Privacy policy

Last updated: January, 2024

GRESSO, LLC (together with our affiliates and subsidiaries, "GRESSO", "we", "us,", or "our”) created this Privacy Policy to inform you about how we process the information we collect from and about you when you visit our website located at www.gresso.com (the "Website"), including when you use the online chat function, access our mobile applications ("App"), purchase any of our Products ("Products"), or otherwise contact or interact with us in any other way offline ("Offline Services"). The Website, App, Chat and Offline Services are collectively referred to as the "Services." This Privacy Policy also explains how GRESSO may use and share your personal information, as well as your ability to control certain uses of it.

By using the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy, and agree to the Terms and Conditions which are incorporated by reference. If you do not agree, please do not further access or use the Services.

What personal information we collect

The following are the categories of personal information we collect and the period of time we retain personal information for each category:

Category of personal information we collect	How long we retain it
Identifiers, such as your name, alias, phone number, mailing and email addresses, IP address, account name or other similar identifiers, account credentials, address book entries, birth date, and ZIP code.	For as long as you remain a customer plus as long as necessary for legal reasons or to protect our interests.
Commercial information, including purchase and related transaction information, payment method(s), items purchased, items altered or custom made, order status, information about Wish List items, items in your online shopping bag or those saved for future purchase, items in your registry, product review information.	For as long as you remain a customer plus as long as necessary for legal reasons or to protect our interests.
Information you share during communications and interactions with us, which may include the content of email messages, chat sessions, text messages, and phone calls.	For as long as we need the information to provide service to you.
Demographic information, which may include age or birth date, gender, ZIP code, and other information about you.	For as long as you remain a GRESSO customer plus as long as necessary for legal reasons or to protect our interests.
Location or geolocation information, including device location information when using our App (if your device settings permit us to collect this information).	One year or longer as necessary for legal reasons or to protect our interests.
Internet or other electronic network activity information, including internet browsing information, unique device identifiers, cookie identifiers, device and browser settings and information, interaction with our Website, App or an advertisement, and Internet service provider information. We may also collect information about when and how you access and use our Website and App, such as the date and time of your visit or use, the websites visited before and after visiting our Website, how you navigate and what you search for on the Website or App, the pages visited on the Website, items you view, and the items you purchase.	For as long as you remain a customer plus as long as necessary for legal reasons or to protect our interests.
Inferences about or derived from any of the information above that may relate to your preferences or other matters.	For as long as you remain a customer plus as long as necessary for legal reasons or to protect our interests.

Our Website is for individuals who are at least 18 years old

GRESSO does not knowingly request or collect personal information from anyone younger than 18 years old without prior consent from a parent or legal guardian. Please contact privacy@gresso.com if you believe your child under age 18 has submitted personal information to GRESSO without prior parental or legal guardian consent so that we can take steps to delete the information.

How we collect personal information

We collect personal information in various ways, both directly and indirectly. For example, when you email our customer care team, fill out a form on our Website, place an order through the Website or App, we collect your information directly from you. We may also collect your personal information indirectly through automated means, for example, when you interact with our Website or use our App, we may use technologies to collect information about how you use the Website or App. We may also receive information about you from third parties including from our affiliates and subsidiaries, social media platforms or from our advertising partners.

We collect personal information when you provide it

We may collect personal information directly from you or your device as follows:

When you register for a GRESSO account, it is necessary for you to provide personal information that includes your name and email address. You may choose to provide us with additional personal information, including billing, mailing, and shipping addresses, phone number. If you make purchases through the Website or App, you will also create a username and password, information that on subsequent visits helps us confirm your identity and makes it easier for you to make purchases on our Website and App.
When you shop with us, either through the Website or App, we store your browsing history, what you searched for, including what you have saved for later, what you bought (if you make a purchase).
When you interact with GRESSO, including with a member of our sales team, contact our Customer Care team, participate in a contest or sweepstakes, respond to a survey, engage in a promotional activity, register to attend an event or appointment.
When you sign up to receive emails, including marketing communications.

We collect personal information from third-party sources

To better understand your preferences, operate our business, and provide you with products and services we believe you will love, we may receive your personal information from the following third parties:

Online social networks if you follow GRESSO or any of our brands on social media sites, for example, Facebook, Instagram, LinkedIn, TikTok or Pinterest. We may collect personal information when you communicate with us within the social media sites or use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our Website (e.g., to log into an account, or to share inspiration, finds, purchases, and other content with your friends and followers on social media) or when you click "Share This" or "Like" buttons. We think it is important to point out that if you make a post on a social media site, such as on Facebook, Instagram, or Pinterest, or identify us in your social media feed by tagging us using a hashtag (#) or "at" (@), your personal information may be publicly available and is subject to the privacy policies of those social media sites. We recommend you review the privacy policies of any third-party sites you visit to understand the data collection and practices of those third parties.
Third-party service providers that support our business, including companies that help with our marketing efforts, analytics providers, advertising networks and cooperatives, third parties that share information with us about the different devices you use online, reviews you have posted on third-party sites about products we offer, and other third parties that we collaborate or work with.

We collect personal information using automated technologies

Personal information is also collected through automated technologies and shared with us when you visit our Website, use our App, open an email, or click on one of our advertisements.

We automatically create website and mobile application log files, which are created when you access our Website and/or App. In addition, automated data collection technologies - such as cookies, beacons, tags, software development kits (SDK), and scripts - are used by us to analyze trends, administer the Website and App, and track users' movements around the Website and App. We, and our third-party service providers, also use these technologies to gather demographic information about our user base as individuals and in the aggregate.

A "cookie" is a small text file that is stored on an individual's computer and downloaded to the computer or mobile device when they visit a website. Cookies then send information back to the originating website on each subsequent visit, or to another website that recognizes that same cookie. We use the following types of cookies:

Essential Cookies are required to make our Website and App function properly and cannot be turned off in our systems. If you block these cookies, portions of our Website or App may not function properly.
Performance and Functional Cookies allow us to count visits and sources of traffic on our Website and App so we can measure and improve performance and functionality. They help us know which pages of our Website are most and least popular, which features of the App are used most, and how visitors move around the Website and App.
Targeted Advertising Cookies may be set through our Website by our advertising partners. They may be used by advertising companies to build a profile of your interests and show you relevant advertisements on other websites. Please see Targeted Advertising in the Your options and legal disclosures section for information about how you can opt out of these cookies.
Social Media Cookies allow you to share information using social media sharing buttons on social networks like Facebook, LinkedIn, Pinterest, Instagram, or Twitter. This information may then be used by the social media network to deliver targeted advertising to you.

We may combine information collected automatically (as described above) from your interactions with our Services and your activity on third-party sites with other data (including personal information).

If you wish to opt out of allowing certain cookies, you may do so by changing your browser settings so that cookies from our Website and App cannot be set (see Targeted Advertising in the Your options and legal disclosures section below for your options). Please note that if you delete, block, or otherwise restrict cookies, or use a different computer or Internet browser, you will need to renew your cookie management choices.

How we use personal information

We use personal information, including information that we combine from your interactions with our Website and App, your device, or third parties, to conduct our business and to provide you with the best possible products, services, and experiences. We know your personal information is important to you, so we want to be transparent about the purposes for which we use that information. Here the ways we use your personal information:

To provide you access to the Website and App, including to service your account(s) and maintain its security.
To provide you with products and services, including to fulfill your orders, process your payments, and provide you with products and services that we think you will like.
To respond to or notify you, including when you place an order, reach out to us with a comment, request or question, enter a contest or sweepstakes, complete a survey, texting or calling you about products and services you have asked about or purchased, and to let you know when an order is ready, to notify you of updates to the App or, when you elect, to let you know an item is back in stock.
To personalize your experiences with us, including to remember your interests and preferences, customize the products and services we share with you, facilitate interactions with our stylists and team members, track and categorize your activity and interests on the Website and App, including identifying and linking the different devices you use, and to enrich your experience on the Website and the App.
For marketing and advertising, including to send you marketing and advertising communications tailored to your interests and more general in nature.
For analytics, including to understand how you use our Website and App, how you shop with us, the methods, and devices you use to access our Website and App, and to make improvements to our Website and App.
For business purposes, including to operate and improve our business and business activities, for research, to maintain our programs, accounts, and records; to understand your satisfaction with our products and services including the Website and App; to detect and prevent fraud or misuse of our services; and for any other business purpose permitted by law.
For legal and safety purposes, including to defend or protect us, you, our customers, or third parties, from harm or in legal proceedings; maintain the security of our customers, employees, and property; respond to court orders, lawsuits, subpoenas, and government requests; address legal and regulatory compliance; and notify you of product recalls or safety issues.

Below is a summary of the categories of personal information we collect and the purpose for which we use this information.

Category of personal information we collect	Purpose
Identifiers, such as your name, alias, phone number, mailing and email addresses, IP address, account name or other similar identifiers, account credentials, address book entries, birth date, and ZIP code.	To provide access to the Website and App; To provide products and services; To respond to or notify you; To personalize your experiences with us; For marketing and advertising; To offer you personalized content; For analytics; For business purposes; and For legal and safety purposes.
Commercial information, including purchase and related transaction information, items purchased, items altered or custom made, order status, information about Wish List items, items in your online shopping bag or those saved for future purchase, items in your registry, product review information.	To provide access to the Website and App; To provide products and services; To respond to or notify you; To personalize your experiences with us; For marketing and advertising; To offer you personalized content; For analytics; For business purposes; and For legal and safety purposes.
Information you share during communications and interactions with us, which may include the content of email messages, chat sessions, text messages, and phone calls.	To respond to or notify you; For analytics; For business purposes; and For legal and safety purposes.
Demographic information, which may include age or birth date, gender, ZIP code and other information about you.	To provide products and services; To personalize your experiences with us; For marketing and advertising; To offer you personalized content; For analytics; For business purposes; and For legal and safety purposes.
Location or geolocation information, including device location information (greater than within 2,000 feet of your location) when using our App (if your device settings permit us to collect this information).	To provide access to the Website and App; To provide products and services; To personalize your experiences with us; For marketing and advertising; To offer you personalized content; For analytics; For business purposes; and For legal and safety purposes.
Internet or other electronic network activity information, including internet browsing information, unique device identifiers, cookie identifiers, device and browser settings and information, interaction with our Website, App or an advertisement, and Internet service provider information. We may also collect information about when and how you access and use our Website and App, such as the date and time of your visit or use, the websites visited before and after visiting our Website, how you navigate and what you search for on the Website or App, the pages visited on the Website, items you view, and the items you purchase.	To provide access to the Website and App; To provide products and services; To respond to or notify you; To personalize your experiences with us; For marketing and advertising; To offer you personalized content; For analytics; For business purposes; and For legal and safety purposes.
Inferences about or derived from any of the information above that may relate to your preferences or other matters.	To personalize your experiences with us; For marketing and advertising; To offer you personalized content; For analytics; For business purposes; and For legal and safety purposes.

When we disclose personal information

We may disclose personal information we collect from you to third parties, including service providers, business partners, individuals and other third parties, for various reasons. We may disclose personal information to:

Categories of those we share information with	Categories of personal information we may share
The GRESSO family of brands and companies including our affiliates, parents, and subsidiaries.	All categories of information referred to in the What personal information we collect section.
Individuals and other companies with whom you ask us to share.	Including where you ask us to share your Wish List or where you request we accept payment from a third-party payor or financing company.
Marketing and advertising companies and service providers.	Identifiers, commercial information, contact preference information, demographic information, location or geolocation information, Internet or other electronic network activity information, and inferences.
Third parties and service providers, delivering products and services directly to you.	Identifiers and commercial information.
Service providers helping us better understand our interactions and transactions with you.	Identifiers, commercial information, contact preference information, demographic information, location or geolocation information, Internet or other electronic network activity information and inferences.
Service providers addressing online and offline fraud and security.	Identifiers, commercial information, demographic information, location or geolocation information and Internet or other electronic network activity information.
Service providers helping us maintain customer accounts and provide customer service.	Identifiers, commercial information, contact preference information, demographic information, and location or geolocation information.
Service providers supporting internal research.	Identifiers, commercial information, product preference information, demographic information, location or geolocation information, device and Internet browsing information and inferences.
Service providers that verify service quality.	Identifiers, commercial information, information you share during communications and interactions with us, and Internet or other electronic network activity information.
Service providers that support our business as allowed by law.	All categories of information referred to in the What personal information we collect section.
Financial services providers, including collection agencies, credit bureaus, our banking partner and payment card association members. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, defaults, or debt collection.	All categories of information referred to in the What personal information we collect section depending on the circumstance and provider.
Social media platforms and networks such as Facebook, Twitter, Pinterest, and Instagram, when you choose to use certain features or tools available on our Website or App that enable you to connect to a social media account or to share inspiration, finds, purchases and other content on social media.	Contact information, demographic information, location or geolocation information and device information.
Parties to business transactions including those involved in strategic business transactions like mergers, acquisitions, joint ventures, asset sales, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of strategic business transactions where personal information may be shared, sold, or transferred, and subsequently used by a third party.	All categories of information referred to in the What personal information we collect section.
Other third parties not otherwise described above, including service providers who assist us in preventing harm or fraud to us, you, our customers or other third parties; law enforcement, government entities, courts, or other third parties as required or allowed by applicable law, such as for the legal and safety purposes described under the How we use information section. We also may share personal information with third parties upon your request or with your approval, though we may not be able to accommodate all requests.	All categories of information referred to in the What personal information we collect section depending on the circumstance and party.

We may also share aggregated or de-identified information with our affiliates, agents, service providers, business partners or other third parties for their marketing or analytics uses or for any other lawful purpose. This type of information cannot be used to identify you personally.

Note that it is our policy to require that third parties we share your personal information with protect that information consistent with this Policy and applicable law.

Targeted advertising partners

We work with and disclose certain personal information (identifiers, commercial information, contact preference information, demographic information, location or geolocation information, Internet or other electronic network activity information, and inferences) to third-party companies that support our advertising and marketing efforts, including to serve interest-based advertisements across the Internet; track and categorize your activity, interests and device(s) used over time on our Website and App, and on third-party websites and mobile applications. The advertising networks and related providers gather this information to create individual profiles that are disclosed to us, which allows us the ability to match those individual customer profiles with advertisements we believe may be most relevant to a particular customer.

We may also disclose other information at our discretion, including information collected by automated technologies, which may be used by third parties for their own marketing, advertising, and other purposes. Please see the Targeted advertising portion of the Your options and legal disclosures section below for information on the choices you have related to interest-based advertising.

We use third-party analytics providers

We use analytics services, including Google Analytics, to better understand how customers use our Website and App to improve those technologies and optimize your experience and interactions. If you wish to opt out of allowing Google to collect analytics information, please visit Google Analytics Opt-out Browser Add-on.

We may share feedback you provide to us

We are excited when customers want to share feedback with us about the products and services they have purchased and what we offer. If you ask a question about a product, respond to a question about a product or submit an online review, including if you include a photo, please be aware that this feedback may be publicly shared and used by us on the Website or App without compensation or attribution. Please see our Terms and Conditions for more information.

Your options and legal disclosures

We recognize that you want choice not only in the products and services we offer but also in how your personal information is used and shared. We currently offer the following choices and options:

Viewing your personal information. You can access your name, email address, billing address, shipping addresses, payment methods, transaction information (orders, purchases, and returns), by logging into your account on the Website and App.
Updating your personal information. You can also correct or update your name, email, billing or shipping addresses and payment methods by logging into your account on the Website. You may also make a request to update your personal information by writing to us at the email or postal mailing address specified in the Contact us section below.
Targeted advertising. You may opt out of the use of information about your browsing activities on our Services to show you ads on other websites and services by adjusting your settings for each device and browser you use with the Website and within each App you use. To opt out of targeted advertising, you must submit a request using our online form and adjust settings for each device and browser you use with the Website and within each App you use. To adjust settings for GRESSO, please go to our opt-out page. Alternatively, you may visit our Services using a legally recognized device or browser-based universal opt-out mechanism such as the Global Privacy Control, which will opt out the sharing of your personal information at a browser level. You may also opt out of targeted advertising by certain companies that participate in third-party industry groups by visiting the Network Advertising Initiative consumer opt-out page or the Digital Advertising Alliance's consumer choice tool. In addition, your device settings may offer you additional privacy settings when using our App; please see the device settings for details. Please note that even if you opt out of receiving interest-based advertising, you will still receive advertisements, but they will be more general in nature.
Email choices. You can opt out of marketing or advertising emails by following the unsubscribe process included in the promotional email you received or by logging into your account and indicating your preference. You may also request to opt out of marketing or advertising emails by contacting us at privacy@gresso.com. Please keep in mind that you if you opt out of receiving marketing messages, you will still receive transactional and service-related emails from us (such as emails related to your order, correction of personal information, password reset requests, reminder emails you have requested, updates to our terms and policies and other similar communications essential to your transactions on the Website or App) that may be necessary for us to make the Website and App available to you or respond to your inquiries.
Telephone choices (calls and texts). You may opt out of receiving text messages by texting "Stop" at the end of any message you receive, or to opt out of marketing or advertising calls, by contacting us through one of the methods specified in the Contact us section below and sharing the phone number that you would like to opt out.
Mobile location choices. If you use our App, you may decline to provide location information through your mobile device settings or any prompt requesting location information.

Additional rights in specific jurisdictions. For our customers residing in California, Colorado, Connecticut, Utah or Virginia, state law grants you additional rights (see below for information on the rights currently granted by state). You, or your legally designated representative, may submit a request to exercise your rights by completing our online form.

Rest assured, GRESSO will not discriminate or retaliate against you if you elect to exercise any legally available rights as described in this Policy. If you would like an authorized agent to submit a request on your behalf, please send us an email at privacy@gresso.com for instructions and additional information we need to respond to a request when submitted by a legally authorized agent.

Identity verification requirement. The law requires that we validate the identity and legal authority associated with certain personal information requests, including for customers residing in states granting additional rights as set out below. As a result, we may require that you take additional steps to validate your identity and legal authority, particularly where you make a request through our online form or in writing (email or postal mail). If you make a request online or through our Customer Care center, we will send a message to the email address you provided in your request and you must validate your request within seven (7) days as instructed in that email. Your request will be considered validated once you have completed the email validation process or submitted additional information as requested. Should you fail to confirm your request within the relevant timeframe and/or fail to provide the additional information requested, your request will be considered unvalidated and closed.

We will provide a response to any personal information request within the timeframe required by law. If we cannot substantively respond to your request in a timely manner, we will notify you and provide the reason for the delay.

Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. But we will respond to your request within a reasonable time, as required by law, and provide an explanation.

Virtual try-on information notice

We provide a virtual try-on tool for your convenience. The virtual try-on tool uses augmented reality technology to allow you to “try on” certain of our products, such as sunglasses, virtually, in order to get an idea of what the product would look like on your face in real life. We do not store any biometric information when you use the virtual try-on tool.

We use TrueDepth API technology with your camera to look at and measure multiple data points on your face. We use that information to place AR optical and sunglasses frames on your face in a realistic position and scale. We can also guide you to the best “width” frames based on your facial data points. We do not store any of these scans or measurements and we only collect and use that data while you are using the virtual try-on feature. We do not share these scans or measurements with any third parties.

During your virtual try-on session, no information or data relating to your face are sent to or from any external servers. The virtual try-on tool does not store, obtain, or transmit any retinal scans, facial geometry, or other biometric data externally, and does not have the ability to store, obtain, or transmit any retinal scans, facial geometry, or biometric data externally. The process of applying selected eyewear products on top of your face is all completed locally on your browser session, with no collection, preservation, storage, or transmission of any facial data outside of your browser.

For our customers residing in California

California law requires that we provide certain disclosures, including a description of legal rights, to those who reside in the state of California. If you are a California resident and a GRESSO customer, this section applies in addition to all other applicable rights and information contained in this Policy.

California disclosures. Please see the What personal information we collect and When we disclose personal information sections above for information about the categories of personal information we collect and categories of recipients to which we have disclosed such information over the preceding 12 months.

Your California rights. As a California resident, you have the right to request:

To know more about and access your personal information.
That we correct your personal information that is inaccurate.
That we delete your personal information.

Please see the Your options and legal disclosures section for additional information on how to exercise your rights. In addition, California law also gives you the right to request that we limit the use of your "sensitive" personal information. GRESSO does not use any sensitive personal information to make inferences about you and uses sensitive personal information only for reasons set forth in this Policy and as permitted by the California Consumer Privacy Act.

The rights granted to you under California law may provide us with exceptions to fulfilling your request, including where we need to retain the information to fulfill a legal obligation, complete a transaction with you, prevent fraud or any other purpose permitted by law.

Should you wish to appeal a determination we have made with regard to your personal information request, send an email to privacy@gresso.com within 14 days of receiving a final response from us. Include "Data Subject Rights Appeal" in the subject line of your email, and provide your name, the original request case number, the email address associated with your request and any relevant information for us to investigate your appeal. We will provide a response to your request for an appeal within a reasonable time and in accordance with applicable law.

Do not sell or share my personal information

As described above, we work with certain advertising partners to show ads that are targeted to your interests. These activities may be considered "selling" or "sharing" of your personal information under California law. To opt out of these activities, you must submit a request using our online form and adjust settings for each device and browser you use with the Website and within the App you use. To adjust settings for GRESSO, please go to our opt-out page. Alternatively, you may visit our Services using a legally recognized device or browser-based universal opt-out mechanism such as the Global Privacy Control, which will opt you out of the sale or sharing of your personal information. Please note that we may continue to collect and share personal information about you with other third parties, including to continue providing services to you where sharing of your personal information is for purposes other than targeted advertising and permitted by law. Adjusting your settings using the settings link above will only opt out of any sharing activity on the browser and device you are using for the GRESSO-branded website you are visiting once you tap the "confirm" button. If you use the App, you will also need to opt out under the Your Privacy Rights menu item for each App.

We do not knowingly "sell" or "share" the personal information of consumers under 16 years of age.

For our customers residing in Colorado, Connecticut, Utah and Virginia

Colorado, Connecticut, Utah and Virginia laws require that we provide certain disclosures, including a description of legal rights, to those who reside in those states. If you are a resident of Colorado, Connecticut, Utah or Virginia, and a GRESSO customer, this section applies in addition to all other applicable rights and information contained in this Policy.

As a resident of Colorado, Connecticut, Utah or Virginia, you have the right to request:

To know more about whether we are processing your personal information, access and receive a copy of your personal information.
That we correct your personal information that is inaccurate.
That we delete your personal information.
To opt out of the processing of your personal information for the purposes of providing you with targeted advertising.

Please see the Your options and legal disclosures section of this Policy section for additional information on how to exercise these rights.

The rights granted to you under applicable law may provide us with exceptions to fulfilling your request, including where we need to retain the information to fulfill a legal obligation, complete a transaction with you, prevent fraud or any other purpose permitted by law.

Other than as set forth in this Policy, GRESSO does not collect or process personal information that may be considered "sensitive" and subject to the laws in Colorado, Connecticut, Utah or Virginia. Nordstrom does not use personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

For our customers residing outside the U.S.

We operate globally and may transfer, store, and/or process your information to or with other entities within the GRESSO family of companies or other third parties such as trusted service providers and partners in locations around the world (including the United States) for the purposes described in this Privacy Policy. Wherever your information is transferred, stored or processed by us, we take reasonable steps to protect your information in accordance with this Privacy Policy and applicable laws. These measures may include implementing Standard Contractual Clauses to govern the transfer of your information, or other means recognized by applicable laws. By providing us with your information, you acknowledge any such transfer, storage, or processing.

Links to other sites

Links to other websites and services. Our Website and App may provide links to Internet sites, content, or videos (embedded or direct links) maintained by third parties. We are not responsible for the sites, content, or videos available via those links, and we have not reviewed the privacy practices of those third parties. We encourage you to review the privacy practices of any third-party sites you choose to access.

Contact us

If you have any questions or comments concerning your privacy or this Privacy Policy, you may contact us by email at privacy@gresso.com or write to us at the following address: GRESSO LLC, 444 Brickell Ave, Miami, FL 33131.

Updates to this policy

We may make changes to this Policy from time to time, and we may apply any changes to information previously collected, as permitted by law. Please be sure to check this Policy for updates. Each version of this Policy will be indicated by the last updated date at the top. If we make material changes to this Policy, we will notify you, such as by posting the updated Policy on the Website or App, and/or as otherwise required by applicable law.