Privacy Policy of Ohana Tax & Financial Services

Ohana Tax & Financial Services collects some Personal Data from its Users.


Users may be subject to different protection standards and broader standards may therefore apply to some. Users can contact the Owner, to learn more about such standards.

This document contains a section dedicated to Users in the European Union and their privacy rights.

This document contains a section dedicated to Users in the United States and their privacy rights.


This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

Ohana Tax and Financial Services
135 Camino Dorado, Suite 8
Napa, CA 94558

Owner contact email: privacy@ohana.tax

Types of Data collected

Among the types of Personal Data that Ohana Tax & Financial Services collects, by itself or through third parties, there are: email address; name; phone number; Trackers; city; device information; browser information; Usage Data; first name; last name; username.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Ohana Tax & Financial Services.
Unless specified otherwise, all Data requested by Ohana Tax & Financial Services is mandatory and failure to provide this Data may make it impossible for Ohana Tax & Financial Services to provide its services. In cases where Ohana Tax & Financial Services specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Ohana Tax & Financial Services or by the owners of third-party services used by Ohana Tax & Financial Services serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through Ohana Tax & Financial Services.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Ohana Tax & Financial Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Displaying content from external platforms, Collection of privacy-related preferences, Analytics, Managing contacts and sending messages, Platform services and hosting, Contacting the User and Traffic optimization and distribution.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Analytics

    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

    Google Analytics 4 (Google LLC)

    Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Ohana Tax & Financial Services, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: browser information; city; device information; Trackers.

    Place of processing: United States – Privacy Policy – Opt Out.

    Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

  • Collection of privacy-related preferences

    This type of service allows Ohana Tax & Financial Services to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

    iubenda Cookie Solution (iubenda srl)

    The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on Ohana Tax & Financial Services.

    Personal Data processed: Trackers.

    Place of processing: Italy – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

  • Contacting the User

    Contact form (Ohana Tax & Financial Services)

    By filling in the contact form with their Data, the User authorizes Ohana Tax & Financial Services to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data processed: email address; first name; last name.

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

  • Displaying content from external platforms

    This type of service allows you to view content hosted on external platforms directly from the pages of Ohana Tax & Financial Services and interact with them.
    This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

    Calendly widget (Calendly, LLC)

    Calendly widget is a calendar content visualization service provided by Calendly, LLC that allows Ohana Tax & Financial Services to incorporate content of this kind on its pages.

    Personal Data processed: email address; name; phone number.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a Sale in California

    Google Fonts (Google LLC)

    Google Fonts is a typeface visualization service provided by Google LLC that allows Ohana Tax & Financial Services to incorporate content of this kind on its pages.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

  • Managing contacts and sending messages

    This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

    Mailchimp (Intuit Inc.)

    Mailchimp is an email address management and message sending service provided by Intuit Inc.

    Personal Data processed: email address; first name; last name; username.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a Sale in the United States
    • a Sharing in California

  • Platform services and hosting

    These services have the purpose of hosting and running key components of Ohana Tax & Financial Services, therefore allowing the provision of Ohana Tax & Financial Services from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
    Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    TaxDome

    TaxDome is a client relationship manager that allows Ohana Tax & Financial Services to manage, collect, and process personal information to provide services, secure messaging and communication services, and to incorporate content of this kind on its pages.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

  • Traffic optimization and distribution

    This type of service allows Ohana Tax & Financial Services to distribute their content using servers located across different countries and to optimize their performance.
    Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Ohana Tax & Financial Services and the User's browser.
    Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

    Cloudflare (Cloudflare Inc.)

    Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
    The way Cloudflare is integrated means that it filters all the traffic through Ohana Tax & Financial Services, i.e., communication between Ohana Tax & Financial Services and the User's browser, while also allowing analytical data from Ohana Tax & Financial Services to be collected.

    Personal Data processed: Trackers.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

Ohana Tax & Financial Services uses Trackers. To learn more, Users may consult the Cookie Policy.

This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Ohana Tax & Financial Services and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

  • Identifiers

    Personal Information collected or disclosed: email address, name, phone number, Trackers, city, device information, browser information, first name, last name

    Sensitive Personal Information collected or disclosed ℹ️: username

    Purposes:

    • Displaying content from external platforms
    • Analytics
    • Managing contacts and sending messages
    • Contacting the User

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Third-parties: Calendly, LLC, Google LLC, Intuit Inc., Ohana Tax & Financial Services

  • Internet or other electronic network activity information

    Personal Information collected or disclosed: Trackers, city, device information, browser information, Usage Data

    Purposes:

    • Collection of privacy-related preferences
    • Analytics
    • Displaying content from external platforms
    • Traffic optimization and distribution

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Third-parties: iubenda srl, Google LLC, Cloudflare Inc.

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Ohana Tax & Financial Services.

For example, you directly provide your Personal Information when you submit requests via any forms on Ohana Tax & Financial Services. You also provide Personal Information indirectly when you navigate Ohana Tax & Financial Services, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Ohana Tax & Financial Services and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

  • the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
  • the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
  • the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
  • the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
  • the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
  • the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

  • The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
  • The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have

  • The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

Additional rights for users residing in Utah

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have

  • The right to opt out of the processing of your Personal Information for Targeted Advertising;
  • The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on Ohana Tax & Financial Services.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Ohana Tax & Financial Services or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Ohana Tax & Financial Services may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Ohana Tax & Financial Services and any third-party services may collect files that record interaction with Ohana Tax & Financial Services (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Ohana Tax & Financial Services and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Personal Data (or Data) / Personal Information (or Information)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Sensitive Personal Information

Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.

Usage Data

Information collected automatically through Ohana Tax & Financial Services (or third-party services employed in Ohana Tax & Financial Services), which can include: the IP addresses or domain names of the computers utilized by the Users who use Ohana Tax & Financial Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Ohana Tax & Financial Services who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Ohana Tax & Financial Services. The Data Controller, unless otherwise specified, is the Owner of Ohana Tax & Financial Services.

Ohana Tax & Financial Services (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Ohana Tax & Financial Services as described in the relative terms (if available) and on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.

Targeted advertising

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations.

This privacy policy relates solely to Ohana Tax & Financial Services, if not stated otherwise within this document.

Latest update: December 22, 2022

iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.

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