In accordance with Art. 12, 13, 14 and 21 of the General Data Protection Regulation (GDPR) and § 13 of the German Tele Media Act (TMG) we inform you below how your personal data are handled when using our website www.clipmyhorse.tv.
The controller in terms of data protection law is:
ClipMyHorse.TV Operations GmbH
Wandersmannstr. 68
65205 Wiesbaden
E-Mail: support@clipmyhorse.tv
Please find below the contact data of the Data Protection Officer of ClipMyHorse.TV Operations GmbH
Wandersmannstr. 68
65205 Wiesbaden
E-Mail: dataprivacy@clipmyhorse.tv
We process your personal data in accordance with the General Data Protection Regulation, the German Federal Data Protection Act and other applicable data protection regulations. “Personal data” are all information relating to an identified or identifiable natural person (“data subject”); a natural person is regarded as being identifiable who, directly or indirectly, is able to be identified in particular by means of assignment to an identification, such as a name, an identification number, location information, an online identification code or to one or more particular features which are an expression of the physical, physiological, genetic, psychic, economic, cultural or social identity of this natural person.
The purpose of the data processing and the corresponding legal principles are given below.
Where data processing takes place between you and any event organisers (e.g. through the compiling of participant lists, data collection relating to the owners of horses), the circumstances of the data processing and any consent given or other legal principles conform in all cases with the data protection regulations of the promoter.
You may visit our website without giving any personal details. If you use our website solely for information purposes, and therefore do not register, log in or otherwise communicate information on your person to us, we collect no personal data with the exception of the data which your browser communicates in order to enable you to carry out the visit to the website and information which is communicated to us as a result of the cookies used.
It is necessary for the purpose of the technical provision of the website that we process certain automatically communicated information from you so that your browser is able to display our website and you are able to use the website. This information is automatically collected each time that our website is called up and stored in our server log files. This information is related to the computer system of the calling computer. The following information is collected during this process:
Additionally, we employ cookies in order to be able to provide our website for your use. Cookies are text files which are stored in the internet browser or by the internet browser on your computer system when calling up a website. A cookie contains a characteristic string which enables a clear identification of the browser when the website is called up once more. We employ these cookies in order to provide our website to you together with its technical functions. A number of functions of our website cannot be provided without the use of cookies and therefore these cookies are absolutely necessary in order for us to be able to operate our website. The following information is stored in the cookies and communicated to us:
We process your personal data for the technical provision of our website on the basis of the following legal principles:
We use the Sentry service (Sentry, 1501 Mariposa St #408, San Francisco, CA 94107, USA) to improve the technical stability of our service by monitoring system stability and detecting code errors. Sentry serves these purposes alone and does not evaluate data for promotional purposes. User data, such as device information or time of failure, is collected anonymously and is not used in a personalized manner, and is deleted afterwards. For more information, please see the Sentry Privacy Policy: https://sentry.io/privacy/.
We employ cookies with your consent for the analysis of the use of our website and/or for the expansion of our reach.
On the first visit to our website an overlay appears in which you may select which cookies we may place on your device for what purposes and what information is gathered for this. You have the option to permit all cookies or to individually choose between the cookies. The consent applies for a period of 90 days. After expiry of this period the overlay appears once more and you are able to make an appropriate choice. If you wish to previously revoke your consent, you may do this by deleting the cookies placed by us. This is fundamentally permitted by every current browser. The details of how you do this may be obtained from the operating instructions of your specific browser. Should you delete the cookies, the overlay will re-appear on your next visit to our website and you can make the appropriate choice once more.
Consent may only be granted by users who are over 16 years of age. If you are younger, we would request you to ask your parent/guardian for permission.
For statistical analysis purposes of the use of our website we employ analysis tools such as Google Analytics, and thus cookies, which enable an analysis of your surfing habits. This works similarly to the viewing figures for television. We are able as a result to improve the quality of our website and our content. We discover how the website is being used and can thus constantly optimise our range of services.
The information obtained as part of the statistical analysis of our website is not combined with the rest of your data collected during your visit to our website.
This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses what are known as "cookies” which are text files stored on your computer which allow an analysis of your use of the website. The information generated by the cookie on your use of this website is generally transmitted to a Google server in the USA and stored there. Where IP-anonymization is activated on this website, your IP address will, however, be previously shortened by Google within member states of the European Union or in other states which are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and abbreviated there. Google will use this information on behalf of the operator of clipmyhorse.tv in order to assess your use of the website, to compile reports on the website activities and to provide additional services associated with the website usage and internet usage for the website operator. The IP address communicated by your browser as part of Google Analytics will not be combined with other Google data.
This website uses Google Analytics with the extension „_anonymizeIp()“. IP addresses are processed as a result in an abbreviated form, a direct personal reference can be thus excluded.
You can prevent the storage of cookies by an appropriate setting of your browser software; however, we would like to point out that you will possibly not be able in this case to make complete use of all functions on this website.
You can prevent the collection of the data generated by a cookie and relating to your use of the website (including your IP address) by Google and the processing of these data by Google by downloading and installing the browser plug-in to be found under the following link: https://tools.google.com/dlpage/gaoptout?hl=en
Alternatively to the browser plug-in you can click on this link in order to prevent the collection in the future by Google Analytics on this website. During this, an opt-out cookie will be placed on your end device. Should you delete your cookies, you must click on this link once more.
More detailed information on conditions of use and data protection by or with Google Analytics may be found under https://www.google.com/analytics/terms/us.html or under https://policies.google.com/?hl=en.
This website uses Hotjar, an analysis software product from Hotjar Ltd. (“Hotjar”) (http://www.hotjar.com, Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta, Europe). With Hotjar it is possible to measure and evaluate user behaviour (clicks, mouse movements, amount of scrolling, etc.) on our website. The information on your visit to our website which is thus generated by a “tracking code” and “cookie” is transmitted to the Hotjar server in Ireland and stored there. The following information is gathered by the tracking code:
Device-dependent data:
The following information is collected which relates to your end device and your browser:
Log data:
The following data are automatically created on Hotjar servers:
Hotjar is used for the evaluation of usage information and for the generation of reports on the usage. The information is also used by Hotjar for the provision of other services which affect the usage of the website and evaluation of the website. For this, Hotjar also makes use of the services provided by third-party companies such as Google Analytics. These third-party companies are able to store information which your browser transmits as part of the visit to the website such as cookies or IP requests. Please compare the explanations given above for more detailed information on how Google Analytics stores data.
The cookies which Hotjar uses are subject to different storage periods depending on the cookie in question; some remain valid for up to 365 days, some remain valid only during the current visit. The duration of the storage in each case may be seen in item 6 below.
You can prevent the collection of the data by Hotjar by clicking on the following link and following the instructions there: Hotjar opt-out.
We process your personal data for the statistical analysis of the use of our website on the basis of the following legal principles:
So that we can distribute our content in the internet we utilise cookies with your consent in order to display the content of our website on other websites or in social networks.
clipmyhorse.tv uses the online advertising service, Google AdSense. Advertising is intended through its use to be presented to you which is designed for your interests. These advertisements can be recognised by the information “Google Ads” in each of the advertisements.
Due to your visit to our website Google receives the information that you have called up our website. For this, Google places a cookie on your computer. The data listed under item 3.2.1 of this data protection declaration are transmitted. Additionally, so-called web beacons are utilised; these are invisible graphic images with whose use your user behaviour on our website can be evaluated. The IP address communicated by your browser as part of Google AdSense will not be combined with other Google data. We neither have any influence on the data collected nor is the full extent of the data collection known to us. These data are transmitted to the USA and analysed there. It is possible that these data are passed on to contractual partners of Google and to authorities. This website has also activated Google AdSense advertisements of third-party providers. The above-mentioned data may be transmitted to these third-party providers (the list may be found under https://developers.google.com/third-party-ads/adx-vendors?visit_id=0-636589427183379249-3187330481&rd=1).
You can prevent the installation of the Google AdSense cookies in various ways
a) through an appropriate setting in your browser software, in particular the suppression of third-party cookies leads to you receiving no advertisements from third-party providers;
b) by deactivating the Google interest-related advertisements via the link http://www.google.com/ads/preferences, whereby this setting is deleted if you delete your cookies;
c) by deactivating the providers’ interest-related advertisement which are part of the
self-regulating campaign “About Ads“, via the link http://www.aboutads.info/choices, whereby
this setting is deleted if you delete your cookies;
d) through a permanent deactivation in your
browsers, Firefox, Internet Explorer or Google Chrome, under the link
https://support.google.com/ads/answer/7395996?hl=en;
e) by not giving us the required consent for the use of Google Adsense. However, we would like to point out that this may
result in you being unable to fully utilise all of our website's functions.
Further information on the purpose and extent of the data collection and its processing and further information on your rights and setting options in this context for the protection of your private sphere may be obtained from: Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA; data protection conditions for advertising: https://policies.google.com/technologies/ads?hl=en and information on the DoubleClick cookies: http://support.google.com/adsense/answer/2839090.
We use the online advertising program “Google AdWords” and, as part of Google AdWords, Conversion Tracking. Google Conversion Tracking is an analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). If you click on an advertisement placed by Google, a cookie for Conversion Tracking will be placed onto your computer. These cookies are valid for 30 days, contain no personal data and are thus not used for personal identification.
If you visit certain pages of our website and the cookie has not yet expired, Google and we can detect that you have clicked on the advertisement and have been forwarded to this page. Every Google AdWords customer receives a different cookie. There is thus no possibility that cookies can be tracked back via the websites of AdWords customers.
The information which is obtained with the aid of the conversion cookie is used to generate conversion statistics for AdWords customers who have decided on Conversion Tracking. From this, customers discover the total number of users who have clicked on their advertisement and who have been forwarded to a page which is marked with a Conversion Tracking tag. However, they receive no information with which users can be personally identified.
We use Google AdWords solely with your consent. You can revoke a consent which you have granted by
We use the Google Tag Manager from Google on our website. The Google Tag Manager is a solution with which the marketer can manage website tags via a user interface. The Google Tag Manager service itself (which implements the tags) is a cookie-free domain and does not collect any personal data. The Google Tag Manager service ensures the triggering of other tags which in turn may collect data under certain circumstances. Google Tag Manager does not access these data. If a deactivation has been undertaken at domain or cookie level, it remains in existence for all tracking tags which are implemented using Google Tag Manager, more detail on this may be found under: https://policies.google.com/privacy?hl=en.
The behaviour of users can be backtracked using Facebook Pixel after they have been forwarded to the website of a provider by clicking on a Facebook advertisement. This behaviour is used to assess the effectiveness of Facebook advertising for statistical and market research purposes and may contribute to the optimisation of future advertising measures. The collected data are anonymous for us and therefore provide us with no indication of the personal identities of the users. However, the data of Facebook are stored and processed so that a connection to the relevant user profile is possible and Facebook is able to use the data for its own advertising purposes in accordance with the Facebook data usage guidelines ( https://www.facebook.com/about/privacy/). They can enable Facebook and its partners to place advertisements within and outside Facebook. Additionally, a cookie may be stored on your computer for these purposes.
A consent for the use of the visitor behaviour pixel may only be declared by users who are over 16 years of age. If you are younger, we would request you to ask your parent/guardian for permission. Please only click here if you wish to revoke your consent: LINK or send an e-mail to support@clipmyhorse.tv
We use no social plug-ins on our website but instead simply place a link to the social media website in question (e.g. www.facebook.com) and our presence there. The data processing on these social media websites is beyond our knowledge and our control and may be obtained from the data protection declaration of the service in question (e.g. in the case of Facebook https://www.facebook.com/help/568137493302217). Before calling up the social media website we exchange no data about you with the relevant social media service.
We process your personal data for the increase of the reach of our website on the basis of the following legal principles:
In addition to the pure use of our website for information purposes, you can also actively use our website in order to come into contact with us or to register either for the free-of-charge and restricted services or for the fee-based and more extensive services and to use them as a registered user. In addition to the processing of your personal data in a use for information purposes as detailed above, we then collect and process further personal data from you which we require for the processing of your registration, for invoicing, for the provision of the registration-based services and, in the case of a contact enquiry, for the response to your enquiry.
In order to be able to process and reply to your enquiries to us, for example, via the contact form or to our e-mail address, we process the personal data communicated by you in connection with this. This includes, in all cases, your first name, last name and your e-mail address in order to send you a response and the remaining information which you pass to us as part of your message.
We process your personal data in order to answer user enquiries on the basis of the following legal principles:
If you wish to subscribe to our newsletter, you must give your e-mail address to which we can send the newsletter. The consent for the newsletter is given in accordance with the so- called “double-opt-in” procedure, i.e. firstly, you select a checkbox on our page which confirms that you wish to receive the newsletter, then you are sent a confirmation e-mail and not until you have clicked on the appropriate link in this confirmation e-mail will you be entered into the circulation list for the newsletter.
You naturally have the option at any time to unsubscribe from the newsletter and to revoke the consent granted by you for the future. For this purpose please click on the appropriate button in the newsletter sent to you, send an e-mail to support@ClipMyHorse.tv or click on the button under www.clipmyhorse.tv/newsletter/unsubscribe.
We process your personal data in order to distribute newsletters on the basis of the following legal principles:
It is possible that we will request you at different places within our website and from time to time to take part on clipmyhorse.tv in a survey (for example, a question of the most popular equestrian discipline). Where appropriate, there also follows a request for participation in a survey on certain actions undertaken by you (for example, a question of the reason for cancellation as a result of the selection of the particular action by you on our website). Both the participation and the provision of any data as part of this survey are voluntary and in particular you are able to make (further) unrestricted use of the fee-based services on clipmyhorse.tv even if you do not participate in the survey.
In addition to the data entered by you voluntarily and explicitly as part of the survey, we only collect the data given above in accordance with 3.2.1, that is to say the following:
In doing this, we link in many cases the data given by you as part of the survey with a user profile previously created by you.
We process your personal data in order to carry out the survey on the basis of the following legal principles:
You may use clipmyhorse.tv free-of-charge and without registration (unrestrictedly) and watch those videos which have been activated for this purpose or register and obtain a fee- based access and make unrestricted use of all available services on clipmyhorse.tv. Through the use of fee-based services after registration you receive additional services and further functions of our website are made available to you. Where you access our website from a mobile end device (e.g. a tablet or smartphone), the free-of-charge use of clipmyhorse.tv is only possible for a limited period, after this the subscription to fee-based access is necessary in order to continue using the service from a mobile end device.
Specifically, we process the following data as part of your registration for the services selected by you and the provision of the services:
Following this, we request you to select a form of payment and to enter the data relevant to this which we process for the purpose of the provision of the fee-based services.
Once you have fully concluded the registration and payment—which is necessary for fee- based services–has been transacted, the services selected by you will be activated and remain in this state until you cancel the services.
We process your personal data for the carrying out of registration-based services on the basis of the following legal principles:
We utilise a payment service provider for the handling of payments. We transmit for the handling of payments
We process your personal data for the carrying out of registration-based services on the basis of the following legal principles:
If you register for a membership account at clipmyhorse.tv, we demand that you answer the question by means of a “checkbox” whether you are of legal age, although we do not demand the entry of a date of birth. When you conclude this necessary step by placing a tick in the appropriate place, we store only the information that you are of legal age, not however your date of birth or your exact age.
We process your personal data for the carrying out of registration-based services on the basis of the following legal principles:
If you make use of the services on clipmyhorse.tv, in particular if you watch videos which have been activated for you, we collect, on the one hand, data as part of the analysis tools described above which cannot be traced back to individual users and, on the other hand, the user profile created by us on you is enriched by the information which results from your use of the services (e.g. what videos have been watched by a user, in what sequence etc.). Cookies are not created in this case.
We process your personal data for the carrying out of registration-based services on the basis of the following legal principles:
We additionally process your personal data in order to meet other statutory obligations which are placed on us in connection with the processing of the registration-based services on clipmyhorse.tv. This includes, in particular, storage periods related to business and trade law or tax law.
We process your personal data for law enforcement purposes and for the compliance with legal regulations on the basis of the following legal principles:
We additionally process your personal data in order to be able to enforce our rights and our legal claims. Similarly, we process your personal data in order to be able to defend ourselves against legal claims. Finally, we process your personal data where it is necessary for protection against or the pursuit of criminal offences.
We process your personal data for law enforcement purposes and for the compliance with legal regulations on the basis of the following legal principles:
Initially, only our employees are given knowledge of your personal data. Additionally, we pass your personal data, where legally permitted or prescribed, to other recipients who provide services for us in connection with our website. During this, we restrict the forwarding of your personal data to what is necessary, in particular in order to be able to provide you with the registration-based services. To an extent, our service providers receive your personal data as a contract processor and, as such, are strictly bound to our instructions for the handling of your personal data. To an extent, the recipients act independently with your data which we transmit to them.
We give below the categories of the recipients of your personal data:
Specifically, we make use of the following IT service providers for the services described below:
For the processing of customer enquiries by telephone we use the ticket system “Zendesk” of Zendesk Inc. (1019 Market St, San Francisco, CA 94103, U.S.A.). When you contact us, the data necessary for responding to the contact enquiry (name, first name, telephone number, e-mail) are collected. The personal data communicated by you as such are solely used for the processing of your contact enquiry. The data protection declaration of Zendesk Inc. may be found under https://www.zendesk.co.uk/company/customers-partners/privacy-policy/.
We use the “push” messaging service, OneSignal, of the service provider, OneSignal (2194 Esperanca Avenue, Santa Clara, CA 95054, U.S.A.). This service is used, for example, to send automatic reminder messages. We do not collect personal data as part of this service. The data protection declaration of OneSignal may be viewed under https://onesignal.com/privacy_policy.
In order to be able to receive push messages you must activate the appropriate button on your device which is generally to be found under “Settings”-> “Push messages” or similarly labelled buttons.
We use the service “Mailjet” of the company Mailjet (13-13bis, rue de l’Aubrac, 75012 Paris, France) for sending our newsletter. Within this service only those data are processed which you have given for the sending of the newsletter (e.g. e-mail, name, first name). The data protection declaration of the service may be found under https://www.mailjet.com/privacy-policy/.
As explained at the appropriate point in this data protection declaration for the newsletter, you may revoke your consent for the receipt of the newsletter at any time without giving a reason. You may carry out the revocation either via the appropriate link in the newsletter itself or by a message to the controller by using the contact data given above.
In order to adjust the range of services provided by clipmyhorse.tv even better to your needs as a customer we carry out surveys, the participation in which is completely voluntary. We use the service “Typeform” of the company Typeform S.L. (Carrer Doctor Trueta, 113-119, Planta 1, 08005 Barcelona, Spain) in order to carry out these surveys. Within this service those personal data are processed which you enter voluntarily as part of the surveys, that is to say generally your e-mail address. The data protection declaration of Typeform S.L. may be found under https://admin.typeform.com/to/dwk6gt.
We use the service “Unbounce” of unbounce Marketing Solutions Inc. (400-401 West Georgia Street, Vancouver BC, Canada V6B 5A1) as a hosting service for individual small pages. When you visit these pages (“landing pages”), your browser communicates with the service provider. During this, your IP address is transmitted to it and cookies are placed (cf. general information on cookies previously in item 3.2.1.1 of this data protection declaration). The data protection declaration of the service provider may be found under https://unbounce.com/privacy/.
As part of the use of Google Analytics we transmit your abbreviated IP address to the USA. The data transfer to any third country is based on the Implementing Decision (EU) 2016/1250 of the EU Commission dated 12 July 2016 in accordance with the guideline 95/46/EG of the European Parliament and of the Council on the adequacy of the level of protection afforded by the EU-US Privacy Shield.
To an extent, we work jointly with service providers which are similarly located outside the EU or the EEA. In these cases it may be that your data are transmitted to the service providers or that these service providers receive access to your data. These service providers work on our behalf. If the service providers are not located in a country with an adequate level of data protection, we have agreed appropriate standard data protection clauses which are approved by the Commission.
We do not otherwise transfer your personal data into countries outside the EU or the EEA or to international organisations.
Information on the standard data protection clauses employed may be requested from our Data Protection Officer.
During the pure use of our website for information purposes we store your personal data on our servers solely for the duration of the visit to our website. Your personal data are deleted without delay once you have left our website. We generally store server log files for a period of 365 days.
Cookies installed by us are placed for a period of 90 days and are then automatically deleted.
The storage periods given below apply to the following cookies as an exception to the storage duration of 90 days:
Additionally, you have the option at any time to personally delete any installed cookies as variously described above.
During an active use of our website we store your personal data initially for the duration of the response to your enquiry or for the duration of our business relationship. This also includes the initiation of a contract (a pre-contractual relationship) and the processing period of a contract.
We additionally then store your personal data until expiry of the statute of limitations period for any possible legal claims arising from the relationship with you in order that they may be entered as evidence where necessary. The statute of limitations period is generally between 12 and 36 months but may also be up to 30 years.
We will delete your personal data from the time of expiry of the statute of limitations period unless a statutory storage obligation exists, for example arising from the German Commercial Code (§§ 238, 257 para. 4 of the Commercial Code [HGB]) or from the German Tax Code (§ 147 para. 3, 4 of the German Tax Code [AO]). These storage obligations may be between two and ten years.
You have the following rights as a data subject in accordance with statutory requirements which you may enforce upon us:
You have the right at any time within the terms of Art. 15 of the GDPR to obtain from us confirmation as to whether or not personal data concerning you are being processed; where that is the case, you are furthermore entitled within the terms of Art. 15 of the GDPR to obtain access to the personal data and certain other information (including the purposes of the processing, the categories of personal data concerned, the recipients, the envisaged period for which the personal data will be stored, your rights, any available information as to the source of the data, the existence of automated decision-making and, where personal data are transferred to a third country, the right to be informed of the appropriate safeguards) and also the right to obtain a copy of your data.
You have the right, in accordance with Art. 16 of the GDPR to demand from us that we rectify any personal data stored about you if this is inapplicable or inaccurate.
You have the right, based on the conditions given in Art. 17 of the GDPR to demand from us that we erase without delay the personal data relating to you. The right to erasure shall not exist in cases where the processing of personal data is required (i) for exercising the right of freedom of expression and information, (ii) for compliance with a legal obligation to which we are subject (e.g. statutory storage obligations) or (iii) for the establishment, exercise or defence of legal claims.
You have the right, based on the conditions given in Art. 18 of the GDPR to demand from us that we restrict the processing of your personal data.
You have the right, based on the conditions given in Art. 20 of the GDPR to demand from us that we transfer to you the personal data relating to you which you have provided to us in a structured, accessible and machine-readable format.
You shall have the right to withdraw the consent which you have granted for the processing of personal data at any time with future effect.
You have the right, based on the conditions given in Art. 21 of the GDPR to object to the processing of your personal data so that we must end the processing of your personal data. The right to object shall be subject to the limits stipulated in Art. 21 of the GDPR. Additionally, our interests may oppose an ending of the processing, meaning that we shall have the right, despite your objection, to process your personal data.
You have the right, based on the conditions given in Art. 77 of the GDPR, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. The right to lodge a complaint shall remain irrespective of any other administrative and judicial remedies.
The regulatory authority with responsibility for us is:
Der Hessische Datenschutzbeauftragte
(Commissioner for Data Protection of Hesse)
Gustav-Stresemann-Ring 1
65189 Wiesbaden, Germany
You are fundamentally not obliged to communicate your personal data to us. However, if you do not do this, we will not be able to provide our website to you, to be able to answer your enquiries to us and will be unable to enter into a contract with you for our registration-based services.
We do not use any systems for automated decision making or profiling (an automated analysis of your personal circumstances).
You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 (1) lit. e (performance of a task carried out in the public interest) or Art. 6 (1) lit. f of the General Data Protection Regulation (GDPR) (legitimate interests pursued by the controller); this includes profiling based on these provisions. We will no longer process the personal data relating to you unless we are able to prove compelling legitimate grounds for the processing which outweigh your interests, rights and freedom or where the processing is necessary for the establishment, exercise or defence of legal claims.
Should the personal data relating to you be processed in order to carry out direct advertising, you shall have the right to file an objection at any time against the processing of the personal data relating to you for the purpose of such advertising. Should you object to the processing for direct advertising purposes, the personal data relating to you shall no longer be processed for these purposes.