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 is any information that can be used to personally identify you.
    1.2 The controller responsible for data processing on this website in accordance with the General Data Protection Regulation (GDPR) is Shop Name. The controller is the natural or legal person who alone or jointly determines the purposes and means of processing personal data.
    1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the "https://" string and the lock symbol in your browser's address bar.

  2. Data collection when visiting our website
    When you visit our website for informational purposes, i.e., when you do not register or transmit other 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:

  • Our visited website
  • Date and time of access
  • Amount of data sent in bytes
  • Source/reference from which you accessed the page
  • Browser used
  • Operating system used
  • IP address used (possibly anonymized)
    The processing is carried out in accordance with Article 6(1)(f) GDPR based on our legitimate interest in improving the stability and functionality of our website. Data is not disclosed or otherwise used. However, we reserve the right to review the server log files retrospectively if there are specific indications of unlawful use.
  1. Cookies
    To make our website attractive and enable the use of certain features, 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, i.e., after closing 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 on your next visit (persistent cookies). When cookies are set, they collect and process certain user information such as browser and location data as well as IP address values. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie.
    Some cookies serve to simplify the order process by saving settings (e.g., remembering the contents of a virtual shopping cart for a later visit to the website). If personal data is processed by individual cookies we have implemented, the processing takes place in accordance with Article 6(1)(b) GDPR either for the performance of the contract or in accordance with Article 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 website visit.
    In some cases, we work with advertising partners who help us make our internet offering more interesting for you. For this purpose, cookies from partner companies may be stored on your hard drive when you visit our website (third-party cookies). If we collaborate with the aforementioned advertising partners, you will be informed about the use of such cookies and the scope of the information collected in the following sections.
    Please note that you can set your browser to be informed about the setting of cookies and to decide individually whether to accept them, or to exclude the acceptance of cookies for certain cases or in general. 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 under the following links:
  • Internet Explorer: Support
  • Firefox: Support
  • Chrome: Support
  • Safari: Support
  • Opera: Support
    Please note that if you do not accept cookies, the functionality of our website may be restricted.
  1. Contacting us
    In the context of contacting us (e.g., via contact form or email), personal data is collected. The data collected in the case of a contact form is evident from the respective contact form. These data are stored and used exclusively for the purpose of responding to your inquiry or for contacting you and the associated technical administration. The legal basis for data processing is our legitimate interest in responding to your inquiry in accordance with Article 6(1)(f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Article 6(1)(b) GDPR. Your data will be deleted after the final processing of your request, provided that the circumstances indicate that the matter has been conclusively clarified and there are no legal retention requirements.

  2. Data processing when opening a customer account and for contract execution
    In accordance with Article 6(1)(b) GDPR, personal data is also collected and processed if you provide us with this data to execute a contract or when opening a customer account. The data collected is evident from the respective input forms. Deletion of your customer account is possible at any time and can be done by sending a message to the above address of the controller. We store and use the data you provide to execute the contract. After the contract is fully executed or after the deletion of your customer account, your data is locked with regard to tax and commercial law retention periods and deleted after these periods expire, unless you have explicitly consented to further use of your data or we have reserved a legally permitted further use of your data, about which we inform you below.

  3. Use of your data for direct marketing
    6.1 Subscription to our email newsletter
    If you subscribe to our email newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your email address. The provision of further data is voluntary and is used to address you personally. For the dispatch of the newsletter, we use the so-called double opt-in procedure. This means that we will only send you an email newsletter after you have expressly confirmed that you consent to receiving the newsletter. We will send you a confirmation email, asking you to confirm by clicking a link that you wish to receive newsletters in the future.
    By activating the confirmation link, you give us your consent for the use of your personal data in accordance with Article 6(1)(a) GDPR. When registering for the newsletter, we store the IP address registered by the Internet Service Provider (ISP) as well as the date and time of registration to track any misuse of your email address at a later time. The data we collect when registering for the newsletter will be used exclusively for the purpose of advertising through the newsletter. You can unsubscribe from the newsletter at any time using the link provided in the newsletter or by sending a corresponding message to the responsible party mentioned above. After unsubscribing, your email address will be immediately deleted from our newsletter distribution list, unless you have explicitly consented to further use of your data or we have reserved a further data use that is legally permissible, about which we will inform you in this statement.
    6.2 Sending the email newsletter to existing customers
    If you have 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. In this case, we do not need to obtain separate consent from you. The data processing is carried out solely based on our legitimate interest in direct marketing. Legitimate interest in personalized direct advertising pursuant to Art. 6(1)(f) GDPR. If you initially objected to the use of your email address for this purpose, no emails will be sent by us. 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. You will only incur transmission costs in accordance with the basic rates. Upon receipt of your objection, the use of your email address for advertising purposes will be discontinued immediately.

     

    7) DATA PROCESSING FOR ORDER PROCESSING 7.1 The personal data we collect will be forwarded to the transport company entrusted with the delivery as part of the order processing, as far as this is necessary for the delivery of the goods. Your payment data will be forwarded to the bank instructed for payment processing, if this is required for payment handling. If payment service providers are used, we will explicitly inform you below. The legal basis for the transfer of data is Art. 6 para. 1 lit. b GDPR.

    7.2 Use of Payment Service Providers (Payment Service Providers)

    • PayPal If payment is made via PayPal, credit card via PayPal, direct debit via PayPal, or if offered - "Buy on invoice" or "Installment payment" via PayPal, we will forward your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg ("PayPal") for payment processing. The transfer takes place according to Art. 6 para. 1 lit. 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 - "Buy on invoice" or "Installment payment" via PayPal. For this, your payment data may be forwarded to credit agencies according to Art. 6 para. 1 lit. f GDPR based on PayPal's legitimate interest in assessing your creditworthiness. The result of the credit check, concerning the statistical probability of payment default, is used by PayPal to decide whether to offer the respective payment method. The credit check may include probability values (so-called score values). If score values are included in the credit check result, they are based on a scientifically recognized mathematical-statistical procedure. The calculation of score values takes into account, among other things, but not exclusively, address data. For further data protection information, including the credit agencies used, please refer to PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full. You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still process your personal data if necessary for the contractual payment processing.

    • SOFORT If you select the payment method "SOFORT," the payment processing is carried out via the payment service provider SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany ("SOFORT"), to whom we will forward the information you provided during the ordering process, along with information about your order according to Art. 6 para. 1 lit. b GDPR. SOFORT GmbH is part of the Klarna Group (Klarna Bank AB (publ), Sveavägen 46, 11134 Stockholm, Sweden). The transfer of your data takes place exclusively for the purpose of payment processing with the payment service provider SOFORT and only to the extent necessary for this purpose. Further information about SOFORT’s data protection policies can be found here: https://www.klarna.com/sofort/datenschutz.

    8) CONTACT REGARDING REVIEW REMINDER Own review reminder (not sent through 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 gave us your explicit consent during or after your order according to Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time by notifying the responsible party for data processing.

    9) USE OF SOCIAL MEDIA: SOCIAL PLUGINS 9.1 Facebook Plugins with Shariff Solution 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") of the social network Facebook, which is 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 fully integrated as plugins but only embedded using an HTML link on the page. This ensures that no connection is established to Facebook's servers when a page containing these buttons is accessed. If you click the button, a new browser window will open, and the Facebook page will be loaded, where you can interact with the plugins (possibly after logging in). Facebook Inc. based in the USA is certified under the US-EU Privacy Shield framework, ensuring compliance with the data protection standards in the EU. For more information on the purpose and scope of data collection, further processing, and usage of your data by Facebook, as well as your rights and privacy protection options, please refer to Facebook's privacy policy: https://www.facebook.com/policy.php

    9.2 Google+ Plugins as Shariff Solution On our website, social plugins ("plugins") of the social network Google+ are used, operated by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). To enhance data protection when visiting our website, these buttons are not fully integrated as plugins, but are embedded using an HTML link on the page. This ensures that no connection is made to Google+ servers when a page containing these buttons is accessed. If you click the button, a new browser window opens and the Google+ page is loaded, where you can interact with the plugins (possibly after logging in). Google LLC, based in the USA, is certified under the US-EU Privacy Shield framework, ensuring compliance with EU data protection laws. For information on the purpose and scope of data collection and further processing and use of the data by Google, as well as your rights and privacy options, please refer to Google's privacy policy: https://www.google.com/intl/de/policies/privacy/

    9.3 Instagram Plugin as Shariff Solution On our website, social plugins ("plugins") of the online service Instagram are used, 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 fully integrated as plugins but embedded using an HTML link on the page. This ensures that no connection is established to Instagram's servers when a page containing these buttons is accessed. If you click the button, a new browser window will open, and the Instagram page will be loaded, where you can interact with the plugins (possibly after logging in). Instagram LLC., based in the USA, is certified under the US-EU Privacy Shield framework, ensuring compliance with EU data protection standards. For information on the purpose and scope of data collection and further processing and use of the data by Instagram, as well as your rights and privacy options, please refer to Instagram’s privacy policy: https://help.instagram.com/155833707900388/

    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 ads relevant to users, improve campaign performance reports, or prevent a user from seeing the same ads multiple times. Using a cookie ID, Google tracks which ads are displayed in which browser and can prevent them from being shown repeatedly. Processing is carried out based on our legitimate interest in the optimal marketing of our website in accordance with Art. 6(1)(f) GDPR.

    Additionally, DoubleClick can use cookie IDs to track so-called conversions related to ad requests. This occurs, for example, when a user views a DoubleClick ad and later visits the advertiser's website with the same browser and makes a purchase. According to Google, DoubleClick cookies do not contain any personal data.

    Due to the marketing tools used, your browser automatically establishes a direct connection to Google's server. We have no control over the extent and further use of the data collected by Google through this tool and inform you according to our current knowledge: By integrating DoubleClick, Google receives information that you have accessed the corresponding part of our website or clicked on an ad from us. If you are registered with a Google service, Google can associate your visit with your account. Even if you are not registered or logged into Google, there is a possibility that the provider may obtain and store your IP address.

    If you wish to opt out of this tracking process, you can deactivate cookies for conversion tracking by adjusting your browser settings 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 obtain information about cookie settings and make adjustments via the Digital Advertising Alliance at www.aboutads.info. Finally, you can configure your browser to notify you about cookie settings and allow them on a case-by-case basis or exclude them altogether. If cookies are not accepted, the functionality of our website may be restricted.

    Google LLC, based in the USA, is certified under the US-European Privacy Shield Agreement, ensuring compliance with EU data protection standards.
    Further information on 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 feature of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

    We use Google AdWords to draw attention to our attractive offers on external websites using advertisements (Google AdWords). We can analyze the success of individual advertising measures by evaluating campaign data. Our goal is to show you advertisements that are relevant to you, make our website more engaging, and achieve a fair calculation of advertising costs.

    A conversion tracking cookie is set when a user clicks on an ad placed by Google AdWords. These cookies are small text files stored on your computer system. They usually expire after 30 days and do not serve personal identification purposes. If a user visits certain pages of this website while the cookie has not yet expired, Google and we can detect that the user clicked on the ad and was redirected to the page. Each Google AdWords customer receives a unique cookie, preventing tracking across multiple AdWords customers' websites.

    The information collected using conversion cookies is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers receive information about the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that personally identifies users.

    If you do not wish to participate in tracking, you can disable this feature by deactivating the Google Conversion Tracking cookie in your browser settings under user preferences. In doing so, you will not be included in 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 Privacy Shield Agreement, ensuring compliance with EU data protection standards.

    Further information on Google's privacy policy can be found at: https://www.google.de/policies/privacy/

    You can permanently disable cookies for advertising preferences by adjusting your browser settings 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 if you disable cookies, certain features of this website may not be fully functional or may only be available to a limited extent.


    11) WEB ANALYTICS SERVICES

    Google (Universal) Analytics

    This website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses so-called "cookies," text files stored on your computer that enable an analysis of your website usage. The information generated by the cookie about your use of this website (including the truncated IP address) is usually transmitted to a Google server in the USA and stored there.

    This website uses Google Analytics exclusively with the "_anonymizeIp()" extension, ensuring that IP addresses are anonymized before processing, making direct personal identification impossible. With this extension, Google truncates your IP address within member states of the European Union or other contracting states of the European Economic Area Agreement before transmission. Only in exceptional cases will the full IP address be sent to a Google server in the USA and truncated there. In these exceptional cases, processing is carried out based on our legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes under Art. 6(1)(f) GDPR.

    On our behalf, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide us with further services related to website usage and internet usage. The IP address transmitted by your browser within the scope of Google Analytics is not merged with other Google data.

    You can prevent cookies from being stored by adjusting your browser settings accordingly. However, please note that doing so may limit the functionality of this website.

    Additionally, you can prevent Google from collecting and processing data generated by the cookie (including your IP address) by downloading and installing the browser plug-in available at:
    https://tools.google.com/dlpage/gaoptout?hl=en

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

    Google LLC, based in the USA, is certified under the US-European Privacy Shield Agreement, ensuring compliance with EU data protection standards.

    This website also uses Google Analytics for cross-device visitor analysis via a User ID. When you visit a page for the first time, you are assigned a unique, persistent, and anonymized User ID, which is used across multiple devices. This allows interaction data from different devices and sessions to be linked to a single user. The User ID does not contain personal data and does not transmit such data to Google.

    You can opt out of data collection and storage via the User ID at any time with future effect by deactivating Google Analytics on all systems you use, such as different browsers or mobile devices.

    You can deactivate this tracking using the Google browser plugin (https://tools.google.com/dlpage/gaoptout?hl=en). Alternatively, use the opt-out link provided above.

    More information about Universal Analytics can be found here:
    https://support.google.com/analytics/answer/2838718?hl=en&ref_topic=6010376

    12) RETARGETING / REMARKETING / RECOMMENDATION ADVERTISING

    Facebook Custom Audience via the Pixel Method
    This website uses the “Facebook Pixel” from Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). If explicit consent is given, this allows the behavior of users to be tracked after they have seen or clicked on a Facebook advertisement. This process is used to evaluate the effectiveness of Facebook ads for statistical and market research purposes and can help optimize future advertising efforts.

    The collected data is anonymous to us and does not provide us with any conclusions about the identity of users. However, Facebook stores and processes the data, enabling a connection to the respective user profile. Facebook may use this data for its own advertising purposes, in accordance with Facebook’s Data Usage Policy (https://www.facebook.com/about/privacy/). This allows Facebook and its partners to display advertisements on and outside of Facebook. Additionally, a cookie may be stored on your computer for these purposes. These processing operations only take place with explicit consent under Article 6(1)(a) GDPR.

    Consent for the use of the Facebook Pixel may only be given by users over the age of 13. If you are younger, please ask your legal guardian for permission.

    Facebook Inc., based in the USA, is certified under the EU-U.S. Privacy Shield framework, ensuring compliance with EU data protection standards.

    To disable the use of cookies on your computer, you can configure your internet browser to prevent future cookies from being stored or delete existing cookies. However, disabling all cookies may result in some functions of our website not working properly. You can also deactivate the use of cookies by third-party providers such as Facebook via the Digital Advertising Alliance website: https://www.aboutads.info/choices/

    Google AdWords Remarketing
    Our website uses Google AdWords Remarketing features to advertise 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 places a cookie in the browser of your device, which automatically enables interest-based advertising using a pseudonymous cookie ID based on the pages you have visited. Processing is carried out based on our legitimate interest in the optimal marketing of our website according to Article 6(1)(f) GDPR.

    Additional data processing will only take place if you have consented to Google linking your web and app browsing history to your Google account and using this information to personalize ads you see online. In this case, if you are logged into Google while visiting our website, Google uses your data in combination with Google Analytics data to create and define audience lists for cross-device remarketing. Your personal data is temporarily linked with Google Analytics data by Google to form target groups.

    You can permanently disable cookies for ad preferences by downloading and installing the browser plugin available at the following link: https://www.google.com/settings/ads/onweb/

    Alternatively, you can find out more about the setting of cookies and adjust your preferences on the Digital Advertising Alliance website: www.aboutads.info. Finally, you can configure your browser to notify you when cookies are set and to decide individually whether to accept them or to exclude cookies in certain cases or in general. If cookies are not accepted, the functionality of our website may be limited.

    Google LLC, based in the USA, is certified under the EU-U.S. Privacy Shield framework, ensuring compliance with EU data protection standards.

    Further information and Google’s privacy policy regarding advertising can be found here: https://www.google.com/policies/technologies/ads/


    13) RIGHTS OF THE DATA SUBJECT

    13.1 Data Subject Rights

    Under applicable data protection law, you have the following rights regarding the processing of your personal data, which we inform you about below:

    • Right of Access (Article 15 GDPR): You have the right to obtain information about the personal data we process, including the purposes of processing, the categories of processed personal data, recipients or categories of recipients to whom your data has been disclosed or will be disclosed, the planned storage period, the right to rectification, erasure, restriction of processing, objection, the right to lodge a complaint with a supervisory authority, the origin of your data if it was not collected by us, the existence of automated decision-making, including profiling, and, where applicable, meaningful information about the logic involved, as well as the significance and the intended effects of such processing, and the guarantees in place for transfers of your data to third countries under Article 46 GDPR.

    • Right to Rectification (Article 16 GDPR): You have the right to request the immediate correction of incorrect personal data concerning you and/or to have incomplete personal data stored by us completed.

    • Right to Erasure (Article 17 GDPR): You have the right to request the deletion of your personal data under the conditions of Article 17(1) GDPR. However, this right does not apply if processing is necessary for exercising the right to freedom of expression and information, for fulfilling a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims.

    • Right to Restriction of Processing (Article 18 GDPR): You have the right to request the restriction of processing of your personal data if you contest the accuracy of your data, if processing is unlawful but you oppose deletion and instead request the restriction of its use, if we no longer need the data for processing but you require it for legal claims, or if you have objected to processing pending verification of whether our legitimate grounds override yours.

    • Right to Notification (Article 19 GDPR): If you have asserted your right to rectification, erasure, or restriction of processing, we are obliged to notify all recipients to whom your personal data has been disclosed of this rectification, erasure, or restriction, unless this proves impossible or involves disproportionate effort. You have the right to be informed about these recipients.

    • Right to Data Portability (Article 20 GDPR): You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, or to request that it be transferred to another controller where technically feasible.

    • Right to Withdraw Consent (Article 7(3) GDPR): You have the right to withdraw consent to data processing at any time with effect for the future. In the event of withdrawal, we will immediately delete the relevant data unless further processing is justified by a legal basis that does not require consent. The legality of processing carried out based on consent before its withdrawal remains unaffected.

    • Right to Lodge a Complaint (Article 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 in your country of residence, workplace, or the location of the alleged infringement.


    13.2 RIGHT TO OBJECT

    IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION.

    IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING YOUR AFFECTED DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR IF 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 SUCH PROCESSING. IF YOU EXERCISE THIS RIGHT, WE WILL STOP PROCESSING YOUR DATA FOR DIRECT MARKETING PURPOSES.


    14) DURATION OF STORAGE OF PERSONAL DATA

    The duration of storage of personal data is determined based on statutory retention periods (e.g., commercial and tax-related retention periods). After the expiration of these periods, the relevant data is routinely deleted, provided it is no longer required for contract fulfillment, contract initiation, or if there is no legitimate interest in further retention.