Citadel Communications Group Corp. and its corporate affiliates or subsidiaries (collectively, CTS, Citadel, we, us or our) cares about privacy and wants you to be familiar with how we collect, disclose, and use (Process) information about you. This privacy notice (Privacy Notice) describes our practices concerning information we collect through our websites (the Websites or sites), social media pages we control (Social Media Pages), and software applications we make available (Apps) and through offline activities, such as when you provide your data by phone via our call centers or in person (collectively, for all items above, the Services). Please read the following to learn more about our privacy practices, and note that our practices are subject to applicable law. This means that they may be more limited in certain jurisdictions to reflect local legal requirements.
Information Categories We collect Personal Information (information that identifies you, relates to you, describes you or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you as a particular individual or as defined under applicable law, your household) about you from a variety of sources and use and disclose it for multiple purposes.
Contact Information
- Elements:
- Sample data elements include without limitation, real name, alias, postal address, phone number or email address
- Legitimate Business Interests / Purposes:
- We may use this information for our business transactions with you, including without limitation, to:
- Enter into or perform a contract with you.
- Respond to your inquiries or requests, or to complete and fulfill any purchases or services requests.
- Send transactional or administrative information to you.
- Allow you to participate in sweepstakes, contests and similar promotions, and to administer them.
- Send you communications we believe may interest you, for our own or third parties’ products and services.
- Allow you to send messages to a friend through the Services, or submit reviews or other user-generated content.
- Allow you to participate in any loyalty or other programs.
- Personalize your experience on the Services by presenting products and offers tailored to you.
- Allow you to enable multi-factor authentication to access your account
- Sources:
- You, when you interact with us, including without limitation as described above (for example, using the Services, contacting us, making a reservation, registering or paying for a product or service, staying at a property, providing us feedback or reviews, participating in loyalty or other programs, promotions or activities)
- Other sources, including without limitation public databases, joint marketing partners, data firms, social media platforms, from your social media connections, your social media account if you choose to connect it to your Website account if applicable, or other third parties.
- Sharing:
- We may share this information with Affiliates, Service Providers, Business Partners and Other Third Parties as described in this Privacy Notice or as permitted by law as described below under Information Disclosure.
- Subject to your marketing or other preferences (which may include consent), we may sell, share or license this information for financial consideration to our former affiliate, a timeshare corporation so that they may contact you about their products or services which may interest you.
- Your phone number will not be sold or shared with Affiliates, Service Providers, Business Partners and Other Third Parties for the purposes of sending unsolicited marketing text messages
- Retention Period:
- We will retain your Contact Information for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records. We may sell or license this information for financial consideration to our former affiliate, a timeshare corporation so that they may contact you about their products or services which may interest you.
- Demographic Information
- Elements:
- Sample data elements include without limitation, age, gender, family status, income or other information
- Legitimate Business Interests / Purposes: We may use this information to:
- Personalize your experience on the Services by presenting products and offers tailored to you.
- Complete and fulfill any purchases or requests for services (for example, if you are travelling as a family with adults and children and have associated accommodations preferences)
- Sources:
- You, when you interact with us, including without limitation as described above (for example, contacting us, promotions or activities)
- Other sources, including without limitation public databases, joint marketing partners, data firms, social media platforms, from your social media connections, your social media account if you choose to connect it to your Website account if applicable, or other third parties.
- Sharing:
- We may share this information with Affiliates, Service Providers, Business Partners and Other Third Parties or as permitted by law as described below under Information Disclosure.
- Retention Period:
- We will retain your Contact Information for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- Government-issued Identification Numbers or Documents
- Elements:
- Sample data elements include without limitation, driver’s license number, social security number, passport number or other similar government-issued identification number and associated documents
- Legitimate Business Interests / Purposes:
- We may use this data to more precisely identify you where needed, such as for fraud prevention or compliance verification; or as required by law, such as for tax or financial processing or other purposes
- Sources:
- You, when you interact with us, including without limitation as described above (for example, contacting us, promotions or activities)
- Other sources, including without limitation public databases, data firms or other third parties
- Sharing:
- We may share this information with Affiliates, Service Providers or as permitted by law as described below under Information Disclosure
- Retention Period:
- We will retain your Government-issued Identification Numbers or Documents for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- Financial Information
- Elements:
- Sample data elements include without limitation, credit or debit card number, bank account number or other financial information
- Legitimate Business Interests / Purposes:
- We may use this data to:
- Enter into or perform a contract with you.
- Allow you to make a payment for a product or service.
- Complete and fulfill any purchases or requests for services
- Sources:
- You, when you interact with us, including without limitation as described above (for example, contacting us, promotions or activities)
- Other sources, including without limitation public databases, data firms or other third parties
- Sharing:
- We may share this information with Affiliates, Service Providers or as permitted by law as described below under Information Disclosure
- Retention Period:
- We will retain your Government-issued Identification Numbers or Documents for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- Unique Personal Identifiers
- Elements:
- Sample data elements include without limitation, online identifiers, Device ID, Internet Protocol (IP) address, account or membership name or identification number or other similar identifiers Legitimate
- Business Interests / Purposes:
- We may use this information to:
- Complete and fulfill loyalty program activities by using a membership number, if applicable
- Analyze usage of the Services (for example, on our Websites, Social Media Pages or Apps)
- Understand how you use our Services across the various devices, and to deliver tailored promotions
- Recognize you across devices you use, and allow us to serve targeted advertisements about goods or services that may interest you when you access and use our Services or other websites, apps or online services
- Facilitate geolocation activities as described below
- Sources:
- You, when you interact with us, including without limitation as described above (for example, using the Services, contacting us, promotions or activities)
- Other sources, including without limitation public databases, joint marketing partners, data firms or other third parties
- Sharing:
- We may share this information with Affiliates, Service Providers, Business Partners or Other Third Parties or as permitted by law as described below under Information Disclosure
- Retention Period:
- We will retain your Unique Personal Identifiers for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- Transaction, Relationship, Personal Preferences, Usage and Location Information
- Elements:
- Sample data elements include without limitation, purchase or usage history (for example, stay or trip information and preferences, such as your preferred location/facilities, dates and number of children included), member or other program status, communications preferences, product or service preferences (such as any special needs or conditions that may impact your stay), Services usage history, location information
- Legitimate Business Interests / Purposes:
- We may use this information to:
- Personalize your experience on the Services by presenting products and offers tailored to you.
- Complete and fulfill any purchases or requests for Services (for example, if a special need, condition or other preference is mentioned that may impact the accommodation arrangements for your stay, or if you have a preferred location/facilities or amenities for your stay).
- Configure your profile to reflect your communications preferences (for example, preferring email over text messages or postal mail, or opting in or out to certain types of messages).
- If you have downloaded our Apps, to provide real-time information or offers to you based on your transaction or stay information and your geolocation.
- Sources:
- You, when you interact with us, including without limitation as described above (for example, using the Services, contacting us, promotions or activities) using a variety of devices, such as a mobile phone with location tracking enabled on the phone or an App
- Other sources, including without limitation public databases, joint marketing partners, data firms or other third parties
- Sharing:
- We may share this information with Affiliates, Service Providers, Business Partners or Other Third Parties or as permitted by law as described below under Information Disclosure
- Retention Period:
- We will retain your Transaction, Relationship, Personal Preferences, Usage and Location Information for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- User Generated Content or Social Media Account Information
- Elements:
- Sample data elements include without limitation, reviews, testimonials, posts or social media account information such as profile data, posts or other information
- Legitimate Business Interests / Purposes:
- We may use this information to:
- Facilitate social sharing functionalities of your social media account(s)
- Allow you to send messages to a friend through the Services, where you are permitted to provide us with their data
- Allow you to participate in sweepstakes, contests and similar promotions, and to administer them
- Send you newsletters or marketing communications we believe may be of interest to you, for our own products and services, and on behalf of our Affiliates or selected third parties
- Allow you to provide a testimonial or story, or submit a review or comment
- Allow you to Like, Follow or otherwise connect with or post to one of our Social Media Pages Sources
- You, when you interact with us, including without limitation as described above (for example, contacting us, promotions or activities)
- Other sources, including without limitation public databases, joint marketing partners, data firms, social media platforms, from your social media connections, your social media account if you choose to connect it to your Website account if applicable, or other third parties
- Sharing:
- We may share this information with Affiliates, Service Providers, Business Partners or Other Third Parties or as permitted by law as described below under Information Disclosure
- Retention Period:
- We will retain your User Generated Content or Social Media Account Information for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- Cookies, Pixels or Beacons
- Elements:
- We may use cookies (small text files this site sends to your computer and stores on your hard drive) to save your preferences. For example, a cookie may save a user’s login details, so that they do not need to login every time. Cookies may be persistent or temporary. Persistent cookies retain preferences for future sessions and stay valid until a set expiry date (unless deleted earlier by the user). Temporary cookies expire at the end of the session, when the browser is closed.
- If you enroll in marketing text messages, cookies may be used to personalize your experience (e.g., send you personalized text messages such as shopping cart reminders).
- Google Analytics: We use Google Analytics to better understand how visitors use our site and for interest based advertising associated with your Google Account and devices you use. This cookie’s site usage information is transmitted to and stored by Google.
- Adobe Marketing Cloud Device Co-op: CTS participates in the Adobe Marketing Cloud Device Co-op to better understand how you use our sites across devices, and to deliver tailored promotions.
- Pixels, Beacons: We or third party ad servers may use invisible pixels or beacons to count users visiting certain pages. This is collected, reported in the aggregate and may be used to improve our marketing programs, and target advertisements at this Website and/or on others.
- Legitimate Business Interests / Purposes:
- We may use this information to:
- Simplify your Website use by saving your preferences to improve your next visit to our Website
- In the U.S., to collect personal information you enter into the Website booking form (even if you do not click to submit) to send you an email if the booking is not completed
- Determine how the Website is used (statistical or marketing purposes)
- Facilitate tailored advertising or monitor patterns of buying specific goods or interest – for example, holidays or hobbies and run advertisements tailored to the user based on online buying habits
- Facilitate interest based advertising associated with your Google Account and devices you use
- Understand how you use our Services across the various devices you use and to deliver tailored promotions
- Sources:
- You, when you interact with us, including without limitation as described above (for example, using the Services)
- Other sources, including without limitation advertising or joint marketing partners, data firms or other third parties
- Sharing:
- We may share this information with Affiliates if linked to our sites, Service Providers or Other Third Parties or as permitted by law as described below under Information Disclosure.
- We do not control or have access to third party advertising partners’ cookies, but allow them to be used to identify purchasing or interest patterns and run ads tailored to the user’s online habits.
- Preferences:
- Please visit our Cookie Consent tool available in the footer of this website for more information about cookies used on this site and for preferences information. Privacy Preference Opt-Out Signals: We respond to opt-out preference signals that are supported by some internet browsers.
- Do Not Track Signals: We do not currently respond to browser ‘do not track’ signals. Third parties, including our service providers, may collect information about your online activities over time and across websites, including when you visit our site. Internet Based
- Advertising: We may use third-party advertising companies to serve ads for goods and services that may interest you when you access and use our Services or others’ services, based on information about online activities across sites. These companies may use a unique cookie on your browser (including using pixel tags) to collect data about your online use and to recognize you across devices.
- Retention Period:
- We will retain information collected about you from Cookies, Pixels, or Beacons for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- Sensitive Personal Information
- Elements:
- Sample data elements include without limitation, personal information that reveals your Social Security or other state identification number, your account log-in, financial account, debit card, or credit card in combination with any required security or access code, password, or credentials allowing access to an account, your geolocation, your racial or ethnic origin, and the contents of your mail, email, or text messages when you communicate with us.
- Legitimate Business Interests / Purposes:
- We may use this data to more precisely identify you where needed, such as for fraud prevention or compliance verification; or as required by law, such as for tax or financial processing or other purposes
- We may use this information, as allowable under applicable law, to provide or enhance our Services; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent or illegal actions directed at us; to ensure the physical safety of natural persons; for short-term transient use; to perform services on behalf of the business such as, but not limited to, providing customer service, verifying customer information, processing payments, or providing other similar services on behalf of the business.
- Limit on the Use of Your Sensitive Personal Information:
- We do not use your Sensitive Personal Information to infer characteristics about you, or for other purposes beyond what is allowable under applicable law.
- Sources:
- You, when you interact with us, including without limitation as described above (for example, contacting us, promotions or activities)
- Other sources, including without limitation public databases, data firms or other third parties
- Sharing:
- We may share this information with Affiliates, Service Providers or as permitted by law as described below under Information Disclosure.
- Retention Period:
- We will retain your Sensitive Personal Information for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- All Categories Data from all categories above, subject to the limitations outlined for Sensitive Personal Information, may also be used for our legitimate business interests / purposes concerning data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing our Services, helping us comply with legal requirements or process, enforcing compliance with our Terms of Use or any product, service or program terms and conditions, helping protect our Services, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. We may share or disclose it to respond to requests from public and government authorities globally; to protect our operations or those of any of our Affiliates or other third parties; to protect our rights, privacy, safety or property, or that of our Affiliates, you or other third parties or to allow us to pursue available remedies or limit damages we, our Affiliates or other third parties may sustain.
- Automated Decision Making and Profiling
- We do not perform automated decision making or profiling with your Personal Information in furtherance of decisions that produce legal or significant effects concerning you under applicable law.
- Non-Personal Information
- We and our third-party service providers may collect usage information when you visit and use the Services. This may include browser type and/or settings, operating system, page(s) served, the time, request source, preceding page view, and similar data. We may analyze this information and use it to help us determine how our Services are used, such as how visitors arrive at the Services, what content is popular or most relevant and what type of visitors are interested in certain content or ads. We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities and improve our services. We may use such data by itself in anonymized form or aggregate it with information obtained from others. We may share such data with our affiliated companies and third parties to achieve these objectives and others, but the aggregate or anonymized data does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may use it in turn to serve ads tailored to your interests), but this will not personally identify you. If we subsequently associate your usage data or re-identify anonymized data with Personal Information you provide in a way that allows us to identify you as an individual or as part of a household under applicable law, we will treat the combined data as Personal Information.
- Information Disclosure.
- We may disclose your Personal Information as described below, where allowable under applicable law.
- Affiliates: To any other entity that is, at the time you disclose your Personal Information, directly or indirectly controlled by, or under common control with us (Affiliates) for the purposes described herein, unless otherwise prohibited by law. Please see our current Annual Report for details about our Affiliates as of its publication date.
- Service Providers: We may disclose your information to our service providers, who perform services for us such as, without limitation: travel services, financial and/or tax services, vacation insurance, website hosting, data analysis, payment or credit card processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, legal advisers, accountants, auditing or other services.
- Business Partners: In accordance with your preferences, we may disclose your Personal Information to business partners to provide you or market to you services of interest to you. For example, we may share it with owners or operators of hotels and resorts, airlines, car rental services, retail stores, credit agencies and other third parties to facilitate reservations, assist you in making arrangements or requested purchases of products or services, or in connection with our loyalty program or one of our partners’ programs (for example, to earn or redeem points). We may co-sponsor promotions, sweepstakes, or events with a third party and share your data when you provide it to facilitate these events. Further, we may share your data with third party providers of ancillary services on-site at hotels or resorts to fulfill your service requests, such as spa, golf, concierge, and dining providers. If you provide additional data to such third parties, it will be subject to their privacy practices.
- Third Parties: Subject to your marketing or other preferences (which may include consent), we may license, sell, or otherwise share your Personal Information with selected third parties for compensation for their own business purposes or our own business purposes. Such third parties may include timeshare organizations formerly affiliated with us or third parties for the purposes of advertising network services. Once shared with such entities, this Personal Information may become subject to the third party’s privacy practices.
- User Generated Content: We may offer facilities for users to submit content such as reviews, message boards or other content. Any information disclosed in these areas becomes public information and you should always be careful when deciding to disclose your Personal Information. We are not responsible for privacy practices of other users including website operators to whom you provide information.
- Merger or Acquisition: We may disclose your Personal Information to a third party who acquires any part of our business or the business of any of our Affiliates, whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of our assets.
- Disclosure Permitted by Law: We may disclose your Personal Information to law enforcement authorities, government or public agencies or officials, regulators, and/or any other person or entity with appropriate legal authority or justification for receipt of your data, if required or permitted to do so by law or legal process, to respond to claims, or to protect our rights, interests, privacy, property or safety, and/or that of our Affiliates, you or other third parties.
- Information Safeguards
- We have implemented reasonable and appropriate physical, technical and administrative steps to help protect your personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of all information you provide to us via the Services.
- Other Important Information
- Other Individuals: If you provide us with information about someone else, you must have their permission to do so for the purposes detailed in this Privacy Notice.
- Website Links: The Services may link to sites we do not operate. We have no control over how they collect your data or liability for their practices, policies and security measures. You should read privacy notices on other sites before providing any data to them.
- Social Media Platforms or Sites: We are not responsible for the privacy policies and/or practices of third parties such social media platform or site providers, RIM or any other app developer or provider, operating system provider, wireless service provider or device manufacturer, and/or any data you disclose to them.
- Minors: We do not knowingly collect or Process Personal Information from individuals under 18 years of age, and no part of our Services is directed to individuals under 18. If we incidentally collect or Process such data, you may contact us to request that we delete it.
- Data Transfers: We are a global company and may transfer your data to selected third parties outside your country where information protection standards may differ (e.g., your information may be stored on servers in other jurisdictions). We will use appropriate safeguards governing the transfer and usage of your Personal Information, such as an adequacy decision by the European Commission, Model Clauses or other applicable mechanism. If you would like further detail on the safeguards we have in place please contact us.
- Retention Period: We will retain your Personal Information for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
- Your Choices and Rights
- Marketing Preferences: You can opt-out from our marketing communications by using the unsubscribe function in our emails; or contacting us as set forth under Contact Us below.
- Withdrawing Consent: You may withdraw any consent you provided to us to Process your Personal Information at any time.
- Access / Right to Know: You may access Personal Information we Process about you. Any request to access or obtain copies of your Personal Information must be made in writing by contacting us as set forth below. We may, in certain jurisdictions, be entitled to charge a nominal fee to cover related administration costs. We may also ask you to verify your identity and to provide further details relating to your request.
- As allowable under applicable law, you have the right to request a copy of specific pieces of personal information or categories of personal information we collected about you in the prior 12 months and to receive it free of charge by email or other electronic portable and usable format. You may also request information about how we have handled your personal information in the prior 12 months, including the following, by category: personal information collected; sources of personal information; purposes for collecting and selling or sharing your personal information; third parties with whom we shared your personal information for a business purpose and corresponding personal information categories shared; categories of third parties with whom we sold or shared your personal information and corresponding personal information categories sold. As allowable under applicable law, you may make Right to Know requests up to twice every 12 months as set forth under Submitting Requests below.
- Right to Opt-Out: In the past 12 months, unless you otherwise opted out, CTS may have sold or shared your Contact Information. As allowable under applicable law, individuals may opt-out of our sale or share of their Personal Information, and exercise this right as described by email: citadelcomm@gmail.com
- Correction: We will take reasonable steps to ensure the accuracy of Personal Information we maintain about you. You are responsible for submitting accurate and complete information to us, and timely updating us if it changes. You may contact us to request that we correct any inaccurate or incomplete data.
- Erasure / Deletion: You may contact us to request we delete your Personal Information. We will assess your request and determine whether we may delete the information if no exemption under law applies, or it is not otherwise subject to a longer legal requirement or as part of information required to be preserved due to a pending claim or litigation.
- Processing Objection: You may contact us to object to any Processing of your Personal Information. We will assess your request and determine whether we have any legal or other justification for continued Processing.
- Data Portability / Transfers: You may request to receive your Personal Information in a format that allows you to send it to another company or to direct us to transfer it directly to another company.
- Right to Non-Discrimination: Applicable law prohibits discrimination against individuals for exercising their rights, such as by denying or providing a different level or quality of goods or services, or charging different prices or imposing penalties on residents who exercise their privacy rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.
- Right to Appeal: Upon receipt of a denial of your individual privacy rights request, you may appeal our decision by contacting us as set forth in Contact Us below.
- EU-U.S. Data Privacy Framework
- We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
- Contact Us
- If you have a complaint or concern about how we Process your Personal Information, we will work to address it. You may also direct your complaint/concern to your applicable data protection authority. If you have any privacy-related questions or concerns, or would like to make any requests in relation to your Personal Information, your Choices, Rights, or its Processing, please email citadelcomm@gmail.com, or by calling 1-760-666-1122, or send a letter to: Citadel Communications Group Corp PO BOX 2088 Indio Ca 92202
- Submitting Requests
- For request in relation to your Personal Information, please provide your email address, first and last name, valid residential address, phone number and Citadel Rewards number (if applicable) that matches information we currently have on file. Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from individuals as required by law.
- Authorized Agent
- To the extent you wish to designate an authorized agent to make any rights requests on your behalf, we require a written and signed authorization letter from you that includes your first and last name, residential address, email and phone number, as well as the full name, address information and relationship to you of the agent you wish to authorize (for example, an attorney, family member or other party). Please send the agent authorization letter to: Citadel Communications Group Corp. PO BOX 2088 Indio Ca 92202 We will review all requests and may require additional details for verification purposes. Please note that we may honor requests made by authorized agents on your behalf, but for fraud prevention purposes, we will only provide responses directly to you, firstly to the email address you currently have on file or to your mailing address currently on file should you not have an email address.
- California Privacy Rights under California’s Shine-the-Light Law
- Under California’s Shine the Light law (Cal. Civ. Code 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the Personal Information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. To make such a request, please call 760-666-1122, send an email to citadelcomm@gmail.com or send a letter to: Citadel Communications Group Corp PO BOX 2088 Indio Ca 92202. The request should attest to the fact that the requester is a California resident, and provide a current California address.
- Privacy Notice Changes
- We may change this Privacy Notice from time to time and the date of last revision is included at the beginning of this notice.
- Should we need to change the purpose or the type or the way we Process information we previously collected about you, we will only do so after we notify you and obtain your express consent to the extent required under applicable law.