Privacy Policy

Neta Privacy Policy

(A) This Notice

This Notice is issued by Husqvarna AB (publ.) on behalf of itself, its subsidiaries and its affiliates (together, “Husqvarna Group”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products or services, job applicants, and visitors to our premises (together, “you”). Defined terms used in this Notice are explained in Section (B) below.
Details of the relevant controllers under this Privacy Notice are provided inSection (W) below. Any country specific provisions are set out in Appendix 1.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

(B) Definitions

• “App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means) including but not limited to Automower Connect, My Automower, Husqvarna Battery Connect, Husqvarna Fleet Services 2.0, Husqvarna Sales Tool, Husqvarna Connect, Husqvarna Group Events, and GARDENA Smart System.
• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• “Site” means any website operated, or maintained, by us or on our behalf.

(C) Collection of Personal Data

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application, or when you enter a contest or participate in a promotional campaign, or when you fill out a contact form).
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we quote on or provide a service to you, or to your employer, our service providers process orders in online shops and subsequently provide us with the associated data, we receive information about payment or delivery notifications).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• App data: We collect or obtain Personal Data when you download or use any of our Apps, including when you use an App in connection with an Automower or other robotic lawnmower, or any of our other products or services.
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site (technical connection data, e.g. the specific web page accessed, your IP address, the date and time of access, the end device used, browser configuration data).
• Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, Apps, products, or services.
• Content and advertising information: If you choose to interact with any third party content or advertising on a Site or in an App, we receive Personal Data about you from the relevant third party.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities, social media providers; etc.).
• Tracking data: We may collect or obtain Personal Data through web page tracking and newsletter tracking.

(D) Creation of Personal Data

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your purchase history.

(E) Categories of Personal Data we Process

We may Process the following categories of Personal Data about you provided we have an applicable legal basis:

• Personal details:given name(s); preferred name; and photograph.
• Demographic information:gender; date of birth / age; nationaolty; salutation; title; and language preferences.
• Contact details: correspondence address; shipping address; telephone number; fax number, email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Purchase details: records of purchases and prices; and consignee name, address, contact telephone number and email address.
• Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
• Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information.
• Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

(F) Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights;
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your SensitivePersonal Data (this legal basis is only used in relation to Processing that is entirely voluntary –it is not used for Processing that is necessary or obligatory in any way); or
• Manifestly made public: We may Process your Sensitive Personal Data where the Processing of such Personal Data relates to data which are manifestly made public by you as a data subject, e.g. on our Fan Pages in social media.

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

(G) Purposes of Processing and Legal Bases for Processing

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

(H) Disclosure of Personal Data to third parties

We disclose Personal Data to other entities within the Husqvarna Group, for legitimate business purposes and the operation of our Sites, Apps, products, or services, in accordance with applicable law. In addition, we disclose your Personal Data to:

• you and, where appropriate, your appointed representatives;
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, lawyers and other outside professional advisors to Husqvarna Group, subject to binding contractual obligations of confidentiality;
• third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (H);
• any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
• any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content or when you choose to connect your Husqvarna Group products or services with third party products or services. If you choose to interact with any such advertising, plugins, content or connect to such products/services, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy notice before interacting with its advertising, plugins, content or connecting Husqvarna Group products or services with third party products or services.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

(I) Profiling

(J) International transfer of Personal Data

Because of the international nature of our business, we transfer Personal Data within the Husqvarna Group, and to third parties as noted in Section (H) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section (W) below. In case we use a Processor that has adopted Binding Corporate Rules we may also transfer your Personal Data on the basis of Binding Corporate Rules.

Please note that when you transfer any Personal Data directly to a Husqvarna Group entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.

(K) Data Security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet –any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(L) Data Accuracy

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
  From time to time we may ask you to confirm the accuracy of your Personal Data.

(M) Data minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

(N) Data Retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

1. we will retain Personal Data in a form that permits identification only for as long as:

• a. we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or
• b. your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your personal data are included in a contract between us and your employer, and we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data; or until you withdraw your consent and no other legal basis exists; or as long as there are statutory retention obligations),

plus:

2. the duration of:

• a.applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and
• b. an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:

3. in addition: if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim; we may also continue to process Personal Data if deleting the data would conflict with the requirement to protect the interest of the persons concerned; or if the processing is otherwise necessary in accordance with Art.17 (3) of the GDPR.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

(O) Your legal rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, products, or services, if you do not provide us with your Personal Data –e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;•
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please visit https://privacyportal.husqvarnagroup.com or use the contact details provided in Section (W) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(P) Cookies and Similar Technologies

When you visit a Site or use an App we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. This helps us make our site better and easier to use. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policies available via the links outlined above.

(Q) Terms of Use

All use of our Sites, Apps, products, or services is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

(R) Direct Marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, products, or services that may be of interest to you. If we provide Sites, Apps, products, or services to you, or if you have requested to receive our newsletter, we may send information to you regarding our Sites, Apps, products, or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

Our newsletters contain tracking pixels. A tracking pixel is an invisible graphic in HTML emails; its purpose is to generate a log file when the email is opened and to log which links are activated from the newsletter and subsequently analyse this data. This allows us, by means of statistical evaluations, to determine the success of our newsletter campaigns and to optimise our newsletters, e.g. so that you receive information and offers that are more appropriate to your interests.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, products, or services you have requested.

We invite you to use our online garden planner. In order to save your planned garden across all your devices you will need to register. The registration form will allow us to personalize how we address you, it also details the scope of the data we collect for the assignment of the garden. If you choose to share the garden you have created with third parties, this will be done anonymously, meaning that the garden you share cannot be used to identify you personally.

(S) Competitions

From time to time, you have the opportunity to take part in competitions or similar promotional campaigns, for example via our websites. As part of these campaigns, it may be necessary to collect and store your Personal Data, as further specified in the campaign entry form, to administer the competition. Data that we do not necessarily need for the conduct of the competition but which, for example, allows us to notify you faster in the event that you may win, are expressly marked as voluntary information. Any Personal Data that you provide to us in the context of such campaigns will be used exclusively for the handling of the campaign (in the case of a competition, for example, to determine the winner(s), notify the winner(s) and send the winner(s) their prize). When the campaign is completed, data of the participants who did not win will be deleted immediately and the data of the winner(s), will be deleted upon expiry of the statutory retention period.

(T) Online Application Process

We provide an online job application process. The data you submit, including any files you upload, are transferred via a secure connection. Your electronic application data will be routed to the relevant personnel department, who will send it only to the relevant department for the job in question and/or to the people who are authorised to process the application. All parties will treat your application documents with the utmost care and keep the content strictly confidential.

Following completion of the candidate selection process, we will retain your application documents for six months, after which time we will delete them and/or destroy any copies, unless we have entered into an employment contract with you. If we wish to keep your application documents on file in our applicant pool, we will contact you about this. During this communication, we will give you the opportunity to actively consent to the continued storage of your documents. Regardless of whether or not you currently have an open application, your applicant account and the associated data will continue to be stored unless you deactivate them; this gives you the opportunity to apply for other jobs with us.

Please note that applications submitted to us by email are transferred to us in an unencrypted format. We therefore recommend that you use the online application portal where possible.

(U) Minors

Our Sites are not aimed at minors and we do not knowingly collect Personal Data from minors.

(V) Social Media and Other Third Party Platforms

Social Media Buttons

We use social media buttons for Facebook, Twitter, Instagram, Pinterest, YouTube, LinkedIn and Xing on our Websites. The social media buttons are not integrated as plugins via iFrame, but only provide a link to our company representation page (“Fan Page”) on the respective social media platform. No Personal Data is transmitted to such social media provider upon clicking on a social media button

Fan Pages on Social Media Platforms

We maintain Fan Pages on social media and other third party platforms to market and promote our products and services. When we provide a Fan Page on a social media or other third party platform, we are a joint controller with the provider of the platform. We operate Fan Pages in joint controllership with Facebook and Instagram, Pinterest, Twitter, YouTube, LinkedIn and Xing (incl. Kununu). We recommend that you review each such company’s privacy notice for further information about the processing they carry out and the contact details for such companies. We will Process Personal Data of both registered and non-registered visitors of our Fan Pages.

Registered Visitors

We Process data relating to our Sites (such as user identification), Personal details and Contact details (e.g. shared profile data). We also Process Personal Data generated through sharing of content, message exchange and communication. We may also Process special categories of Personal Data, if the user has shared such Personal Data

Registered and Non-Registered Visitors:

We Process pseudonymized data such as statistics and insights on visitors’ interaction with the content on our Fan Page (page activities, page views, like information, reach, general demographic, location and interest-related information on age, gender, country, city, language), evaluations of the success of our advertisements, and other analyses. We cannot merge pseudonymized data with the corresponding attribution features (e.g. name details) and hence it is not possible for us to identify individual visitors who remain anonymous

We are not responsible for the user’s experience within the Fan Pages, e.g. with regard to the use of interactive functions such as sharing and rating.
A Fan Page or other corporate presence on third party platforms is just one of several options for contacting us or receiving information from us. As an alternative, the information offered via our Fan Pages and corporate presences can also be accessed on our websites.

Targeting

As further explained in our Cookie Policies (see Section (P) above), we may use cookies on our sites to allow Facebook, if you have a Facebook account, to serve you Husqvarna Group ads that are relevant to your interests. To do so, we direct Facebook, based on the data collected by the Facebook pixel, to create a group of Facebook users that will be the audience of our ad campaigns (so called custom audiences). For the creation of custom audiences, we and Facebook Ireland are acting as joint controllers and have entered into Facebook’s Controller Addendum to determine the parties’ respective responsibilities. We are responsible to provide the information set out herein, and Facebook Ireland is responsible for enabling data subjects’ rights under Articles 15-20 GDPR with regard to personal data stored by Facebook Ireland after the joint processing. You can find the relevant contact details and further information on how Facebook Ireland processes personal data, including legal basis and ways to exercise your rights against Facebook Ireland in Facebook Ireland’s Data Policy at https://www.facebook.com/about/privacy.
Facebook may also use the custom audience data to create lookalike audiences, which are Facebook users with similar interests or profiles as our custom audiences, for the purpose of delivering our ads to these audiences. For any such processing, Facebook is the data controller and its privacy notice will apply to this processing. You can view your Facebook ad settings and update your preferences with Facebook at any time.

(W) Details of Controllers

For the purposes of this Notice, the relevant Controllers are:

Alternatively, you may contact us via https://privacyportal.husqvarnagroup.com/ If you have any questions related to this Privacy Notice you may also contact us at [email protected].

Our Group Data Protection Officer is contactable using the details set out above and can also be contacted by email at [email protected].

APPENDIX 1 –COUNTRY SPECIFIC PROVISIONS

(1) Germany

(R) Direct Marketing

Double-Opt-In-Procedure within Newsletter SubscriptionIf explicitly requested by you, we will send you our newsletter on the topics you have chosen as well as information about our company. Please note that the delivery can only take place after you have explicitly confirmed your subscription request again within the scope of our double opt-in procedure. The personal data collected during the newsletter registration process is used exclusively for the purpose of sending and personalising the newsletter (e.g. to address you with your name). You can revoke your consent to the storage of personal data that you have given us for the purpose of sending the newsletter at any time with effect for the future. For the purpose of revoking your consent, each newsletter contains a corresponding link; alternatively, you can also contact us directly so that we can implement your revocation. We have provided details of the consent given to us in the double opt-in e-mail.

(U) Minors

Our Sites are not aimed at minors and we do not knowingly collect Personal Data from minors (except applicants). If persons under the age of 16 transmit personal data to us, this is only permitted if the parent or guardian has given his or her consent or has agreed to the consent of the minor. In accordance with Art. 8 Para. 2 GDPR, the contact details of the parent or guardian must be provided to us in order to convince us of the consent or approval of the parent or guardian. This data and the data of the minor will then be processed in accordance with this Privacy Notice. If we discover that a minor under the age of 16 has sent personal data to us without the consent of the parent or legal guardian, we will delete the data immediately.

(W) Details of Controllers

Our Data Protection Officer for Germany is contactable using the details set out above and can also be contacted by email at [email protected].

(2) Austria

(R) Direct Marketing

Double-Opt-In-Procedure within Newsletter Subscription
If explicitly requested by you, we will send you our newsletter on the topics you have chosen as well as information about our company. Please note that the delivery can only take place after you have explicitly confirmed your subscription request again within the scope of our double opt-in procedure. The personal data collected during the newsletter registration process is used exclusively for the purpose of sending and personalising the newsletter (e.g. to address you with your name). You can revoke your consent to the storage of personal data that you have given us for the purpose of sending the newsletter at any time with effect for the future. For the purpose of revoking your consent, each newsletter contains a corresponding link; alternatively, you can also contact us directly so that we can implement your revocation. We have provided details of the consent given to us in the double opt-in e-mail.

(U) Minors

Our Sites are not aimed at minors and we do not knowingly collect Personal Data from minors (except applicants). If persons under the age of 16 transmit personal data to us, this is only permitted if the parent or guardian has given his or her consent or has agreed to the consent of the minor. In accordance with Art. 8 Para. 2 GDPR, the contact details of the parent or guardian must be provided to us in order to convince us of the consent or approval of the parent or guardian. This data and the data of the minor will then be processed in accordance with this Privacy Notice. If we discover that a minor under the age of 16 has sent personal data to us without the consent of the parent or legal guardian, we will delete the data immediately.