Duty to inform according to Art. 12 ff. EU-DSGVO
Name and address of the person responsible
Your contact person as the person responsible within the meaning of the European Data Protection Basic Regulation ("EU-DSGVO") and other national data protection laws of the member states as well as other provisions of data protection law:
ICS International GmbH
ICS International GmbH Identcode-Systeme (hereafter: ICS or editor) is a member of the ICS Group. The ICS Group offers consulting, software, technology, and services for the digitization of corporate processes.
Our products, solutions, and services offer a high degree of customer value. This is based on trustful business relations with customers, suppliers, and partners and the trustful dealing with interested companies, employees, and other groups of stakeholders.
Performing our work and rendering our services sometimes requires the collection, processing, and use of personal data. ICS takes the protection of personal data very seriously and strictly ad¬heres to legal standards – like at present the General Data Protection Regulation GDPR 2016/679 (hereinafter referred to by the German abbreviation DSGVO) and the Data Protection Adaptation and Application Act that is additionally valid in Germany (DSAnpUG), and its integral part, the new German Data Protection Act (BDSG-NEU).
ICS will collect, process, and use personal data only as far as strictly necessary.
The following statement will tell you how we do guarantee data protection and which type of data are collected for which purpose.
1) Collection and Processing of Personal Data
1.1) General information
We will collect and process data on you in the following circumstances:
- If you contact us directly, e.g. via our website, through our customer service/telephone hotline, and if you are interested in our products and services or if you have any other request.
- If you register as a participant/visitor at ICS events and trade fair appearances, and/or voluntarily provide us with your contact details at such events.
- If you directly buy or ask for our products and services.
- If you respond to our direct marketing activities, e.g. by returning a response card from one of our mailing campaigns.
- If associated companies (acc. to § 15 AktG - German Stock Corporation Law. Hereinafter referred to by the German abbreviation §15 AktG) and individual business partners permissibly provide us with your data.
- If you provide us with data (online/offline) in the course of recruitment and application processes.
We shall not pass on your data to any third party without your consent, except
- where we are obliged to provide details in connection with legal provisions
- where the passing on of data is legally permitted and necessary, e.g. in connection with the prevention of fraud
- if associated companies (acc. to § 15 AktG) have to be involved in order to process your request.
1.2) Processing within the customer database
We store and use contact data and information (such as business communication history) received from customers and interested parties for the purpose of processing or initiating the business relationship. The processing is carried out on the basis of Art. 6 para. 1 sentence 1 lit. a of the German Data Protection Act. Personal data is collected and stored exclusively in accordance with the provisions of the basic data protection regulation DSGVO 2016/679 and the Federal Data Protection Act additionally applicable in Germany in its new version (BDSG-NEU).
As a customer database we and our affiliated companies (acc. to § 15 AktG) use Zoho CRM. The provider is Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, The Netherlands (hereinafter Zoho). The data is stored on Zoho's servers in the Netherlands / in the EU. In order to provide the service, we and our affiliated companies (acc. to § 15 AktG) have entered into a contract for commissioned data processing with Zoho.
You have the right to be informed at any time about the data stored about you in the customer database and you can request that the data is changed or deleted.
Further information on data protection at Zoho CRM can be found online at: https://www.zoho.com/crm/gdpr/ as well as https://www.zoho.com/security.html.
2) Collection and Processing of Personal Data when Accessing this Website
No personal data will normally be collected when you access our website. Whenever personal data (such as name, address, or email address in contact forms) are collected on our webpages you will give them on a voluntary basis. Your data will be automatically SSL (Sockets Layer Protocol) encoded right away. Your data will be saved and processed according to European and German data protection guidelines (DSGVO and DSAnpUG incl. BDSG-NEU) as well as in accordance with our internal rules.
Personal data collected in connection with this website will be used for processing your enquiries and orders. Depending on the type and contents of your enquiry, your data may be passed on to associated companies (acc. to §15 AktG) if this is necessary for processing purposes.
2.2) Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). The use is based on § 6 para. 1 p. 1 DSGVO. Google Analytics uses so-called “Cookies“, i.e. text files which are saved on your computer and which allow to analyze your use of this website. The information created by the cookie regarding your use of the website such as
- Browser type/version,
- Operating system used,
- Referrer URL (previous website used),
- Host name of the accessing computer (anonymised IP address),
- Time of the server server request,
will usually be transferred to a Google server in the USA where they are saved. The IP address transmitted by your browser in connection with Google Analytics will not be matched with other Google data. On this website, we have enhanced Google Analytics by the “anonymizeIP“ code. This guarantees the masking of your IP address so that all data will be collected anonymously. Only in exceptional cases will the complete IP address be transferred to a Google server in the USA where it will be abbreviated.
As instructed by the operator of this website, Google will use this information to analyze your use of the website, compile reports on the website activities, and to provide the website operator with other services in connection with the use of websites and of the Internet. You can prevent the saving of cookies through appropriate settings in your browser software; please note however that by doing so you may not be able to use all functions of this website to their full extent.
Apart from that you can prevent the collection of data (incl. your IP address) created by the cookie in connection with your use of the website through Google and Google’s processing of these data by downloading and installing the browser plug-in available via the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
We also use Google Analytics for analyzing data from double-click cookies and AdWords for statistical purposes. If you do not agree, you can disable this function by means of the Ads Preferences manager (https://adssettings.google.com).
For more information on data protection in connection with Google Analytics please refer to the Google Analytics Help function (https://support.google.com/analytics/answer/6004245?hl=de)
We and companies affiliated with us (pursuant to §15 AktG) use Zoho Campaigns to send newsletters. The provider of this application is Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, The Netherlands (hereinafter: Zoho). Zoho Campaigns is a service for creating, sending and managing marketing emails and newsletters. The data is stored on Zoho's servers in the Netherlands / in the EU. Responsible for the data processing process towards you is ICS. The newsletter is only available in German.
We offer you the possibility to subscribe to our newsletter on our website. If you would like to receive the newsletter offered on the website, we require a valid e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided or that the owner agrees to receive the newsletter. You are free to enter your last name and title when registering for the newsletter. Further data will not be collected. The personal data collected will be used to send you e-mail newsletters. You give us your consent in accordance with the law using the double opt-in procedure.
With your consent, you can subscribe to our newsletter. The data you enter for the purpose of receiving the newsletter (e.g. e-mail address) will be stored on Zoho's servers. A corresponding processing takes place on the basis of Art. 6 para. 1 p. 1 lit. a DSGVO. By subscribing to the newsletter, you consent to us measuring your click and opening behavior in order to provide you with an optimal offer of our newsletter dispatch.
2.4.2) Order data processing
We and our affiliated companies (according to §15 AktG) have concluded an order processing agreement with Zoho and fully implement the legal requirements of European and German data protection when using Zoho Campaigns. We transfer your data deposited during registration to Zoho only for the purpose of sending marketing emails and newsletters by us. Data is stored by Zoho in such a way that other Zoho customers or third parties do not have access to this data.
2.4.3) Additional information about Zoho Campaigns
You may withdraw your consent at any time without affecting the lawfulness of the processing carried out so far. If consent is revoked, we will stop the corresponding data processing. If you no longer wish to receive a newsletter in the future, you can also easily unsubscribe at any time, e.g. via the unsubscribe link at the end of each newsletter or by sending an e-mail to firstname.lastname@example.org. Your data for the newsletter dispatch will be deleted after the end of the newsletter receipt, provided that the deletion does not conflict with any legal retention obligations.
2.5) Data Protection Statement for the Use of Facebook
2.5.1) External links to the Facebook network
2.5.2) Facebook Marketing Services (Facebook Pixels and Custom Audiences)
Within our online offer, the so-called "Facebook pixel" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used for the purposes of analysis, optimization and economic operation of our online offer.
For data exchanges with Facebook (if outside the EU), the Facebook European Data Transfer Agreement Addendum will apply, effective 09/27/2021: https://www.facebook.com/legal/EU_data_transfer_addendum
With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to Facebook users who have shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called "custom audiences"). Using Facebook pixels, we also want to ensure that our Facebook ads match the potential interest of users and are not annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by showing whether users were referred to our website after clicking on a Facebook ad (known as "conversion").
The Facebook pixel is directly integrated by Facebook when our web pages are accessed and can store a so-called cookie, i.e. a small file, on your device. So-called first-party cookies, i.e. cookies stored under the domain of our website, are used here. If you then log in to Facebook or visit Facebook when logged in, the visit to our online service is noted in your profile. The data collected about you is anonymous to us and does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and can be used by Facebook as well as for its own market research and advertising purposes. If we transmit data to Facebook for comparison purposes, this data is encrypted locally on the browser and only then sent to Facebook via a secure https connection. This is done solely for the purpose of comparing it with the data encrypted by Facebook and only with your consent.
Facebook processes the data in accordance with the Facebook Data Usage Guidelines. Accordingly, general notes on the presentation of Facebook ads in the Facebook data usage guideline: https://www.facebook.com/policy.php.
Specific information and details about Facebook pixels and how they work can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.
You may opt out of Facebook pixel collection and use of your information to display Facebook ads. To set what types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions on the settings for usage-based ads: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
2.6) Data Protection Statement for the Use of Instagram
2.7) Data Protection Statement for the Use of LinkedIn
Our website uses functions of the LinkedIn network. Its provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Whenever you access one of our pages that includes LinkedIn functions, a connection with the LinkedIn servers will be established. LinkedIn will be informed that you have accessed our Internet pages through your IP address. If you click on the LinkedIn "Recommend button" while being logged into LinkedIn account, LinkedIn can allocate your visit of our Internet pages to you and your user account. Please note that we as the provider of these pages have no knowledge of the contents of the data transmitted and of their use by LinkedIn.
For more information please refer to LinkedIn’s data protection statement at: https://www.linkedin.com/legal/privacy-policy
2.8) Data Protection Statement for the Use of Twitter
Our pages contain functions of the service Twitter. These functions are offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. By using Twitter and the function "Re-Tweet", the websites accessed by you will be linked with your Twitter account and will be visible to other users. There will be data transfer to Twitter. Please note that we as the provider of these pages have no knowledge of the contents of the data transmitted, and of Twitter’s use of them. For more information please refer to Twitter’s data protection statement http://twitter.com/privacy.
You can amend your data protection settings for Twitter in the account settings at http://twitter.com/account/settings.
2.9) Data Protection Statement for the Use of Xing
Our website uses functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Deutschland. Whenever you access one of our pages that contains Xing functions, a connection with the Xing servers will be established. To our knowledge, no personal data will be saved in this case. No IP addresses will be saved, nor will be utilization behavior be analyzed.
For more information on data protection and the Xing Share button please refer to Xing’s data protection statement at https://www.xing.com/app/share?op=data_protection
2.10) Data Protection Statement for the Use of YouTube
Our website uses functions from Google's YouTube site. This website is operated by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. If you visit one of our pages equipped with a YouTube plugin, a connection to the YouTube servers is established. The Youtube server will be informed that you have accessed our Internet pages through your IP address.
If you are logged into your YouTube account, you allow YouTube to associate your surfing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.
2.11) Contact Form
When you send us enquiries using our contact form, your entries in the enquiry form including your contact details will be saved by us in order to process your enquiry and in case of further questions. Depending on the type and the contents of your enquiry, your data may be passed on to associated companies (acc. to § 15 AktG) if this is necessary for processing your enquiry.
2.12) Links to other Websites and Third Party Applications
For the interaction with other websites for which you are registered as a user (e.g. Facebook etc.) we can provide links or integrate applications of third parties. We can also provide you with general links to websites of other provider.
The use of these links and applications is controlled by the providers of these pages and is subject to their data protection guidelines. ICS International GmbH Identcode-Systeme is not responsible for the data protection stipulations or the contents of these pages.
2.13) Data Protection Statement for the use of Zoho SalesIQ and Zoho Page Sense
When you visit our website, anonymous usage data is collected using the ZOHO service SalesIQ (https://zoho.eu/salesiq). SalesIQ uses so-called "cookies" which enable an analysis of our website. You can prevent this "tracking" by making the appropriate settings in your browser. We store this data exclusively for statistical purposes. The IP addresses are shortened by the last digits within the framework of legislation in order to guarantee anonymity.
Through the service Sales IQ we also provide a chat function on our website (or selected websites). You can use the chat completely anonymously and enter your request - without providing personal data - in the chat text field. Optionally, you can enter your name and e-mail address in the chat contact fields. Chat logs are stored in our customer database (Zoho CRM). We only store business relevant contacts and chat logs.
Zoho Page Sense:
When you visit our website, anonymous usage data is collected using the ZOHO PageSense service (https://zoho.eu/pagesense). Page Sense only records visits and clicks to our website anonymously. There is no inference about individual visitors. PageSense only enables us to check the general use of our website in the form of a heat map and to display its important content in the right place on the individual websites. No usage data or personal data is collected or stored.
The website uses the "Acuity Scheduling" service in some places to simplify appointment scheduling via an integrated calendar function. The provider of this tool is Acuity Scheduling Inc, a Squarespace company, NY, USA. Acuity Scheduling enables us to process appointment requests faster and in a more customer-friendly manner.
When you book an appointment (support, consulting, sales, etc.) online via our website, the data you enter will be transferred to our protected account at Acuity Scheduling for processing your appointment request. You will then receive an appointment confirmation by email. If you decide to cancel your appointment reservation, after saving the appointment, please click "Cancel". You will then receive an appointment cancellation confirmation via email. If you wish to stop receiving appointment notifications, you can unsubscribe at any time by clicking the "unsubscribe" button in the email. In addition, you have the right to request deletion of your data at any time. To do so, please contact us at email@example.com.
The legal basis for the processing is our legitimate interest in offering you a user-friendly, time-saving appointment arrangement (cf. Art. 6 (1) lit. f DSGVO). If you do not wish to use the service, you always have the option to use an alternative contact channel (e.g. via the contact form on the website).
If necessary, we may pass on your transmitted data to companies affiliated with us (according to Section 15 of the German Stock Corporation Act (AktG)), insofar as this is necessary for processing your appointment request or concern. ICS International is the solely responsible party to you for your personal data and its use in Acuity Scheduling. You can request the deletion of your data stored in Acuity Scheduling at any time by notifying us.
2.15) Data protection declaration for the use of the Microsoft Office services “Bookings” and “Teams”.
On our websites and in other digital media, especially in emails, we offer you the opportunity to reserve consultation and/or consultation appointments (on-site, online, hybrid) with us directly using the Microsoft calendar function “Bookings” and to reserve these in the event from “teams” online.
The provider of the services is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. ICS is responsible for data processing within the meaning of the GDPR when using these services.
The following personal data may be processed when using the services, including but not limited to:
- E-mail address
- Telephone number if applicable
- Appointment information (date, time, purpose of the appointment)
- If necessary, further information provided by the user in the appointment content
- User account information (e.g. name, email address, profile picture)
- Communication content (e.g. chat messages, files, shared content)
- Metadata about the use of Microsoft Teams (e.g. IP addresses, device information, location data)
you and for live communication with you (in the case of Microsoft Teams). Data processing is carried out on the basis of Art. 6 Para. 1 GDPR.
We may pass on your data to an affiliated company (according to Section 15 AktG) and, if necessary, other third parties if this is necessary to prepare and/or fulfill an appointment with you. In addition, data will only be passed on to third parties if we are legally obliged to do so.
We and companies affiliated with us (according to section 15 AktG) take appropriate technical and organizational measures to protect your personal data from unauthorized access, loss or misuse. This includes encryption of data transmissions, access restrictions and regular reviews of our security measures.
Other third parties to whom we transmit personal data are contractually obliged to take appropriate data protection measures.
The data collected will be stored for as long as it is necessary to fulfill the purpose of the appointment or as long as there is a legal obligation to retain it. Once the purpose or the retention period has expired, the data will be deleted. If a business relationship with you is initiated or contractually concluded after an appointment has been concluded, the statutory retention period of the data applies for the resulting fulfillment purpose.
In accordance with applicable data protection laws, you have the right to access, rectify, delete and restrict the processing of your personal data. You also have the right to object to the processing of your data and the right to data portability. Please contact us using the contact details provided at the end of the data protection declaration.
Further information about Microsoft's services and the provider's respective data protection regulations can be found here: https://privacy.microsoft.com/de-de/privacystatement. You can view Microsoft's security measures for Microsoft 365 services (such as bookings and teams) here: https://www.microsoft.com/de-de/microsoft-365/business/data-security-privacy-germany.
Our website uses plugins from the customer evaluation platform Proven Expert. The provider is Expert Systems AG, Quedlinburger Str. 1, 10589 Berlin, Germany. In the context of the creation of reviews, only your email address and the corresponding log file are stored as inventory data. A log file consists of the IP address assigned to the inquiring computer by the Internet access provider for the session, as well as the name and version of the Internet browser with which you accessed our website.
You also have the option of entering your first and last name, which is then also stored. Personal data (e.g. name and e-mail address) is always processed in accordance with the basic data protection regulation and in compliance with the applicable data protection regulations. Evaluations can be made anonymously. Further information about the handling of Proven Expert and the respective data protection can be found under: https://www.provenexpert.com/en-us/privacy-policy/
You have the possibility to subscribe to our weblog (https://blog.ics-group.eu). Confirmation of the subscription is done via the double opt-in procedure. All you need is your e-mail address. No other data is collected and stored. The weblog is operated by ICS Group with a server in Germany / in the EU.
For our own market research purposes, we, and our affiliated companies (according to §15 AktG) use Zoho Survey to create surveys and process the responses. Our surveys have an exclusive B2B focus and are not intended for private individuals.
The provider of the application we use for surveys is Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, the Netherlands (hereinafter: Zoho). The data is stored on Zoho's servers in the Netherlands / in the EU. The ICS is responsible regarding your data processing.
Participation in surveys is always voluntary, as is answering or not answering individual questions in surveys.
Surveys are conducted by us anonymously - personal data is not collected, and it does not bear any relation to the respondent as a person. Exception: In individual cases, surveys may be designed by us in such a way that the respondent can provide personal data voluntarily (such as name and e-mail address), e.g. for the purpose of contacting the respondent. The indication of this data is always voluntary. If you have voluntarily provided us with personal data via surveys, you have the right to view this data, correct it or have it deleted at any time.
We and our affiliated companies (according to §15 AktG) have concluded an order processing contract with Zoho and fully implement the legal requirements of European and German data protection law when using Zoho Survey.
3) Use of Personal Data
We will use the data provided by you for the processing of your order and for responding to your queries as well as to initiate and maintain the business relationship. If you register for our newsletter, your email address will be used for our marketing purposes until you unregister from the newsletter. This possible anytime (e.g. by using the “unregister” link in the newsletter or by sending an email to firstname.lastname@example.org).
If necessary and legally permitted, your data will be used for credit checks or for requests for information prior to the conclusion of a contract and if necessary also in the course of business relations in connection with contract management and handling. To this end, we use special providers and credit agencies; information on payment behavior and credit standing can also be provided as score values based on mathematical-statistical procedures.
We guarantee not to pass on personal data to third parties unless we are legally permitted or obliged to do so, or with your prior consent. We can pass on your personal data in connection with ongoing or future lawsuits – among others to justify, execute or defend our legal rights (including the passing on of information to third parties for the prevention of fraud prevention and to reduce the credit risk).
We can pass on your personal data to associated companies (acc. to § 15 AktG) should this be necessary for processing your request.
3.2) Recruitment / Application Process
We would like to point out that we and our affiliated companies (acc. to §15 AktG) collect and use your personal data in connection with personnel recruitment (both online and offline).
As far as we use service providers for the execution and handling of processing, the contractual relationships are regulated according to the provisions of the European Data Protection Basic Regulation (DSGVO).
We and our affiliated companies (acc. to §15 AktG) use the recruiting tool "Zoho Recruit" to receive and to administer applications and thus for the purpose of (possibly) establishing an employment relationship. The provider of this application is Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, The Netherlands (hereinafter: Zoho). The data is stored on Zoho's servers in the Netherlands / in the EU.
If you apply to us, the following will happen: The provider collects the following data from you on our behalf: Your title, your first name and surname, your availability data and other data from your application. ICS and our affiliated companies (acc. to §15 AktG) can then access an internal and secure area of Zoho Recruit, view your applicant data and use / process it for the documentation of the application process and communication with you.
The legal basis for processing applicant and application data is Article 88(1) DSGVO in conjunction with paragraph 1, section 26, BDSG 2018. The relevant service relationship between Zoho and ICS or companies affiliated with ICS is based on Article 28 DSGVO and the so-called order processing.
ICS and companies affiliated with us (acc. to §15 AktG) store applicant data in Zoho in accordance with statutory retention periods. Subsequently, applicant data will be deleted completely and in accordance with data protection regulations. Furthermore, the applicant (m/f/d) has the right to have his/her data completely deleted at any time upon request and notification.
If ICS and affiliated companies wish to keep applicant data in the Zoho for longer than the legal requirements (e.g. for the talent pool), this will only happen if the applicant (m/f/d) gives his written consent. This consent can be revoked at any time.
3.3) Right to Information / “Right to be Forgotten“
According to the Basic Data Protection Act (DSGVO) you are entitled to gratuitous information on the data saved on you and the right of correction, blocking or deletion of these data, or the right to be forgotten.
According to Art. 21 § 1, sentences 2 and 3 DSGVO, we are obliged to provide you with information – depending on the circumstances - in writing, electronically or – on request – orally. You have an all-time, comprehensive right of objection (Art. 21 Abs. 2 DSGVO). Any consent given so far will remain effective. All our ways of communication fulfill the respective safety requirements. Information on the data saved on you will be provided on request by our data protection engineer. To contact us please use the email address email@example.com.
3.4) Credit Checks and Scoring
Should we provide preliminary work, e.g. in case of purchase on account, we may obtain a credit check based on mathematical-statistic processes from Creditreform, Hellersbergstraße 12, 41460 Neuss and/or Euler Hermes Deutschland AG Friedensallee 254, 22763 Hamburg to safeguard our interests. To this end, we will transfer the personal data necessary for a credit check to Creditreform / Euler Hermes. We shall use the resulting information on the statistical possibility of a debt default for an assessed decision regarding the justification, execution, or termination of the contract. The credit report may include score values that are calculated on the basis of scientifically renowned, mathematic-statistic procedures; among others, address data will be used for calculation purposes. Your concerns worthy of protection shall be taken into account in accordance with legal stipulations.
5) Further Information / Data Protection Contact
Your trust is important to us. We would therefore like to answer your questions regarding the processing of your personal data. If you would like information about your stored personal data or have questions that could not be answered by this data protection declaration or if you would like more detailed information on a certain point, please contact our data protection officer at any time: firstname.lastname@example.org. You can also reach us at:
ICS International GmbH
Data protection officer
Data protection queries / data protection queries will usually be replied to within max. 30 days upon receipt.