The Organization for the collection, use and disclosing of your personal information (hereinafter “Data Controller” or "Controller") is Tod's S.p.A. - company number 01113570442 – (hereinafter also "Company", "we", “us” or "our"), with registered office in Via Filippo Della Valle n.1, Sant'Elpidio a Mare (FM) - Italy (EU), contactable at the following e-mail address: dataprivacyofficer@todsgroup.com.

When consulting the pages of our website, some of your personal information will be collected or, in connection with some services, you will be requested to provide additional personal data.
We will follow the principles of lawfulness, legality, and necessity to collect and use your personal information for the following purposes described in this privacy policy. We will not collect personal information unrelated to the services provided, nor will we refuse you to use the basic functions of the products and/or services because you do not agree to the collection of unnecessary personal data. If we use your personal information for other purposes not specified in this privacy policy or collect and use your personal information for other specific purposes, we will reasonably notify you and obtain your consent again before collection and use.

2.1. Automatically acquired data
(i) Browsing Data - The computer systems and software procedures used to operate the Website acquire, in the course of their normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
(ii) Cookies - to find out more, we invite you to read the section "Cookie Policy - Cookie Setting" available at the bottom of every page on our website.
This is information that is not collected in order to be associated with you, but which by its very nature could, through processing and association with information in possession of third parties, allow you to be identified. This category of data includes the IP addresses or domain names of the computers used for navigation and which connect to the Sites, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the IT environment. These data are not circulated, but are used only to obtain anonymous statistical data on the use of the Site and to check its correct operation, and are kept for the time periods defined by the relevant legal regulations. The data could, however, be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site. Except in the latter case, such data are not retained for more than fifteen days. For further information and to manage your preferences, we invite you to view the section "Cookie Policy - Cookie Settings", which can be reached via the link available at the bottom of each page of our website. You can choose whether to authorize us to use the relevant permissions of your device. If you do not authorize us to use relevant permissions, some products/services we provide may be unavailable, but this will not affect your use of basic functional services.
(iii) Geo-localisation data - The Site's internal search system collects data, exclusively when used and subject to your confirmation, relating to your geographical location, in order to obtain the appropriate search results (e.g., when searching for the boutique nearest to you via the dedicated functionality).

Learn more about the geo-localization process
In order to recommend nearby shops to you, based on your separate consent, we will request your location permission and collect your location data. If you do not provide this information, it will not affect your normal browsing and use of our products/services. If you do not enable location permission, the information of the store closest to you will not be displayed automatically, but you can still manually enter and view the information of the corresponding store.

2.2. Information voluntarily provided by you
In order to enable you to take advantage of the various features offered by our website, you may be requested to provide other personal data, such as:
(i) personal data: first name, surname, date of birth, gender, nationality;
(ii) contact details: e-mail address, telephone number, address of residence or domicile; shipping address;
(iii) information relating to purchase made: date, quantity and type, product code, sale amount, VAT number where applicable, shipping/billing address, data relating to the payment method you wish to use, data on complaints, returns, guarantee, refunds, and other information relating to the sale of products;
(iv) information relating to your interests: services, events, or initiatives of the Tod's Group which you have joined, or expressions of appreciation for products or initiatives of the various Tod's Group brands;
(v) username and password when purchasing our products online, subscribing to one of the services provided through the website or activating a Personal Account on our website;
(vi) information about your level of satisfaction if you decide to rate our products or services.
Please note that your payment data, such as your credit card number, will NOT be processed by us.

2.3. Personal information collected through social media pages We may also collect some of your personal information when you interact with our social pages. Some information is submitted directly by you, when you decide to share - through your profile - images published on our social pages, comment on our posts and/or express your approval of one of our products, one of our initiatives or one of our events by selecting the appropriate features, as well as when you decide to write us a message using the private chat or other channels made available on the various social media.
We may also become aware of some information that is indirectly collected as a result of your interaction with our social pages; for example, we may know the time and day when you express your liking to one of our posts or send a request through a mail message.
The knowledge of much of your personal information depends on your chosen social media settings and the content you choose to make public. This information could include your first name, last name, some contact details, and the image associated with your social profile and related information collected through social log-in. We therefore remind you that some of your information may be visible to us should you decide to follow our social pages. For this reason, we invite you to read the privacy policy of the different social media and to check the privacy settings.

2.4. Personal information relating to minors
We would like to point out that the protection of the safety and privacy of minors is very important to the Tod's Group. Therefore, we do not intend to collect and do not intend to voluntarily use any personal information of persons under sixteen (16) years of age, or under any other age limit imposed by the laws in force in your country of residence. We therefore request you to refrain from providing us with any of your personal information if you are under the age of sixteen (16) years or under the age of majority in your country of residence.
In the case of collecting personal information from minors, we will only use the information when the law permits, if the guardian expressly consents, or it is necessary to protect the minor.
If you believe that we have unintentionally collected personal information from a child without the consent of the guardian, please inform us immediately and we will try to delete the relevant information as soon as possible.

Whenever we acquire and process your personal data, this will be done exclusively in accordance with the principles of legitimacy envisaged in the legislation. We may use personal information for the following business purposes.

3.1. With your explicit CONSENT, we will process your personal information to:
(i) conduct marketing activities, both through automated tools (SMS, MMS, messaging platforms, e-mail, push notifications) and through traditional channels (paper mail, telephone call with operator). The marketing activities may take the form of sending newsletters, promotions, discounts, facilitations, commercial data, and other dedicated services, by paper mail, call with operator, direct sale, through e-mail, pre-recorded calls, 'social' or messaging platforms and SMS/MMS. In this context, we may also process your personal information in order to invite you to participate in shows and events, to involve you in market research or to notify you of special initiatives dedicated to TOD'S Group customers, in the manner and at the times that we deem most effective based on the various initiatives mentioned. We will not transfer and/or sell your personal information to third parties for use in direct marketing;
(ii) analysing some of your personal tastes to identify your preferences, interests, and consumption choices, in order to provide you with services that better meet your expectations and needs. The profiling activities may take the form of the analysis of information regarding your interests and preferences with regard to our products and services and your consumption choices: for example, by surveying the type and frequency of the purchases you make on our e-commerce sites, through your Personal Account and in "guest" mode, and at our boutiques, in order to be able to guarantee you a personalised service during your future visits to TOD'S Group boutiques. If you have also given your consent to the processing of your personal information for marketing purposes, it will allow us to send you promotions and/or invitations to initiatives that are more in line with your profile, preferences, and expectations. The provision of your personal information is entirely voluntary, but failure to provide some of them may result in your partial or total inability to be involved in our marketing initiatives.
Please note that, should you decide not to consent to the processing of your personal information for marketing purposes, this would prevent us from being able to involve you in our promotional initiatives, including our periodic newsletter updates.
Should you decide not to consent to the processing of your personal information for profiling purposes, this would have no impact on your participation in our promotional communications plan, but would simply result in our inability to send you personalised promotional communications.

Learn more about how our consent request works
When giving your consent, you will be requested to tick the checkbox for each purpose for which you wish to authorise us to process your personal data:
(i) if you tick the consent check box, we will process your personal information for the chosen purpose;
(ii) in the event that you do not tick the consent check box, we will maintain the previous situation, i.e.,
if you have previously given us your consent, it shall remain valid until revoked or until the defined 'expiry date';
if you have not previously given us your consent, we will continue NOT to use your personal information for the purpose in question.
We would like to remind you that you may revoke previously issued consents at any time by following the instructions given in the remainder of the privacy policy.

3.2. We will process your personal information to FULFIL CONTRACTUAL OBLIGATIONS OR PRE-CONTRACTUAL MEASURES, in order to:
(i) enable you to purchase products on our website, as well as to fulfil our contract obligations to you. Failure to provide your personal information will result in the impossibility of completing the purchase process, as such information is necessary for us to fulfil our contract obligations;

Learn more about our purchasing process
When placing an order for our products, you can choose to pay quickly as a guest or choose to register a member account and establish yourself as a member to enjoy more membership benefits (see section 3.2 (ii.) “Create a Personal Account” for more details). When you choose to pay as a guest, you must provide us with your email address to complete the purchase process and receive transactional communications relating to the purchase order made.
When you order our products by choosing to collect in store, you must provide us with the recipient's name, mobile number and choose the store where you wish to collect the goods. When ordering our express delivery products, you must provide us with your title ("Mr." or "Ms."), recipient's name, mobile phone number, location, detailed delivery address, code postal address, e-mail address for receiving electronic invoices (optional) and invoice header data (optional) to complete the transaction smoothly and ensure the security of the transaction. If you do not provide the above data, the transaction may not be completed. At checkout, we will generate an order for the products you have purchased, which will include your order number, data about the product you purchased, the time of your order, payment status, the amount you should pay, and logistics information to help you complete the purchase process. By providing your personal information you consent that we use them to manage your purchase operation.
(ii) allow you to create a Personal Account on our Website and use the related dedicated services. The list of services dedicated to holders of a Personal Account may be amended and/or supplemented over time at the discretion of the Data Controller.
Some of the personal information that we request you to submit to us when creating your Personal Account are compulsory, as they are indispensable for us to be able to process your request to open a Personal Account; the communication of other personal information is optional, but failure to submit them may make it impossible for us to provide you with some of the services, or part of some of them, dedicated to those who have a Personal Account on our website;

Learn more about registering and logging into your personal account
When you activate an account on our website, you must provide us with your email address, name, gender, date of birth (mandatory, we need this information to make sure you are not under the age of 16) and secret password to create a Tod's account. If you do not provide the above data, you may not be able to complete the personal account activation process on our website.
To access your Personal Account on our website you will be asked to enter your email address and the password you chose when activating your Personal Account.
After logging in, you can complete or edit your personal data, including your name, gender, date of birth, country/region, state, detailed address, email address, and account password. By completing your personal information and clicking save, you agree to provide us with the above data. By providing your personal information you consent that we use them to allow you to create your Personal Account on our Site and to provide you with the related dedicated services.
(iii) enable us to respond to your contact request and allow us to provide you with the necessary assistance. The personal information we request you for when filling in the on-line form and/or which will be requested from you by our operators are indispensable to enable us to handle your request;

Learn more about our customer assistance
When communicating with customer service or handling disputes, you may need to provide us with your name, order data (including payment time, payment amount, payment channel), contact number and delivery address, etc., so to verify your identity data, check your order data and reply in time. If you do not provide this data, we may not be able to provide you with adequate assistance. By providing your personal data you consent that we use them to provide you with our customer care services.
(iv) enable us to provide you with the services on the Website (hereinafter “Services”) to which you have subscribed. The personal information that we request you to provide when you subscribe to a given service are indispensable for the provision of that service; therefore, failure to provide them may make it impossible, in whole or in part, for you to benefit from them.
The provision of any personal information is voluntary. However, failure to disclose certain personal information could prevent you from partially or fully using Service. Please note that the services available on our website may vary depending on your country of residence. Any and all further processing of your personal data, performed by the point of sale you selected, both preparatory and related to the purchase of Tod’s Group products shall be carried out by each retail company of Tod's Group, which, in its role as the Data Controller will provide you with, the necessary information concerning your privacy and the processing of your personal data.
In the event that communication channels such as messaging apps (WhatsApp, WeChat, Telegram, etc.) are used for the provision of services, please also read the privacy policy of the messaging platform used.

Learn more about the web site services
When you subscribe to one of our website services you may need to give us your name, contact details and any other information we need to be able to provide you with the service you are subscribing to. We will ask you to communicate only the information strictly necessary for the optimal provision of the service, therefore if you do not provide this data, we may not be able to provide you with the requested service. By providing your personal data you agree that we use them to provide you with our website services.

3.3. We will process your personal information in order to comply with compulsory regulatory provisions to which the Company is subject (LEGAL OBLIGATIONS).

3.4. Subject to legal restrictions and provisions, we may also use your personal information to purpose a LEGITIMATE INTEREST of ours or of third parties, as:
(i) detecting, preventing, or investigating potential security incidents or frauds;
(ii) facilitating the functionality of our mobile applications and websites;
(iii) improve our services and business processes;
(iv) enforcing our terms and conditions;
(v) exercise or defend a right of us or of a third party.
If we identify a new purpose for the personal information that we have collected from you, we will obtain your consent before using your personal information for the new purpose.

The processing will be carried out with the aid of telematic, paper and computer tools; such processing will be based on the principles of correctness, lawfulness, transparency and protection of your rights and confidentiality.
In particular, the processing of your data, including for profiling purposes, may be carried out by means of automated processes, for instance through the comparison and comparative analysis of your purchasing choices (types, quantities, frequency, etc.), during a given period and/or season, and through the analysis of the type and number of your possible requests for information on products made in a predetermined timeframe.
The information will be processed in such a way as to minimise the risks of destruction, loss, unauthorised access, or processing that is not permitted or not in accordance with the purposes of collection. We take all reasonable and practicable steps to protect your personal data, but unfortunately, no system or network can be guaranteed to be 100% secure. Should you have any reason to believe that your interaction with us is no longer secure, please notify us immediately as per the Section 9 “HOW TO CONTACT US?” of the privacy policy (please note that notifications by post will increase the time it takes for us to respond to the problem).

Except as otherwise set out herein, we will not disclose, trade, rent, sell, or otherwise transfer personal information about our customers to any external recipient without consent.
For the purposes set out in the Section “3. HOW WE USE YOUR PERSONAL DATA?” of the privacy policy, we may have to share your personal information with the parties as set out below:
(i) Internal Third Parties: other Tod’s Group companies acting on our behalf:
• to provide us with technical and organizational services, with the ultimate aim of pursuing the purposes described above;
• in order to involve you in local marketing initiatives;
• to provide you with a tailored service and a better purchasing experience when you visit Tod’s Group shops.
(ii) External Third Parties: our service providers that assist us with a variety of functions including with research, mail and delivery, security, insurance, professional advisory (including legal, accounting and auditing advice), banking, payment processing, fraud checks, data storage, data processing, order tracking, marketing, product reviews, responding to customer queries and complaints or technology services.
(iii) Public Authorities, in response to formal and lawful requests from the latter or in execution of regulatory obligations;
(iv) Persons authorised by the Company to process personal information necessary to perform activities strictly related to the provision of services, who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality (e.g., employees of the Company);
We may also share your personal information in the event of a reorganisation, merger, sale, joint venture, assignment, transfer of our business or any part of it (including in connection with any bankruptcy or similar proceedings). In any case, your personal information will be processed for the same purposes set out in this Privacy Policy. When providing personal information to third parties, to process them on our behalf, we will only select partners who have implemented adequate safeguards to prevent personal information from being retained by them longer than necessary for the data processing; and to prevent unauthorized or accidental access, processing, deletion, loss, or use. These third parties are subject to a nondisclosure agreement and to other legal restrictions that govern their use of information we provide them, and they are not authorized to use or disclose personal information for any purpose other than to provide services on our behalf or as otherwise required by applicable law.
By your receipt of this Privacy Policy, we will assume, unless we hear from you otherwise, that you consent to the collection, use and disclosure of your personal information by us in accordance with this Privacy Policy.

Your personal information will be transferred to Italy (EU). We would like to point out that the Regulation, to which we are subject, provides a standard of protection to personal information that is comparable to the protection under the PIPEDA.
Should it become necessary to transfer your personal information outside the European Economic Area (EEA), to companies of the Tod's Group and/or to third parties who carry out tasks of a technical and organizational nature on our behalf which are consistent with the pursuit of the purposes for which your information have been collected and processed, this will only take place where it is possible to guarantee a level of protection of personal information equivalent to that of the European Community.
In fact, we guarantee that your personal information may only be transferred to a country outside the European Economic Area if at least one of the instruments recognized by the Regulation as guaranteeing an adequate level of protection for the personal information transferred has been adopted, namely:
(i) the Adequacy Decisions adopted by the European Commission pursuant to Article 45 of the Regulation;
(ii) the provision of specific Standard Contract Clauses (EU Model Clauses), approved by the European Commission, in order to ensure that the level of protection of personal information processed by our partners outside the EEA complies with that guaranteed within the European Economic Area.
We also undertake to carry out, in accordance with the law, any prior risk assessment regarding the transfer of personal data, adopting, where appropriate, any additional security measures in addition to the protections already guaranteed by the aforementioned transfer instruments.
In any event, when we export your personal information out of Canada, we will take all reasonable precautions and exercise all due diligence to ensure that the recipient organization provides a standard of protection to personal information that is comparable to the protection under the PDPA.
You can receive further information on data protection guarantees in case of transfer to countries outside the European Economic Area or Canada contacting our Data Protection Officer (DPO) to the addresses indicated in the Section 9 “HOW TO CONTACT US?” of the privacy policy.

Your personal information will be processed for varying periods of time depending on the different purposes of the processing; in any event, only for the period of time strictly necessary to achieve the purposes for which the information was collected and processed. Reached the maximum terms of retention of personal data, based on the deadlines detailed below, these will be deleted or if made anonymous.
For the processing purposes set out below, the processing and storage of your personal information will be as follows:

7.1. Purposes of processing based on explicit 'CONSENT', as referred to in point 3.1 of the privacy policy:
(i) Marketing activities: until consent is revoked;
(ii) Profiling activities: 7 years from the date of issue of your consent, with automatic renewal in the event of a new purchase at a Tod's Group shop or website.

7.2. Processing purposes based on 'FULFILMENT OF CONTRACT OBLIGATIONS OR PRE-CONTRACT MEASURES', referred to in point 3.2 of the privacy policy:
(i) Sale of Tod's Group products: until complete fulfilment of the contract obligations arising from the sale;
(ii) Provision of services dedicated to Personal Account holders: until you close your Personal Account or 7 years from your last interaction with your Personal Account, whichever is earlier. With the closure of your personal account, all personal information contained therein will be deleted;
(iii) Provision of support services to users of the Web Site: until complete fulfilment of the commitments undertaken following your request for assistance, support, or contact;
(iv) Other services available on the Website: until we have fully discharged our obligations in respect of your membership of the chosen service.

7.3. Purposes of processing based on 'LEGAL OBLIGATIONS', as referred to in point 3.3 of the privacy policy: the storage of your personal information may be further extended, with respect to the timeframe indicated above, should the storage of your personal information be required by compulsory legal regulations, within the time limits provided for by the latter.

7.4. Purposes of processing based on 'LEGITIMATE INTEREST', as referred to in paragraph 3.4 of the privacy policy: should the processing activities be conducted on the basis of a legitimate interest, either ours or that of third parties, the retention of your personal information shall be limited to the time strictly necessary to achieve the legitimate interest pursued from time to time.
Should the legitimate interest pursued lie in the exercise and defence of a right of ours in a court of law, the retention of your personal information may extend up to the last instance.

We would like to remind you that you have the right at any time to know what personal information we hold about you and how they are being processed, to request that they be updated or corrected and, in the cases provided for by current legislation, to obtain their deletion, restriction of processing or to object to their processing. If you wish, you may also receive your personal information in electronic format for the purpose of transfer to a third party indicated by you.

8.1. Request to access your personal information as well as receive information on the purpose of the processing, the categories of information processed, the recipients or categories of recipients to whom your personal information may be disclosed, the planned retention period, the application or non-application of profiling mechanisms and automated decision-making processes.

8.2. Request to rectify your personal data. This right allows you to correct or complete the information concerning you, although in some cases a prior verification of the correctness of the new information provided by you is necessary.

8.3. Request to delete your personal data. This right allows you to request the deletion or removal of your personal information if there are no valid reasons for continuing the processing. You also have the right to request the deletion or removal of your personal information if you have exercised your right to object to the processing and there is no other legal basis for us to keep it, or if we have processed your information in violation of the law or if we are obliged to delete your personal information in order to comply with a specific legal provision. Please note that we may not be able to comply with your request for deletion or may only be able to comply with it partially; for example, because of legal, juridical, or fiscal constraints beyond our control that prevent us from deleting all or part of your personal data. The reasons for our total or partial impossibility of fulfilling your request will be submitted to you promptly.
Please note that when we decide to execute your deletion request, we will delete your information from the server as soon as possible, but due to applicable technological, legal and security restrictions, we may not be able to delete the corresponding information from the system. backup right away. In such cases, we will hold your personal information securely and isolate it from any further processing until the backup is deleted or anonymised.

8.4. Request for restriction of personal information processing. Said right enables you to request the suspension of the processing of your personal information in the following cases:
(i) if you request us to determine the correctness of your data;
(ii) if you do not wish your information to be deleted, despite the fact that the use of the information by us is in breach of a regulation;
(iii) if you wish your information to be retained even if the reasons for their retention by us have ceased to exist, because you wish to ascertain, exercise, or defend a legally protected right;
(iv) if you have objected to the use of your information but it is necessary for us to ascertain the existence of legal grounds for their use;
You have the right to restrict our processing of your personal information under certain circumstances, and the right to object us to use your personal information for automated decision-making, profiling, or the right to object us to process your publicly available personal data, or to opt-out the share of your personal information with third parties if required by applicable law.

8.5. Request to object to the processing of your personal data. By exercising such right, you may obtain the cessation of the processing of your personal information in relation to the purpose(s) indicated by you. We would like to point out that our granting of your request for objection may or may not take place on the basis of the lawfulness of the processing itself.

8.6. Request for portability of your personal data. You have the right to obtain a copy of your personal data. Without prejudice to the limits defined by the applicable legislation, upon your request, we will send a copy of your personal information to a third party indicated by you, in the manner prescribed by current legislation / governmental authorities.

8.7. Revocation of consent. If the processing is carried out against your explicit consent, we will, within the timeframe provided for by the law, execute your request for revocation and cease the processing in question. For personal information obtained by us based on your consent, you have the right to change the scope of your consent or withdraw your consent by disabling device functions, setting privacy Settings, cancelling corporate customer identity authentication, or cancelling your account. Please understand that after you withdraw your consent, we will no longer process the personal information obtained based on your consent, which will affect the products or services provided to you corresponding to this part of personal data. However, your decision to withdraw your consent or authorization will not affect the prior processing of personal information based on your consent before.
With regard to revoking your consent to the processing of your personal information for marketing and/or profiling purposes, without prejudice to the possibility of exercising this right by writing to the e-mail address dataprivacyofficer@todsgroup.com, we would like to point out that in each of our communications, by e-mail or SMS, of a promotional nature, there is a function through which you may autonomously
(i) proceed to block one or more of the communication channels used by us to contact you;
(ii) withdraw consent to the processing of your information for marketing purposes. In this case, any communication from us of an advertising and/or promotional nature will cease, and any active newsletter service (relating to any Tod's Group brand) will be automatically deactivated;
(iii) withdraw consent for profiling purposes. The same functions are available within your Personal Account, if you have activated one.
In addition, a functionality is available in each of our newsletters through which you can unsubscribe from the newsletter service. Please note that you will not be discriminated against in any way for having exercised one or more of the rights recognised by the legislation, nor will such exercise have any repercussions on any existing relationship with the Company.

If you want to know more information about this privacy policy, including exercising your rights, complaints, or the rules of the processing of your personal data, if you have any questions, you can contact our contact points below detailed:
• by post: Data Protection Officer - Tod's S.p.A., Via Filippo Della Valle n. 1, 63811 Sant'Elpidio a Mare (FM) - Italy (EU).
• by e-mail: dataprivacyofficer@todsgroup.com.
When exercising the aforementioned rights, we reserve the right to request you, in the manner we deem most appropriate, for specific information to help us confirm your identity, in order to be reasonably sure that only you have access to your personal information and that they are not disclosed to third parties not entitled to receive them.
We undertake to answer and follow up your request, where well-founded, without delay, by and no later than 30 (thirty) days of receipt of the request to exercise one or more rights. Occasionally, within the time limits granted by law, we may take longer if the request is particularly complex or if you have made several requests. In that case, we will notify you and keep you updated.
The exercise of your rights is completely free of charge. Should your claims, however, be manifestly unfounded or excessive, particularly due to their repetitive nature, we reserve the right to i. the right to charge you a reasonable fee based on the administrative costs incurred in providing you with the information or communication or taking the requested action;
ii. to refuse to comply with your request.

This privacy policy will be changed to adapt to the law, technological and practice changes. However, we will not reduce your rights under this privacy policy without your express consent. We will post any changes to this privacy policy on this page. For major changes involving your rights, we will also provide more significant notifications, such as in- APP notification or email notification.
Please refer to the indication 'LAST UPDATED' at the top of this Privacy Policy. We therefore invite you to visit this page periodically.
We may also need to contact you to obtain your consent in order to allow you to continue using the services, if this is necessary due to changes in applicable law.