Legal & privacy

The new European Regulation for the Protection of Personal Data (GDPR n. 679/2016) is intended to ensure that the processing of your personal data is carried out in compliance with the rights, fundamental freedoms and dignity of persons, with particular reference to privacy and personal identity.
So, is our duty to inform you – as an interested party – about our privacy policy.

1. Data controller

The data controller of the processing of the collected data is SGL Sr with registered office in Barletta, Trani Street n. 342, fiscal code 06599910723, e-mail: [email protected], certified e-mail: [email protected], website owner www.circolo1901.it
He processing of the collected data owned by SGL Srl takes place at the company’s headquarters (legal head office).
If you wish to receive more information on how SGL Srl treats your personal data, please send an e-mail to the company e-mail address [email protected].
To know your rights and be up to date on the legislation on the protection of people and the processing of their personal data, we recommend you to visit the website of the Data Protection Authority on the website www.garanteprivacy.it

2. Data processed

The term “processing of personal data” means their collection, recording, organization, storage, processing, modification, selection, extraction, comparison, recording, use, dissemination, cancellation, distribution, interconnection and whatever else is useful for execution of the service, including the combination of two or more of the aforementioned operations.
Website only deals with common data (first name, last name, e-mail, address, phone number).
The information about you (data) is collected when you access our website, to answer your questions and, with your consent, for marketing purposes (es. newsletter) and analysis of your preferences, when you register to become a member of the newsletter or other forms of commercial communication, when you purchase our products using the platform, when you exchange communications with us via e-mail, when you register in the list of recipients of our shipments, when you partecipate in a promotion or use other functions available on the website.
We keep the data relating to the purchases you make and relating to the payment method used for the commercial transaction. Even if we keep records of commercial transaction you have made via our website, we don’t process financial information such as credit card numbers; in fact we use a payment service provider to complete the purchases you have made via our website. In this sense, you must read privacy policy conditions of this payment service provider.

3. Type of data processed

Navigation data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data. The transmission of these data is implicit in the use of internet communication protocols.
This informations isn’t collected to be associated with identified interested parties.
This data is used fo the only purpose of obtaining anonymous statistical informations on the use of the website and to check that the website functions correctly.
Data provided voluntarily by the user
The optional, explicit and voluntary sending of electronic e-mail to the e mail addresses indicated on this webite causes the subsequent acquisition of the sender’s address, necessary to respond to requests, and any other personal data included in the text of the sent communication.

4. For which purposes S.G.L. s.r.l. collects and processes personal data of the user/customer and legal basis for the collection and processing of personal data

S.G.L. s.r.l. collects and processes the data of its users/customers for the following purposes:
Contractual purpose: To display the web page and use the services within the Website https://www.circolo1901.it. In particular, to proceed to the pre-contractual phase and to the execution of the contract of sale of products for sale on the Website, as well as to undertake activities related to the contract itself. This happens when the user/customer purchases a product or takes part in promotions.
Marketing purposes: for example, sending – by automated ways of contact (e-mail, sms, etc.) – advertising material, promotional and commercial communications of products similar to those already purchased on the Website.
Profiled marketing purposes: analysis of preferences, habits, behaviours, interests of the user/customer inferred, for example, from clicks on products/sections of the Website, in order to send them personalized commercial communications, targeted promotional actions, business intelligence. The processing of the user/customer’s personal data for profiling purposes will be carried out, in case of consent, with processing tools that, after crossing, will create a commercial and behavioral profile on the web. These data processing tools relate the information collected while browsing the Website through the use of profiling cookies accepted by the user/customer with the data collected through his subscription to the newsletter or the creation of the account. Such data/information will be associated with any and all further data/information already in possession of S.G.L. s.r.l. as a result of previous purchases on the Website.
Purposes of compliance/legal obligations: to comply with obligations provided for by regulations and applicable national and supranational regulations.
Purpose of sending newsletters: if requested by the customer with the registration to this service.
Purpose of exercising rights: if necessary, to verify, exercise or defend the rights of S.G.L. s.r.l. in court.
Purpose of operation of the Website: the computer systems and software procedures required for the operation of the Website acquire, during their normal service, some personal data in the use of Internet communication protocols.
Customer Service purposes: if requested by the user/customer through the chat present on the Website or through e-mail, to provide assistance, product information and/or support with the purchase and/or payment procedure.
Purpose of preventing abuses / fraud: exclusively to prevent and/or detect any fraudulent activity or abuse in the use of the Website and therefore allows S.G.L. s.r.l. to protect itself in court.
These are the legal bases that S.G.L. s.r.l. uses, to process the user/customer data, according to the purposes indicated in the previous paragraph:
-Providing the Service: the processing of data for this purpose is necessary to provide the services and, therefore, for the execution of the contract. It is not mandatory to provide S.G.L. s.r.l. with the data for this purpose, but otherwise it will not be possible to offer any Service.
-Marketing: the processing of data for this purpose is based on the legitimate interest of S.G.L. s.r.l. to send marketing communications via email regarding products and services similar to those that the user/customer has purchased in the past or on the Website. You can stop receiving these communications, without any consequence (besides the fact that you will no longer receive further communications of this kind) by using the unsubscribe button at the bottom of each of the e-mails received or by contacting S.G.L. s.r.l.
-Profiled marketing: the processing of data for this purpose is based on the consent. It is not compulsory to provide S.G.L. s.r.l. with it for this purpose and it can be withdrawn any time without any consequence (except the impossibility to benefit from the personalization of the commercial offers you receive). The consent can be revoked any time by the user/customer by following the instructions reported in the Cookie Policy.
-Compliance/legal obligations: the processing of data for this purpose is necessary for S.G.L. s.r.l. in order to fulfill any legal obligations. When you provide personal data to S.G.L. s.r.l., they must be processed according to the applicable law, which could imply their storage and communication to the Authorities for accounting, fiscal or other obligations.
Newsletter: the processing of data for this purpose arises from a specific request by entering the e-mail address (consent) and can be withdrawn at any time through the unsubscribe button in the newsletter section of your account, at the bottom of each e-mail received or by contactingS.G.L. s.r.l. directly.
Functioning of the Website: the processing of data for this purpose is based on the legitimate interest of SGL s.r.l. in the correct operation of the Website.
Costumer service: the processing of data for this purpose is based on the legitimate interest of SGL s.r.l. to provide assistance, product information and/or support in the purchase and/or payment procedure.
Abuses/Fraud: the data treatment for this purpose is based on the legitimate interest of SGL s.r.l. to prevent and/or detect possible fraudulent activities or abuses in the use of the Website and therefore allow it to protect itself in court.

5. Geolocalisation service – Legal purpose

Through our website we treat the data relating to your position to allow you to identify the “Circolo 1901” stores closest to your position.
In order to allow the use of the “localize me” service, our website will be able to access in real time the data relating to your location (geolocation data) without accessing other personal data stored on your device.
The detection of your geographical position requires your consent which will be necessary to activate the “localize me” service of the website circolo1901.it.
The data collected will be delated after browsing our website.
The legal basis for the processing of your data is your possible consent pursuant to article 6, paragraph 1, letter A) of GDPR.
The data relating to your geographical position, possibly detected in the case of use of the ““localize me” service will not be disclosed or communicated to third parties.
No employee or representative of S.G.L. Srl will be able to access this data either in real time or later.

6. Categories of recipients of personal data

Your personal data may be disclosed in order to be able to carry out the necessary activities related to the contract and exclusively as part of this purpose:
-to legal, publc and private subjects, for example with a non-exhaustive list, legal or commercial offices, Chambers of Commerce, authority, etc..;
-to those responsible for the treatment (data controllers) governed by art. 28 of the Regualtion:
people, companies, associations, professional offices that provide assistance and consultancy services to the holder in accounting, administrative, legal, fax, financial and credit recovery in connection with the provision of services, as well as logistics companies;
-to the subjects with whom it is necessary to interact for the provision of services (for example hosting providers);
-to the subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks);
-to post offices, freight forwarders and couriers where necessary to send to the interested user documentation or other materials;
-to the subjects, entities or authorities, autonomous data controllers who are obliged to communicate your personal data according to the provisions of the law or orders of the authorities;
-to banking institutions for the management of receipts and payments.
The data are not subject to disclosure.
In compliance with the general provision of the Guarantor of 28.11.2008, the data may be communicated to the System Administrator.

7. Transmission of data outside the European Union

To allow us to properly manage your purchases and related services, your personal data may be transferred to countries outside the European Union.
The transfer is authorized and strictly regulated by article 45, paragraph 1 of the Regulation.
Therefore no further consent is needed.
Data will never be transferred to third countries that do not comply with the conditions set by article 45 and folllowing of the EU Regulation.
By simple request to be sent via e-mail to the mail address [email protected] you can receive more information on the transfer of your personal data and on the guarantees provided for their protection as well as on the means to obtain a copy of such data or the place where they were made available.

8. Use of cookies

In compliance with the privacy policy guidelines adopted, we informs visitors that the website uses automatic data collection systems not directly released by the user, such as cookies.
To obtain more information on the use of cookies by this website, we invite you to consult the related link.

9. Recall links of third-party websites

Data controller is not responsible for the content of third party websites to which refer links on the site circolo1901.it
Therefore, the interested party is advised to read the sections of the Privacy Notice and Cookies Notice on these third-party websites.

10. Rights of the interested party

The subjects to whom the personal data refer have the right, at any time, to obtain confirmation of the existence of the same data and to know its content and origin, verify its accuracy or request the integration, updating or correction of personal data (articles 15 to 23 and 34 EU REGULATION 678/2016, see ANNEX A below). Pursuant to the same articles, you also have the right to request cancellation (right to be forgotten), the right to data portability, the transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose any case, for legitimate reasons, to their treatment.
Requests should be forwarded to the Data Controller by writing to the following email address: [email protected]
In brief, the interested party has the right:
– to ask the Data Controller to access their personal data and to correct or cancel them or limit the processing that concerns them or to oppose their treatment in addition to the right to data portability ( articles 15, 16, 17 18 20 EU REGULATION 679/2016);
– to withdraw the consent at any time if the processing is based on the article 6, paragraph 1, letter a) or on the article 9, paragraph 2, letter a), without prejudice to the lawfulness of the processing based on the consent given before the revocation;
-to submit a complaint to a supervisory authority;
– to become aware by the Data Controller (that must intervene in this sense) of a violation of personal data likely to present a hight risk for the rights and freedoms of legal persons/entity (article 34 EU REGULATION 679/2016).

11. Data retention period

The Personal Data processed for the purpose of providing the Services will be stored by S.G.L. s.r.l. for the time strictly necessary for the above mentioned purpose (e.g. to send the purchased product). In any case, since such data are processed to provide the services to the user/customer, S.G.L. s.r.l. may keep them for a longer period, in particular for what may be necessary to protect its interests from possible claims related to the services (10 years).
The data processed for Marketing purposes will be kept by S.G.L. s.r.l. until the user opposes such data treatment through the link at the bottom of each e-mail received.
The data processed for Profiled Marketing purposes will be stored until the moment in which the user/customer withdraws the consent. Once the consent has been revoked, S.G.L. s.r.l. will no longer use the data for this purpose, but it will still be able to keep them, in particular for what may be necessary to protect its interests, for example following complaints based on such data processing.
The data processed for the purposes of Compliance/Legal obligations will be stored for the period provided by specific legal obligations or applicable legislation.
The data processed in order to prevent abuse / frauds will be stored for the time strictly necessary for the above mentioned purpose and therefore until the moment in which S.G.L. s.r.l. will be required to keep them to protect itself in court and/or to communicate it to the competent Authorities.

12. Security measures

The Data Controller, taking into account the implementation costs as well as the nature, the scope of application, the context and the purposes of the processing both when determinating the means of treatment and the other of the treatment itself (risk analysis), has implemented adeguate technical and organizational measures, with the purpose of protecting the data. Those measures are intended to effectively implement the data protection principles and the purpose of integrating the necessary guarantees into the processing in order to meet the requirements of the EU REGULATION 679/2016 and protecting the rights of the interested party.
In this perspective, personal data will be processed for the purposes connected and/or instrumental to the professional activities of the data controller, observing the purposes to be pursued above explained.
The data will be processed using methods and instruments suitable to guarantee security (Article 24, 25 and 32 of the EU Reg. 679/2016) and will be carried out by electronic or automated systems (network not accessible to the public) and by not automated systems (paper archives), to which all appropriate technical and organizational measures will be applied to ensure a level of security appropriate to the risk, so as to ensure on a permanent basis their confidentiality, integrity, availability and resilience of the processing systems and services.
The processing of the personal data provided is necessary (and therefore lawful) for the execution of the written assignment existing between the parties. The signing of this Privacy Policy applies as consent to the processing of the data indicated above (article 7 EU REGULATION 679/2016).

13. Applicable law

This Privacy Policy is governed by the new European Regulation for the Protection of Personal Data (GDPR) 2016/679 and by the rules that remain in force of the Code regarding the protection of personal data (Order of the executive 30 June 2003 No. 196) governing the processing of personal data carried out by anyone who is resident or is based in Italy.

14. Changes and updates Privacy Policy

The Data Controller may modify or simply update, in whole or in part, the Privacy Policy, also in consideration of the changes of laws or regulations that govern this matter and protect your rights.
Changes and updates to the Privacy section will be notified to users by publication on the home page as soon as they are adopted; they will be binding as soon as they are published on the website. Therefore we ask you to regularly access to this section to check the publication of the most recent and updated Privacy section.

15. Consent given by the legally responsible parent

Pursuant to article 8 of the European Regulation 2016/679, in cases where the person concerned is younger than fourteen (14), the consent of the legally responsible parent is required for the processing of the personal data of the aforementioned minor.

ATTACHMENT A:
RIGHT OF ACCESS BY THE DATA SUBJECT
ESTRATTO REG. UE 679/2016
Article 15
Right of access by the data subject
1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
(f) the right to lodge a complaint with a supervisory authority;
(g) where the personal data are not collected from the data subject, any available information as to their source;
(h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
Article 16
Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Article 17
Right to erasure (‘right to be forgotten’)
1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defence of legal claims.
Article 18
Right to restriction of processing
1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
(d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
Article 19
Notification obligation regarding rectification or erasure of personal data or restriction of processing
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
Article 20
Right to data portability
1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
(a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
(b) the processing is carried out by automated means.
2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
Article 21
Right to object
1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Article 22
Automated individual decision-making, including profiling
1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
2. Paragraph 1 shall not apply if the decision:
(a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;
(b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
(c) is based on the data subject’s explicit consent.
3. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
4. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.
Article 23
Restrictions
1. Union or Member State law to which the data controller or processor is subject may restrict by way of a legislative measure the scope of the obligations and rights provided for in Articles 12 to 22 and Article 34, as well as Article 5 in so far as its provisions correspond to the rights and obligations provided for in Articles 12 to 22, when such a restriction respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society to safeguard:
(a) national security;
(b) defence;
(c) public security;
(d) the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
(e) other important objectives of general public interest of the Union or of a Member State, in particular an important economic or financial interest of the Union or of a Member State, including monetary, budgetary and taxation a matters, public health and social security;
(f) the protection of judicial independence and judicial proceedings;
(g) the prevention, investigation, detection and prosecution of breaches of ethics for regulated professions;
(h) a monitoring, inspection or regulatory function connected, even occasionally, to the exercise of official authority in the cases referred to in points (a) to (e) and (g);
(i) the protection of the data subject or the rights and freedoms of others;
(j) the enforcement of civil law claims.
2. In particular, any legislative measure referred to in paragraph 1 shall contain specific provisions at least, where relevant, as to:
(a) the purposes of the processing or categories of processing;
(b) the categories of personal data;
(c) the scope of the restrictions introduced;
(d) the safeguards to prevent abuse or unlawful access or transfer;
(e) the specification of the controller or categories of controllers;
(f) the storage periods and the applicable safeguards taking into account the nature, scope and purposes of the processing or categories of processing;
(g) the risks to the rights and freedoms of data subjects; and
(h) the right of data subjects to be informed about the restriction, unless that may be prejudicial to the purpose of the restriction.
Article 34
Communication of a personal data breach to the data subject
1. When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall communicate the personal data breach to the data subject without undue delay.
2. The communication to the data subject referred to in paragraph 1 of this Article shall describe in clear and plain language the nature of the personal data breach and contain at least the information and measures referred to in points (b), (c) and (d) of Article 33(3).
3. The communication to the data subject referred to in paragraph 1 shall not be required if any of the following conditions are met:
(a) the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
(b) the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph 1 is no longer likely to materialise;
(c) it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.
4. If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the personal data breach resulting in a high risk, may require it to do so or may decide that any of the conditions referred to in paragraph 3 are met.