other websites in the Google Network.

Every time data subjects visit a website that uses Google remarketing, their web browser is automatically identified by Google. Google receives personal data as part of this process, such as the user’s IP address and browsing behaviour (i.e. the websites visited by the data subject). This personal data is used by Google to display relevant advertising and to perform other functions.

Each time our web pages are visited, personal data (including the IP address of the data subject’s Internet connection) is transferred to Google in the USA. This personal data is then stored by Google in the USA, and Google may transfer the personal data collected through this process to third parties.

Data subjects may prevent our website from placing a cookie at any time by configuring their web browser accordingly and/or permanently disabling the placement of cookies. If data subjects configure their web browser in such a way, Google will not be able to place a cookie on their IT system. Data subjects can use their web browser or another piece of software to delete any cookies placed by Google on their IT system at any time.

Furthermore, data subjects may object to the use of relevant ads by Google. Data subjects can do this by opening the link www.google.de/settings/ads from every web browser they use and setting their desired configuration.

More information and Google’s privacy policy can be found at https://policies.google.com/privacy?hl=de&gl=de.

10.2   Analytical Tools

10.2.1 Google Analytics (with Anonymisation Function)

We use Google Analytics (with anonymisation function) as a web analytics service on our website. Web analytics is the collection, reporting and analysis of data concerning user behaviour on websites. This service is used to record the website from which a data subject has accessed our website (referrer URL), the sub-pages accessed on our website, and how often and for how long a particular sub-page has been displayed. Web analytics is mainly used to improve our website and perform cost-benefit analysis for our web-based advertising.

Google Analytics components are operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

We use the “_gat._anonymizeIp” extension when performing web analytics with Google Analytics.

Whenever our website is accessed from a Member State of the European Union or the European Economic Area, Google uses this extension to truncate and anonymise the IP address of the data subject’s Internet connection.

We use Google Analytics to analyse user behaviour on our website. Google uses the data collected to analyse the use of our website, which allows it to compile reports for us on the activities on our web pages and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s IT system. The placement of cookies allows Google to analyse the use of our website.

Every time a part of our website with an integrated Google Analytics tool is accessed, the data subject’s web browser automatically sends data to Google for web analytics. Google receives personal data during this process, such as the user’s IP address. Google uses this information to track clicks and the origin of visitors, and to subsequently enable the settlement of commission.

The cookie is used to store personal data, such as the access time, the location from where the page was accessed, and the amount of times a data subject has accessed our website. Each time our web pages are visited, personal data (including the IP address of the data subject’s Internet connection) is transferred to Google in the USA. This personal data is then stored by Google in the USA, and Google may transfer the personal data collected through this process to third parties.

Data subjects may prevent our website from placing a cookie at any time by configuring their web browser accordingly and/or permanently disabling the placement of cookies. If data subjects configure their web browser in such a way, Google will not be able to place a cookie on their IT system. Data subjects can use their web browser or another piece of software to delete any cookies placed by Google Analytics on their IT system at any time.

Data subjects may also object to and prevent the collection of data generated by Google Analytics on the use of our website and the processing of this data by Google.

Data subjects can do this by downloading and installing an add-on for their web browser from the following site: https://tools.google.com/dlpage/gaoptout. This add-on informs Google Analytics that it must not transmit any information on visits to websites that use Google Analytics. The installation of this add-on is seen by Google as an objection. If the data subject’s IT system is reinstalled, the data subject will need to reinstall the add-on to disable Google Analytics. If the browser add-on is ever uninstalled or disabled, it can be reinstalled or reactivated.

More information and Google’s privacy policy can be found at https://policies.google.com/privacy?hl=de&gl=de and http://www.google.com/analytics/terms/de.html.

10.3   Social Media

10.3.1 YouTube

We use YouTube videos on our website. YouTube is a platform used to post and view videos for free. It is also possible to leave comments and rate videos.

YouTube is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Every time data subjects visit a page on our website with an integrated YouTube plug-in, their web browser will automatically download a visualisation of the corresponding YouTube video from YouTube. For more information, see https://www.youtube.com/yt/about/de/. This process allows YouTube to discover which sub-page on our website has been visited by a data subject.

If a data subject is logged in to YouTube while using our website, YouTube will identify which specific sub-pages have been visited during the entire visit to our website. This data is collected by the YouTube plug-in and matched to the user’s own YouTube account.

If a data subject clicks on a YouTube button on our website, YouTube will save this personal data and match it to the data subject’s personal YouTube user account.

If a data subject is logged in to YouTube when accessing our website, YouTube will be informed that the data subject has visited our website containing a YouTube video. This will even happen if the data subject does not click on the YouTube video. Data subjects may prevent this information from being submitted to YouTube by signing out of their YouTube account before visiting our website.

Google has published a privacy policy at https://www.youtube.de/t/privacy, which provides information on the collection, processing and use of personal data by Google and YouTube.

10.4   WordPress Plug-Ins

10.4.1 AddThis

We use AddThis components on our website. AddThis is a tool that facilitates the management of bookmarks. When users click on the AddThis plug-in or hover over it with their mouse, a list of bookmarks and sharing services is displayed.

AddThis is operated by AddThis, Inc. 1595 Spring Hill Road, Suite 300, Vienna, VA 22182, USA.

Every time data subjects visit a page on our website with an integrated AddThis plug-in, their web browser will automatically download data from the AddThis website. AddThis receives information as part of this process, such as the sub-pages visited by the data subject on our website, the IP address allocated by the data subject’s Internet provider, the type and language of the web browser, and the date and time of the visit. AddThis uses this information to create anonymous user profiles. A cookie stores the web pages visited by data subjects to analyse the browsing behaviour of their IT system. AddThis and its partners use this information to provide visitors to our website with personalised advertising.

Data subjects may prevent our website from placing a cookie at any time by configuring their web browser accordingly and/or permanently disabling the placement of cookies. If data subjects configure their web browser in such a way, AddThis will not be able to place a cookie on their IT system.

Data subjects can use their web browser or another piece of software to delete any cookies placed by AddThis on their IT system at any time.

Data subjects may also object to the use of relevant ads by AddThis. Data subjects can do this by opening the link http://www.addthis.com/privacy/opt-out from every web browser they use. If data subjects visit this site, an opt-out cookie will be placed on their IT system to disable the AddThis tool. Please note that this cookie will also be deleted when using the “Delete Cookies” web browser function; in such cases, the use of AddThis must be disabled again via the page indicated above.

Please note that it may not be possible to use all features of our website following the placement of an opt-out cookie.

More information and the AddThis privacy policy can be found at http://www.addthis.com/privacy/privacy-policy.