Privacy & Cookie Notice

Version 2.0

HOW WE USE YOUR PERSONAL INFORMATION

At Franklin Templeton, we care about your privacy and value the trust you place in us when you share your personal information.

Accordingly, we wanted to  let  you  know  how  we  deal  with the personal information you give us or is given to us by a third party. The aim of this Notice is to explain to you - as Data Subject - what kind of personal information we gather on you, why and how we process it as data controller. Data protection laws changed on 25th of May 2018, with the implementation of the EU GDPR (General Data Protection Regulation). This Notice sets out your rights with regard to this    EU regulation.

From time to time, we may update this Notice, and any new version will be posted on  www.fondulproprietatea.ro  (“Our  Website”). We recommend you regularly review it to ensure that you are always aware of our privacy practices.

Our privacy commitments to you:

  • We will keep your data safe and private
  • We will ensure that you can exercise your rights
  • We will train our employees to properly manage your personal information
  • This Notice describes our practices when using:

    1. the personal information of individuals based in the European Economic Area (EEA) or individuals outside the EEA to whom our group companies offer our services, including but not limited to individuals who have invested in Fondul Proprietatea;
    2. the personal information of members of the Board of Nominees;
    3. the personal information of the customers of, suppliers to, and firms which refer clients to, our group companies in the EEA; and
    4. the personal information of persons based in the EEA who may visit Our Website which are intended for access from within the EEA as indicated by our country menu or on the webpage itself.
  • Data Protection laws say that we are allowed to use personal information (including sharing such information with third parties) where we have a proper reason to do so.

    Accordingly, we must have one or more of the following reasons:

    • To fulfil a contract we have with you;
    • When it is our legal duty;
    • When it is in our legitimate interest*;
    • When you consent to it.

    (*) Our legitimate interest is when we have a business or commercial reason to use the information. However, it must not unfairly go against what is right and best for you (more details are available upon request).

    In general, we may collect the following types of personal information you give us or through our third parties:

    • Identification data, such as name, sex, age/date of birth, place of birth, contact details including address (private and professional), phone number (private and professional), email (private and professional);
    • Profession, job title and position;
    • Signature;
    • Nationality or Civil status;
    • Photograph;
    • Passport information or other national identification number;
    • Tax identification such as National Insurance Number;
    • Personal bank  account  and  financial  information  such  as  an identification number, income and (for professional investors) financial licence;
    • Financial details and bank account details;
    • Financial licence;
    • Criminal Data required by EU AML directive(s);
    • Communications including emails, telephone calls and letters.

    Depending on your Data Subject profile the reasons for processing your personal information may be different. Further information for each Data Subject profile can be found in section 8.

    We also collect personal information about users through Our Website and you can refer to section 9 for more information.

  • Individuals have the following rights, under certain circumstances, in relation to their personal information:

    • Right to access personal information
    • Right to rectify personal information
    • Right to restrict the use of personal information
    • Right to request that personal information is erased
    • Right to object to processing of personal information
    • Right to data portability (in certain specific circumstances)
    • Right to lodge a complaint with a supervisory authority.

    If you - as an individual - wish to exercise these rights, you can download an  Individual  Rights  Request  form  which  is  available at www.franklintempletonglobal.com/rights-request-form.pdf.

    A summary of each right and how you can take steps to exercise it is set out below.

    Where we receive a request to exercise one of these rights, we shall provide information on the action we take on the request without undue delay and in any event within one month of receipt of the request. This may be extended by a further two months in certain circumstances, for example where requests are complex or numerous.

    The information will be provided free of charge, except where requests are manifestly unfounded or excessive, in particular because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request.

    We may ask for additional information to verify your identity before carrying out a request, if we consider this information insufficient  we reserve the right to reject your request.

    Where we do not carry out a request, we shall inform you without delay and within one month of receipt of the request, providing our reasons for not taking the action requested.

    Right to access personal information

    Individuals have the right to confirm the following with us:

    • Whether or not we process personal information about them
    • Certain specified information about the processing

    Individuals also have a right to access the personal information   and be provided with a copy.

    Right to restrict processing of personal information

    Individuals have the right to request that we restrict processing of their personal information where one of the following applies:

    • An individual contests the accuracy of the personal information. The restriction will apply until we have taken steps to verify   the accuracy of the personal information;
    • The processing is unlawful but an individual does not want     the personal information to be erased and requests restriction instead;
    • We no longer require the personal information for the purposes of processing, but it is still required by an individual in connection with a legal claim;
    • An individual has exercised their right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

    Right to object to processing of personal information

    Where personal information is used to target marketing to an individual, they have the right to object to this at any stage.

    An individual also has the right to object to processing of their personal information where the legal basis of the processing is in our legitimate interests. We will have to stop processing until we are able to verify that we have compelling legitimate grounds for processing which override the individual’s interests, rights and freedoms, or alternatively that we need to continue processing for the establishment, exercise or defence of legal claims.

    Right to rectification of personal information

    If an individual believes that the personal information we hold on them is inaccurate, they may request that it be amended. They may also request that incomplete personal information be completed, including by providing a written confirmation.

    Right to request erasure of personal information (“right to be forgotten”)

    An individual may also request the erasure of their personal information in certain circumstances,  including  the  following  (this  is  not  an exhaustive list):

    • The personal information is no longer necessary in relation     to the purposes for which they were collected or otherwise processed;
    • The processing was based on consent which has been withdrawn and there is no other legal basis for processing;
    • The individual has exercised their right to object to the processing and there are no overriding legitimate grounds for the processing to continue.

    There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defence of legal claims.

    If an individual does request erasure of their personal information, this will potentially remove records which we hold for their benefit, such as their presence on a suppression list and they will have to contact us to provide personal information if they wish for us to hold this in future.

    Right to Data Portability

    Where we are relying upon the legal basis either of consent or that the processing is necessary for the performance of a contract to which an individual is a party, and  that  personal  information  is processed by automatic means (e.g. electronically), an individual has the right   to receive all the personal information which they have provided to us in a structured, commonly used and machine-readable format and to transmit this to another controller directly, where this is technically feasible.

    Supervisory Authority

    An individual also has a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where they are habitually resident, where they work or where an alleged infringement of Data Protection laws has taken place.

  • If you are a current or former shareholder and/or GDR holder (“investor”), business contact, subscriber or potential client covered by this Notice, we will keep you up-to-date with details of our products and services  by email using the information that you have supplied. When required by regulation and/or law, we will obtain the proper consent to use your contact details, including your email addresses. In any case, you can change your preferences in regards to marketing communications by contacting us.

    Additionally, we  will  ensure  that  any  third  party  assisting  us in marketing our products and services, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your personal information, and will use it only to provide services we have instructed them to perform.

  • Any complaints and requests to exercise your rights should be addressed to the Data Protection Officer, who will arrange for the responsible joint controller to handle the complaint or request.

    We may also transfer and maintain your personal information covered by this Notice on servers or databases outside the European Economic Area (EEA).

    Our Data Protection Officer can be contacted directly at: Franklin Templeton International Services S.à r.l.

    8A, rue Albert Borschette L-1246 Luxembourg Grand Duchy of Luxembourg

    Email Address: DataProtectionOfficer@franklintempleton.com

    If we need to transfer personal data outside the EEA, we will take steps to make sure your personal information is protected and safeguarded once it leaves the EEA, in particular, we will use the EU Data Protection Model Clauses approved by the European Commission and permitted under Article 46 of the GDPR. If you would like to obtain the details of such safeguards, you can request these from the Data Protection Officer.

    In addition to sharing the information with other group companies and third parties, we may disclose or transfer your personal information to a prospective or actual purchaser or transferee, in the event   that a Franklin Templeton company or its assets is / are merged or sold or a sale or transfer is intended

  • We  will retain your personal information covered by this Notice    for as long as required to perform the purposes for which the data was collected, depending on the legal basis on which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain the personal information. In general terms, this will mean that personal information will be kept for the duration of our relationship and:

    • the period required by tax, company and financial services laws and regulations; and
    • as long as it is necessary for individuals to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under applicable law.

    It may differ from jurisdiction to jurisdiction however, in the majority of cases, this will be during our relationship and then for 10 years after the end of the relationship.

    We retain your personal information if you have invested in Fondul Proprietatea for 10 years after the end of the relationship.

    In certain circumstances, data may need to be retained for a longer period of time, for example, where we are in ongoing correspondence or there is a continuing claim or investigation.

    Our web logs are kept for 60 days to support investigation and reporting of any attempted security breaches on Our Website.

  • We have implemented reasonable technical and organisational measures designed to secure personal information from accidental loss and unauthorised access, use, alteration or disclosure. Our employees are required to follow specific procedures with respect to maintaining the confidentiality of our investors’ personal information. Additionally, we maintain physical, electronic, and procedural safeguards to protect the personal information that we process. This includes performing ongoing evaluations of our systems containing investor information and making changes when appropriate.

    However, as  regards information transmitted via the Internet,  the Internet is an open system and we cannot and do not guarantee or warrant the security of any information that an individual transmits on or through Our Website or that we otherwise maintain, although Our Website uses the secure file transfer protocol where appropriate

  • Investor personal information

    Personal Information we collect about investors in Fondul Proprietatea. Investors include current and former GRD holders and shareholders of Fondul Proprietatea.

    We  collect certain personal information but this is not limited to   the following: direct from investors, through their referring professional adviser, intermediary or bank or other firm.

    We may collect the information through applications or other forms, whether we receive the forms in writing or electronically.

    This personal information includes but is not limited to the following:

    • identification data and data we use to communicate with investors, such as their name, position, current and former addresses (private and professional), telephone number (private and professional), email address, age/date of birth, place of birth, nationality, sex, civil status and a photograph;
    • identification numbers we receive from investors or third parties, such as tax, passport, national or other identification number;
    • personal bank account and financial information such as identification number, income and (for professional investors) financial licence;
    • information about the investors’ transactions (requested through Our Website or otherwise), including investment selection, shareholdings or GDR holdings;
    • investors’ communications or queries to us concerning their investments;
    • recordings of telephone calls;
    • information about criminal convictions if we are authorised to use this information under applicable law;
    • other general information that we may obtain about investors such as demographic information.

    How we use investors’ personal  information

    We  use the personal information we collect about investors for the following purposes:

    • verifying identity, checking transactions for anti-money laundering purposes as required by the European Union’s Fourth Anti-Money Laundering Directive which came into force on 26th June 2017, assisting in the prevention of fraud, terrorist financing, bribery and corruption, and assisting us to not provide services to persons who may be subject to economic or trade sanctions;
    • internal analysis and research to help us improve our services   to investors
    • live testing of our systems on an exceptional basis, to resolve issues internally as soon as possible to enable us to deliver high standards of service;
    • protecting our investors’ holdings and data; and
    • providing investors with more choices or information about products and services which may be of interest to them, with the investor’s consent (see “Marketing Communications” above).

    We justify our  processing  of  investors’  personal  information  on the following legal bases:

    • performing a legal obligation to which we are subject, which may include certain legal or regulatory disclosures and recording services we provide by telephone;
    • performing our legal obligations with investors;
    • performing a task in the public interest, for example where we are carrying out our verification processes in relation to the prevention of fraud, money laundering, terrorist financing, bribery and corruption and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions;
    • pursuing our  legitimate interests and  those of  third  parties. A legitimate interest will apply only where we consider that it is not overridden by an investor’s interests or rights which require protection of their personal information.

    We have determined that our legitimate interests include the following:

    • The improvement and management of our investor services;
    • Our compliance with our regulatory requirements and improving the overall performance of Fondul Proprietatea;
    • The conduct of internal audits for the legitimate purposes of managing our business;
    • Live testing as described above in scenarios where live data  is required, for the legitimate purposes of ensuring the resilience of our systems and continuing high standards of service;
    • Tracking the effectiveness of mailing and targeting personalised marketing to investors for the legitimate purposes of promoting our business and our brand;
    • Obtaining professional (including legal) advice and tracking and reporting on ongoing litigation involving investors to protect our business and our brand.

    If an investor requires further information regarding our legitimate interests as applied to their personal information, they may contact the Data Protection Officer.

    We also process personal information where an investor has provided consent, such as in the case of certain marketing communications. In the event that an investor wishes to withdraw their consent they should contact the Data Protection Officer.

    In certain circumstances, where an investor does not provide personal information which is required (for example, for us to carry out anti- money laundering checks), we will not be able to provide the products and services under our contract with them or may not be able to comply with a legal obligation on us. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the investor.

    Recipients  of  personal  information  about investors

    We will disclose investors’ personal information as follows:

    • to our affiliated Franklin Templeton group companies and entities, in order to process the data for the above mentioned purposes;
    • and to relevant categories of third parties detailed in the Appendix

    Board of Nominees information

    We collect the following information from members of the Board of Nominees:

    • Identification data, such as name, address, phone number, email;
    • Tax identification such as National Insurance Number;
    • Passport information;
    • Financial details such as bank account details;
    • Communications including emails, telephone calls and letters

    How we use information we collect about the Board of Nominees

    We use  the  personal information we  collect  about the  Board of Nominees for the purposes of:

    • Managing and fulfilling our obligations under our contracts with members of the Board of Nominees;
    • Compliance with any contractual, legal or regulatory obligations;
    • Management of our business and other legitimate business purposes and otherwise to enable the fulfilment of the duties of the Board of Nominees.

    We justify our processing of the Board of Nominees members’ personal information on the following legal bases:

    • performing our obligations, or entering into,  a  contract with the Board of Nominees;
    • performing a legal obligation to which we are subject, which may include certain legal or regulatory disclosures;
    • performing a task in the public interest, for example where we are carrying out our verification processes in relation to the prevention of fraud, money laundering, terrorist financing, bribery and corruption and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions;
    • pursuing our legitimate interests and those of third parties.      A legitimate interest will apply only where we consider that it is not overridden by a member of the Board of Nominees’ interests or rights which require protection of their personal information.

    We have determined that our legitimate interests include the following:

    • The improvement and management of our services;
    • Our compliance with our regulatory requirements;
    • Improving the overall performance of Fondul Proprietatea.

    If a member of the Board of Nominees requires further information regarding our legitimate interests as applied to their personal information, they may contact the Data Protection Officer.

    In certain circumstances, where a member of the Board of Nominees does not provide personal information which is required (for example, for us to carry out anti-money laundering checks), we will not be able to perform our obligations under the contract with them or may not be able to comply with a legal obligation. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the member of the Board of Nominees.

    Recipients  of personal  information  about  the Board  of Nominees

    We will disclose personal information of the Board of Nominees as follows:

    • to our affiliated Franklin Templeton group companies and entities, in order to process the data for the above mentioned purposes;
    • and to relevant categories of third parties detailed in the Appendix

    Business contact and potential client information

    We collect personal information from  our  business  contacts  and potential clients, such as representatives of banks or financial firms, professional advisers, suppliers and potential investors including the following:

    • name, job title, profession, and contact details including email;
    • communications with our business contacts and potential clients;
    • financial licence.

    How  we use business  contact  and potential  client  information

    We use personal information from  our  business  contacts  for the following purposes:

    • to communicate about the services we offer and provide to mutual clients or investors whom our business contacts refer to us;
    • to enable business contacts to use our online services;
    • to send marketing communications about our services and products we think may be of interest to our potential clients, our business contacts or our mutual clients or investors whom they refer to us;
    • to invite our business contacts to events;
    • for internal analysis and research to help us improve our services;
    • to communicate about the goods and services we obtain from our suppliers.

    We justify our processing on the following legal bases:

    • performing our obligations under our contracts with other businesses;
    • pursuing our legitimate interests and those of third parties.      A legitimate interest will apply only where we consider that it is not overridden by a business contact’s interests or rights which require protection of their personal information.

    We have determined that our legitimate interests include the following:

    • The improvement and management of our services;
    • The promotion of our business and brand;
    • The improvement of the overall performance of Fondul Proprietatea;
    • Conducting internal audits for the legitimate purposes of managing our business;
    • Tracking the effectiveness of mailing and targeting personalised marketing to business contacts for the legitimate purposes     of promoting our business and our brand;
    • Populating client relationship management systems to facilitate ongoing relationships and creating new opportunities for   the business.

    If a business contact or a potential client requires further information regarding our legitimate interests as applied to their personal information, they may contact the Data Protection Officer.

    In certain circumstances, where a business contact does not provide personal information which is required (for example, in relation to our online services), we will not be able to perform our obligations under the contract with them or may not be able to provide them with products and services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the business contact

    Recipients of business contacts and potential clients  data

    We may disclose business contacts’ or potential clients’ personal information as follows:

    • to our affiliated Franklin Templeton group companies and entities, in order to process the data for the above mentioned purposes;
    • and to relevant categories of third parties detailed in the Appendix
  • A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as “cookies”.

    Some of Our Website pages may contain electronic images known  as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

    How do we use cookies?

    We use cookies and other tracking technologies to customise content and advertising, provide social media features and to see how our visitors move through Our Website. We use this information to make decisions about ways to improve the services we offer you.

    We may engage third party tracking and advertising providers such as those named below to act on our behalf to track and analyse your usage of Our Website through the use of cookies. These third parties collect, and share with us, usage information about visits to Our Website and, sometimes by correlating this information with other information (e.g. your IP address), measure and research the effectiveness of our advertisements, track page usage, help us target our recommendations and advertising, and track use of our recommendations and advertisements.

    Cookies and types of cookies we use

    You can find more information about cookies and the types of cookies we use on our website in the cookie register which can be found at: www.franklintempletonglobal.com/privacy/cookie-register.page.

    Contact our Data Protection Officer if you would like a hard copy of this register, or you have any specific queries regarding the cookies which are deployed on Our Website.

    You can find more information about cookies, behavioural advertising and  online  privacy  at www.allaboutcookies.org  or  www.youronlinechoices.com.

    How do I reject cookies?

    If you do not want to be tracked by Google Analytics cookies you can opt-out by installing a browser plug-in here: https://tools.google.com/dlpage/gaoptout/.

    If you do not want to be tracked by Marketo cookies you can opt-out by clicking the link here: http://www.franklintempletonglobal.com/marketo-optout.page?marketo_opt_ out=true

    If you do not want to receive any cookies from our emails then do not download any images or click any links when you open the email. You may first have to disable automatic downloading of images on your email client.

    At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable cookies, please consult your browser’s ‘Help’ or ‘Support’ section. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of Our Website. Please also note that you cannot disable web beacons (clear gifs, pixels, tags) but these typically work in conjunction with other cookies and so will become largely ineffective if you disable cookies in your browser settings.

    Please consult the following links for information on cookie management and blocking according to your browser:

    Explorer: http://windows.microsoft.com/en-gb/internet-explorer/delete- manage-cookies#ie=ie-11.

    Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable- cookies-website-preferences

    Chrome: https://support.google.com/chrome/answer/95647?hl=en

    Safari:    https://support.apple.com/kb/PH19214?locale=en_GB

    You can also find  more information and  manage cookie storage  at https://www.aboutcookies.org/ and www.youronlinechoices.eu.

     

APPENDIX: THIRD PARTY AND OTHER RECIPIENTS CATEGORIES

 

Investors Business Contacts & Potential Clients Board  of Nominees Website Users
  • Administrators
  • Banking Application Suppliers
  • Cloud-based solution providers
  • Couriers
  • Courts
  • Custodians
  • Document Archive, Storage and Destruction Suppliers
  • Events Management Providers
  • Financial Services providers
  • Investment Managers
  • IT Systems Suppliers
  • Parties representing an investor
  • Print Services Suppliers
  • Professional advisors, i.e. auditors and lawyers
  • Regulators
  • Security or Police Authorities
  • Tax Authorities
  • Administrators
  • Asset Management services
  • Banking Platforms
  • Brokers
  • Business Contact database administrators
  • Cloud-based solution providers
  • Couriers
  • Courts
  • Custodians
  • Document Archive, Storage and Destruction Suppliers
  • Events Management Providers
  • IT Systems Suppliers
  • Print Services Suppliers
  • Professional advisors, i.e. auditors and lawyers
  • Regulators
  • Security or Police Authorities
  • Tax Authorities
  • Administrators
  • Asset Management services
  • Banking Platforms
  • Brokers
  • Cloud-based solution providers
  • Couriers
  • Courts
  • Custodians
  • Dealing platforms
  • Document Archive, Storage and Destruction Suppliers
  • Events Management Providers
  • IT Systems Suppliers
  • Payroll Providers
  • Print Services Suppliers
  • Professional advisors, i.e. auditors and lawyers
  • Regulators
  • Security or Police Authorities
  • Tax Authorities
  • Business Contact database administrators
  • Processing System suppliers
  • Social Media Providers

 

What these Third Parties do

Administrators - Third parties working on FT’s behalf or for the investors.

Asset Management services - Third parties working on FT’s behalf or for the investor providing administration, transfer or asset management services.

Banking Application Suppliers - Third parties providing technical services to process transactions requested by investors, or relating to the administration of their investment, specifically for banking systems.

Banking Platforms - Third parties working on FT’s behalf or for the investor providing administration, transfer or asset management services.

Brokers - Third parties working on FT’s behalf or for the investor.

Business Contact database administrators  -  Third  parties  working on FT’s behalf to service or maintain business contact databases, and systems processing information, such as suppliers systems supporting FT’s Website(s).

Cloud-based solution providers - Third parties who provide technical services to process transactions requested by investors, or relate   to their investment administration, specifically  for  IT  systems. This also includes cloud-based solutions such as Translations services, and Training solutions.

Couriers - Third parties working on FT’s behalf to provide courier services.

Courts - Competent third party authorities where required or requested by law, or where we consider it necessary.

Custodians - Third parties working on FT’s behalf or for the investors.

Document Archive, Storage and Destruction Suppliers - Third parties working on FT’s behalf to provide document archive and storage services.

Events Management Providers - Third parties working on FT’s behalf to plan, organise and facilitate events.

Financial  Services  providers   -  Third  parties  who  have introduced investors to FT. These service  providers  offer  banking,  trust and custodial products and services in order to process the data, including access through our portal.

Investment Managers - Third parties working on FT’s behalf or for the investor.

IT Systems Suppliers  - Third parties who provide technical services  to process transactions requested by investors, or relate to their investment administration, specifically for IT systems.

Parties representing an investor - Third parties representing an investor, e.g. in response to a legal process.

Payroll Providers - Third parties who provide services on FT’s behalf, for the benefit of the Board of Nominees.

Print Services Suppliers - Third parties who provide technical services to process transactions requested by investors, or relate to their investment administration, specifically for print services.

Processing System suppliers - Third parties working on FT’s behalf to service or maintain business contact databases, and systems processing information, such as suppliers systems supporting Our Website.

Professional advisors, i.e. auditors and lawyers - Third parties who provide services to Franklin Templeton group companies or to Fondul Proprietatea, such as its professional advisers (e.g. auditors and lawyers).

Regulators  -  Competent third party authorities where required    or requested by law, or where we consider it necessary.

Security or Police Authorities - Competent third party authorities where required or requested by law, or where we consider it necessary.

Social Media Providers - Social Media providers supporting Franklin Templeton web pages, such as Twitter and LinkedIn.

Tax Authorities  - Competent third party authorities where required  or requested by law, or where we consider it necessary.