img-20210914-wa0015

 Ⓒ 2021  IRONSTEEL  Via Belvedere, 15 - 6934 - Bioggio - Ti - Switzerland - Idi Che - 177.265.700

PRIVACY POLICY IRONSTEEL.CH

This Application collects some Personal Data of its Users.

This document can be printed using the print command present in the settings of any browser.

Data Controller
IRONSTEEL via Belvedere, 15 - 6934 - Bioggio - TI - Switzerland
Owner's email address: info@ironsteel.ch

Types of Data collected
Among the Personal Data collected by this Application, independently or through third parties, are: Cookies; Usage Data; phone number; first name; last name; email; unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example); session number; Data disclosed in order to use the Service.
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific informative texts displayed before the collection of the data itself.
Personal Data can be freely provided by the User or, in case of Usage Data, automatically collected during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In the cases in which this Application indicates some Data as optional, the Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who may have doubts as to which Data is mandatory are encouraged to contact the Data Controller.
The possible use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he/she has the right to communicate or disseminate them, releasing the Owner from any liability towards third parties.
Modality and place of treatment of collected Data
Treatment modalities
The Owner adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The treatment is carried out through computer and/or telematic instruments, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.
Legal basis of the treatment 

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
- the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the need for the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such processing. However, this does not apply where the processing of Personal Data is governed by European legislation on the protection of Personal Data;
- the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
- the processing is necessary for the performance of a legal obligation to which the Data Controller is subject;
- the processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;
- the processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.
However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract.
Place
The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.
Your Personal Data may be transferred to a country other than the one in which you are located. You may refer to the section on details of the processing of Personal Data for further information on the location of processing.
The User has the right to obtain information on the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or formed by two or more countries, such as the UN, as well as on the security measures adopted by the Data Controller to protect the Data.

The User may verify whether one of the transfers just described takes place by examining the section of this document relating to details on the processing of Personal Data or request information from the Data Controller by contacting it at the contact details given at the beginning.
Storage Period
The Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of such contract is completed.
- Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is satisfied. You may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.
When the processing is based on the User's consent, the Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this period, the right of access, cancellation, rectification and the right to Data portability can no longer be exercised.Purposes of the Data collected
The User's Data are collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Statistics, SPAM protection, Displaying content from external platforms, Interaction with social networks and external platforms, Contacting the User, Registration and authentication, Tag management, Advertising, Remarketing and behavioral targeting and Content and functionality performance testing (A/B testing).
To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section "Details on the processing of Personal Data".
Personal Data Processing Details
Personal Data is collected for the following purposes and using the following services:
- Contacting the User
Contact by phone (this Application)
Users who have provided their phone number may be contacted for commercial or promotional purposes related to this Application, as well as to fulfill support requests.
Personal data processed: phone number.
Contact form (this Application)
The User, by filling out the contact form with his/her own Data, consents to the use of such Data to respond to requests for information, quotes, or any other nature indicated in the header of the form.
Personal Data: last name; email; name.
Mailing list or newsletter (this Application)
By registering to the mailing list or newsletter, the User's email address is automatically added to a list of contacts to whom email messages containing information, including commercial and promotional information, relating to this Application may be sent. The User's email address may also be added to this list as a result of registering with this Application or after making a purchase.
Personal data processed: surname; email; name.
- Tag management
This type of service is functional to the centralized management of tags or scripts used on this Application.
The use of these services involves the flow of User Data through them and, if necessary, their retention.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data Processed: Usage Data.
Place of treatment: Ireland - Privacy Policy.
- Interaction with social networks and external platforms
This type of service allows for interactions with social networks, or other external platforms, directly from the pages of this Application.The interactions and information acquired by this Application are in any case subject to the privacy settings of the User relating to each social network.
This type of service may still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to disconnect from the respective services to ensure that the data processed on this Application is not linked back to the User's profile.
+1 button and Google+ social widgets (Google Ireland Limited)
The +1 button and Google+ social widgets are services for interaction with the Google+ social network, provided by Google Inc.
Personal Data Processed: Cookies; Usage Data.
Place of processing: Ireland - Privacy Policy.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook "Like" button and social widgets are services for interaction with the Facebook social network, provided by Facebook, Inc.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States - Privacy Policy.
YouTube social button and widgets (Google Ireland Limited)
The YouTube social button and widgets are services for interaction with the YouTube social network, provided by Google Inc.
Personal data processed: Usage Data.
Place of treatment: Ireland - Privacy Policy.
Linkedin social button and widgets (LinkedIn Corporation)
The LinkedIn social button and widgets are services for interaction with the Linkedin social network, provided by LinkedIn Corporation.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States - Privacy Policy.
Twitter Tweet button and social widgets (Twitter, Inc.)
The Tweet button and Twitter social widgets are services for interaction with the Twitter social network, provided by Twitter, Inc.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States - Privacy Policy.
Pinterest "Pin it" button and social widgets (Pinterest)
Pinterest's "Pin it" button and social widgets are services for interacting with the Pinterest platform, provided by Pinterest Inc.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States - Privacy Policy.
AddThis (Oracle Corporation)
AddThis is a service provided by Oracle Corporation that displays a widget that allows interaction with social networks and external platforms and the sharing of content on this Application.
Depending on the configuration, this service may display widgets belonging to third parties, ad

for example, the managers of social networks on which to share interactions. In this case, the third parties that provide the widget will also be aware of the interaction carried out and the Usage Data related to the pages where this service is installed.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States - Privacy Policy.
- SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Personal Data of the Users, in order to filter it from parts of traffic, messages and contents recognized as SPAM.
Google reCAPTCHA (Google Ireland Limited)
Google reCAPTCHA is a SPAM protection service provided by Google Inc.
Use of the reCAPTCHA system is subject to Google's privacy policy and terms of use.
Personal data processed: Cookies; Usage Data.
Place of processing: Ireland - Privacy Policy.
- Advertisement
This type of service allows the User's Data to be used for commercial communication purposes. These communications are shown on this Application in the form of banners and other forms of advertising, also in relation to the User's interests.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below.
Some of the services indicated below may use Tracking Tools to identify the User or use the technique of behavioral retargeting, i.e. displaying customized advertisements based on the User's interests and behavior, also detected outside this Application. For further information, we suggest that you check the privacy policies of the respective services.
In addition to the opt-out features offered by the services below, the User may opt-out by visiting the opt-out page of the Network Advertising Initiative.
Users may also opt-out of certain advertising features through corresponding device configuration options, such as mobile device advertising configuration options or generic advertising configuration.
Google Ad Manager (Google Ireland Limited)
Google Ad Manager is an advertising service provided by Google Ireland Limited with which the Owner may conduct advertising campaigns in conjunction with external advertising networks with which the Owner, unless otherwise specified herein, has no direct relationship.
Users who do not wish to be tracked by the different advertising networks may use Youronlinechoices. For an understanding of Google's use of data, please see Google's partner policy.
This service uses the "DoubleClick" cookie, which tracks the use of this Application and the behavior of the User in relation to advertisements, products and services offered.

The User can decide at any time to disable all DoubleClick cookies by going to: Ads Settings.
Personal Data Processed: Usage Data; Tracking Tool.
Place of treatment: Ireland - Privacy Policy.- Registration and authentication
By registering or authenticating, the User allows the Application to identify him/her and give him/her access to dedicated services.
Depending on what is indicated below, the registration and authentication services may be provided with the help of third parties. If this happens, this Application may access some Data stored by the third party service used for registration or identification.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and connected to the social network Facebook.
Personal Data processed: various types of Data as specified by the privacy policy of the service.
Place of processing: United States - Privacy Policy.
- Remarketing and behavioral targeting
This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the User's past use of this Application.
This activity is facilitated by tracking Usage Data and using Tracking Tools to collect information that is then transferred to partners that manage remarketing and behavioral targeting activities.
Some services offer an email list-based remarketing option.
In addition to the opt-out features offered by the services below, Users may opt-out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through corresponding device configuration options, such as mobile device advertising configuration options or generic advertising configuration.
Google Ad Manager Audience Extension (Google Ireland Limited)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks visitors to this Application and enables selected advertising partners to show them personalized ads within the web.
Personal Data Processed: Usage Data; Tracking Tool.
Place of processing: Ireland - Privacy Policy - Opt Out.
- Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.
Google Analytics (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google uses the Personal Data collected in order to track and examine the use of this Application, compile reports and share them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the ads of its advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland - Privacy Policy.
Google Analytics with anonymized IP (Google Ireland Limited)
Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the Personal Data collected in order to track and examine the use of this Application,

compile reports and share them with other services developed by Google.
Google may use Personal Data to contextualize and personalize ads in its ad network.
This Google Analytics integration anonymizes your IP address. The anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or other countries that are members of the Agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google's servers and shortened within the United States.
Personal data processed: Cookies; Usage Data.
Place of processing: Ireland - Privacy Policy.
Advertising report generation functionality in Google Analytics (Google Ireland Limited)
Google Analytics on this Application has enabled advertising report generation features, which collect additional information from the DoubleClick cookie (web activity) and device ad IDs (application activity). This allows the Data Controller to analyze specific Data related to Users' behaviors and interests (Traffic Data and Ad Interaction Data by Users) and, if enabled, Demographic Data (age and gender information).

Users may opt out of Google's cookies by visiting Google's [Ad Settings] (https://adssettings.google.com/authenticated).
Personal Data processed: unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example); Tracking Tool; various types of Data as specified by the privacy policy of the service.
Place of processing: Ireland - Privacy Policy - Opt Out.
GameAnalytics (GameAnalytics ApS)
GameAnalytics is a statistics service provided by GameAnalytics ApS.
Personal Data Processed: Usage Data; Tracking Tool.
Place of processing: United States - Privacy Policy - Opt Out .
Google Analytics for Firebase (Google Ireland Limited)
Google Analytics for Firebase, or Firebase Analytics, is an analytics service provided by Google Ireland Limited.
For an understanding of Google's use of data, please see Google's Partner Policy.

Firebase Analytics may share Data with other services provided by Firebase including, for example, Crash Reporting, Authentication, Remote Config or Notifications. The User may consult this privacy policy for a detailed description of the other tools used by the Owner.

To allow Firebase Analytics to work, this Application uses some mobile device identifiers or technologies similar to cookies.

The User can opt-out of certain Firebase features through the settings of his mobile device. For example, the User can change the advertising settings on his cell phone or follow the instructions for Firebase that may be available.

within this privacy policy.
Personal data processed: number of sessions.
Place of processing: Ireland - Privacy Policy.
Demographic and Interest Reports by Google Analytics (Google Ireland Limited)
Google Analytics Demographic and Interest Data Reports is an advertising reporting feature that makes available Demographic and Interest Data within Google Analytics for this Application (Demographic Data means Age and Gender Data).

Users may choose not to use Google cookies by visiting Google's [Ad Settings] (https://adssettings.google.com/authenticated).
Personal Data processed: unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example); Tracking Tool.
Place of processing: Ireland - Privacy Policy - Opt Out.
YouTube Analytics and Reporting API (Google Ireland Limited)
YouTube Analytics and Reporting API is a video content statistics service provided by Google Ireland Limited.

Through this Service, this Application may collect Data directly or indirectly on or from the User's devices, including through the use of Tracking Tools. The Users may limit such access to their Data through the page of settings related to security provided by Google. Users, at any time, may contact the Data Controller to request further information on privacy settings through the contact details provided in this document.

The Data collected through the Service may also be used to help third parties display customized advertisements based on interests. Users may opt out of receiving such personalized advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data Processed: Data disclosed in order to use the Service.
Place of processing: Ireland - Privacy Policy - Opt out.
- Performance testing of content and functionality (A/B testing)
The services contained in this section allow the Data Controller to track and analyze the User's response, in terms of traffic or behavior, to changes in the structure, text or any other component of this Application.
Google Optimize (Google Ireland Limited)
Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google").

Google may use Personal Data to contextualize and personalize ads in its advertising network.
Personal Data processed: Usage Data; Tracking Tool.
Place of processing: Ireland - Privacy Policy.

Google Optimize 360 (Google Ireland Limited)
Google Optimize 360 is an A/B testing service provided by Google Ireland Limited ("Google").

This service allows the Owner to identify groups of Users as targets on the basis of their past use of this Application. Users who disable monitoring by Google Analytics will not be included in the experiments created within Google Optimize 360.

Google may use Personal Data to contextualize and personalize ads in its ad network.
Personal Data Processed: Usage Data; Tracking Tool.
Place of processing: Ireland - Privacy Policy.
- Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and to interact with them.
If a service of this type is installed, it is possible that, even if the Users do not use the service, it collects traffic data relating to the pages where it is installed.
Google Fonts (Google Ireland Limited)
Google Fonts is a font style display service operated by Google Ireland Limited that allows this Application to integrate such content within its pages.
Personal Data processed: Usage Data; various types of Data as specified by the privacy policy of the service.
Place of processing: Ireland - Privacy Policy.
Google Calendar Widget (Google Ireland Limited)
Google Calendar Widget is a calendar content visualization service managed by Google Inc. that allows this Application to integrate such content within its pages.
Personal data processed: Cookies; Usage Data.
Place of processing: Ireland - Privacy Policy.
Google Maps widget (Google Ireland Limited)
Google Maps is a map display service operated by Google Inc. that allows this Application to integrate such content within its pages.
Personal data processed: Cookies; Usage Data.
Place of processing: Ireland - Privacy Policy.
YouTube Video Widget (Google Ireland Limited)
YouTube is a video content display service operated by Google Inc. that allows this Application to integrate such content within its pages.
Personal data processed: Cookies; Usage Data.
Place of processing: Ireland - Privacy Policy.
JWPlayer Widget (LongTail Ad Solutions, Inc. )
JWPlayer is a service for displaying video content managed by LongTail Ad Solutions, Inc. which allows this Application to integrate such content into its pages.Personal data processed: Cookies; Usage Data.
Place of processing: United States - Privacy Policy.
Instagram Widget (Instagram, Inc.)
Instagram is an image display service operated by Instagram, Inc. that allows this Application to integrate such content within its pages.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States - Privacy Policy.
YouTube video widget without cookies (Google Ireland Limited)
YouTube is a service for displaying video content managed by Google Ireland Limited which allows this Application to integrate such content into its pages.
This widget is set up so that YouTube does not save information and cookies about Users on this Application, unless they play the video.
Personal Data Processed: Usage Data.
Place of treatment: Ireland - Privacy Policy.
Font Awesome (Fonticons, Inc. )
Font Awesome is a font style display service operated by Fonticons, Inc. that allows this Application to integrate such content within its pages.
Personal data processed: Usage Data.
Place of processing: United States - Privacy Policy.
User Rights
The Users may exercise certain rights with reference to the Data processed by the Owner.
In particular, the User has the right to:
- revoke consent at any time. The User may revoke the consent to the processing of their Personal Data previously expressed.
- oppose the processing of their Data. The User may object to the processing of their Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
- access to their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.
- verify and request rectification. The User may verify the correctness of its own Data and request its update or correction.
- obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
- obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
- receive their Data or have it transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another owner. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, a contract to which the User is a party or contractual measures related thereto.- Propose a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details of the right to object
When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document.
How to exercise rights
In order to exercise the User's rights, Users may address a request to the contact details of the Controller set out in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.
Cookie Policy
This Application makes use of Tracking Tools. To learn more, the User may consult the Cookie Policy.
Further information on processing
Legal defense
The User's Personal Data may be used by the Data Controller in court or in the preparatory phases of any legal proceedings to defend against abuse of this Application or related Services by the User.
The User declares that he/she is aware that the Owner may be obliged to disclose the Data by order of public authorities.
Specific Informations
At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For operation and maintenance purposes, this Application and any third party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User's IP address.
Information not contained in this policy
Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Response to "Do Not Track" requests
This Application does not support "Do Not Track" requests.
To find out whether any third party services used support them, the User is invited to consult their respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details in its possession. Therefore, please consult with

frequency this page, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal data is any information that, directly or indirectly, even in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage Data
This is the information collected automatically through this Application (including by third party applications integrated into this Application), including: IP addresses or domain names of computers used by the User who connects with this Application, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User's IT environment.
User
The individual who uses this Application which, unless otherwise specified, coincides with the Interested Party.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Person Responsible)
The natural person, legal entity, public administration and any other entity that processes Personal Data on behalf of the Data Controller, as set out in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
This Application
The hardware or software tool through which Users' Personal Data are collected and processed.
Service
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.Cookies
Cookies are Tracking Tools that consist of small pieces of data stored within the User's browser.
Tracking Tool
Tracking Tool means any technology - e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that allows Users to be tracked, for example by collecting or storing information on the User's device.
Legal references
This privacy policy is drafted on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to this Application.
Last modified: April 6, 2021
iubenda hosts this content and collects only the Personal Data strictly necessary for its provision.