Privacy Policy

Propet Footwear, Inc. (together with its subsidiaries, divisions, and brands, collectively, "Propet," "we," "us," or "our," as the context may require) provides the Site(s) where this Privacy Policy (this "Policy") appears (collectively, the "Site"). This Policy describes our privacy practices for the Site, including the types of information we may collect from you when you visit the Site and our practices for collecting, using, protecting, and disclosing that information. We respect the privacy of the users of the Site ("you" or "your," as the context may require) and we are committed to respecting your privacy and the security of your personal information through compliance with this Policy.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using the Site, you agree to this Policy and our Terms of Use (collectively the "User Terms"). If you do not agree with our policies, practices, or terms and conditions contained in the User Terms, you may not visit, access, use or otherwise interact with the Site.

This Policy and the User Terms may change from time to time (see Section 11 (How to Contact Us)). Your continued use of the Site after we revise this Policy or the User Terms means you accept this Policy or User Terms as amended, so please check this Policy and the User Terms periodically for updates.

1. The Interactions this Policy Covers

Except with respect to Section 8.A (California Privacy Notice) or as otherwise required by applicable law, this Policy describes our practices with respect to and applies exclusively to personal information (as defined below) that we collect on or in connection with the Site and in texts, emails, and other electronic communications sent through or in connection with the Site. Except as otherwise provided in this Policy or as required by applicable law, this Policy does not apply to information that is collected by any application, website (other than the Site), or third party, including through any application or content that may access, be linked to or otherwise be accessible from the Site.

Except as otherwise provided in this Policy, when used in this Policy, "personal information" mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you; provided that "personal information" shall not include information which is generally not considered "personal information" under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations, such as "protected health information" covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or information not otherwise considered "personal information" under applicable law.

2. Children's Privacy

The Site is not directed to nor intended for use by children under sixteen (16) years old ("Prohibited Users"). We do not knowingly collect personal information from Prohibited Users. Prohibited Users are not authorized to use the Site. If you are a Prohibited User, do not use or provide any personal information to, on, or through the Site. If we learn we have collected or received personal information from a Prohibited User, we will delete that information. If you believe we might have any information from or about a Prohibited User, please contact us by any of the methods listed below.

3. Information We Collect

We collect several types of information from and about you as a result of your use of the Site and as a result of your communication with us. This information may include:

• Personal Information, such as your name, postal address(es), billing address(es), email address, telephone number, billing information (such as credit card information) and, in some cases (such as when you provide this information in response to a survey or registration form) age, gender, and product preference information.
• Information that is about to or relates to you, but is not personal information and which does not identify you, such as information about your internet connection, the equipment you use to access the Site, and usage details.
• Any other form or category of information, including personal information, which you disclose or share on the Site, or disclose to or share with us in any manner.

We may collect personal information from and about you:

• Directly from you when you provide it to us;
• Automatically when you use or access the Site; and
• To the extent permitted by applicable law, from third parties (such as our service providers).

4. How We Collect Personal Information

A. From You

The personal information we collect directly from you when you use or access the Site may include:

• Personal information that you provide by filling in forms on the Site making an account on the Site, or otherwise connecting with us via the Site (e.g., by placing an order). This includes information provided at the time of registering to use the Site, placing an order, posting material, or requesting further information, products, or services. We may also ask you for information when you report a problem with the Site.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete.
• Details of transactions you carry out through the Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Site.  Versapay Corporation is a Credit Card and cloud-based payment processing service provider. For more information, you can read VersaPay’s Privacy policy at (https://www.versapay.com/privacy-policy)
• Information you provide to us in a resume, application, email, or other communication in connection with an application for, indication of interest in, or inquiry regarding employment with us.
• Your search queries on the Site.
• Any other personal information which you provide on the Site or otherwise directly to us.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Site with whom you may choose to share your User Contributions.

B. Automatically

As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including (i) details of your visits to the Site, including traffic data, location data, logs, and other communication data, as well as the resources you access and use on the Site; and (ii) information about your computer and internet connection, including your IP address, operating system, and browser type. We use cookies and may use also use other online tools such as "pixel tags," as described below, when you interact with the Site.

The Site does respond to "do not track" browser signals or any other mechanism which automatically communicates your choice not to be tracked online. The Site does use automatic technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See Section 7 (Your Privacy Choices) for more information on mechanisms that enable consumers to exercise choice about behavioral tracking.

The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.

The information we collect automatically may  include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. Information we collect automatically helps us to improve the Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Site according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Site.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.
• Web Beacons. Pages of the Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain content and verifying system and server integrity).
• Flash Cookies. Certain features of the Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

C. From Third Parties

We may also receive personal information or draw inferences about you from other sources, including service providers who collect or process information on our behalf.

Some content or applications on the Site may be served by third parties. These third parties may use cookies and other tools to collect information about you when you use the Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based, behavioral advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Section 7 (Your Privacy Choices).] [NTD: Bracketed paragraph to be included only if applicable.

The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

This Policy does not cover the privacy practices of any third parties or of websites other than the Site, and please be aware that Propet does not claim any responsibility for the privacy practices of third parties or of websites other than the Site, including those third parties or websites that we may receive information from or that the Site may link from or to. If you have any questions about a third party or their privacy practices, you should contact the third party directly.

5. How We Use Your Information 

We may use the personal information that we collect about you or that you provide to us:

• To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop the Site, and to provide our products and services to you.
• To create, maintain, customize, and secure your account and to provide you with notices about your account and/or orders with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of the Site, as well as our products, services, databases and other technology assets.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to the Site or any products or services we offer or provide though it.
• To identify your product and service preferences.To customize our communications to you.
• ANY OTHER USES FOR PERSONAL INFORMATION RELEVANT TO PROPET'S BUSINESS
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To provide information concerning product recalls or products you have purchased.
• To help maintain the safety, security, and integrity of the Site.
• For testing, research, analysis, and product development, including to develop and improve the Site, as well as our merchandise selection, customer service, products and services.
• To respond to law enforcement requests and, as required by applicable law, court order or governmental regulations.
• To evaluate, negotiate, or conduct a merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users, customers, and/or suppliers is among the assets transferred.
• Provide you with the Site, its contents, and any other information, products, or services that you request from us.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction.

We may also use your information to contact you about our goods and services that may be of interest to you or the entity you represent. If you do not want us to use your information in this way, please see Section 7 (Your Privacy Choices). We do not use your personal information for marketing goods or services of non-affiliated third parties.

6. Disclosure of Your Information/

We may disclose personal information that we collect about you or that you provide to us:

• To our subsidiaries and affiliates.
• To our contractors and service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes which we disclosed it to them. For example, we contract with third parties to provide us certain services, including email services, payment processing, inventory management, advertising, and other ecommerce providers.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Propet, our customers or others.

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction.

7. Your Privacy Choices

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from Us. If you do not wish to have your contact information used by the us to promote our own products or services, you can opt-out of such communications by revising your profile by unchecking the boxes for opt-in communications. You may also click the “unsubscribe” link at the bottom of any email opt-in communication you receive from us and follow the instructions provided therein. If we have sent you a promotional email, you may also send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Propet as a result of a product purchase, warranty registration, product service experience or other transactions.
• Accessing and Correcting Your Information. You can review and change your personal information by logging into the Site and visiting your account profile page. You may also send us an email at [EMAIL] to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users of the Site. Proper access and use of information provided on the Site, including User Contributions, is governed by our Terms of Use.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

If you are a resident of certain jurisdictions (e.g., California), applicable law may provide you with additional rights regarding your personal information. Please see Section 8 (Jurisdiction-Specific Notices) for more information.

8. Jurisdiction Specific Notices

A. California Privacy Notice

This Section 8.A (our "CA Privacy Notice") applies exclusively to visitors and users of the Site who reside in the state of California ("consumers"). We provide our California Privacy Notice to comply with California privacy laws, including the California Consumer Privacy Act of 2018 (the "CCPA"). Notwithstanding anything to the contrary elsewhere in this Policy, terms defined in the CCPA have the meaning assigned to them under the CCPA when used in this CA Privacy Notice.

The CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B Personal Information") and workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals ("Workforce Personal Information") from some of its requirements.

I. Personal Information We Collect

We may collect, and in the last twelve (12) months have collected, the following categories of personal information from consumers:

II. Sources of Personal Information

We may collect your personal information from the categories of sources of personal information identified in Section 4 (How We Collect Personal Information).

III. Use of Personal Information 

We may use, disclose, or otherwise process the personal information we collect for the purposes identified in Sections 5 (How We Use Your Information) and 6 (Disclosure of Your Information).

IV. Sharing Personal Information 

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below. We do not sell personal information. For more on your personal information sale rights, see Section 8.A.V (Your Rights and Choices).

The CCPA differentiates between "business purpose disclosures" (which are made to third parties, such as service providers, who are subject to a written contract restricting their ability to use or disclose the personal information received from the company except for a business purpose specified in the contract) and "sales" (any sharing which involves valuable consideration (which is not limited to monetary consideration) where these restrictions are not in place).

V. Your Rights and Choices 

The CCPA provides consumers with specific rights regarding their personal information. This Section 8.A.V describes your CCPA rights and explains how to exercise those rights.

a. Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (your "Right to Know"). Once we receive a valid request from you and confirm your identity (see Section 8.A.V.c (Exercising Your Rights to Know or Delete)), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a "Data Portability Request").

To the fullest extent permitted by applicable law, including for so long as permitted by the CCPA, we will not provide the foregoing disclosures for B2B Personal Information or Workforce Personal Information.

b. Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (your "Right to Delete"). Once we receive a valid request for your and confirm your identity (see Section 8.A.V.c (Exercising Your Rights to Know or Delete)), we will review your request. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. To the fullest extent permitted by applicable law, including for so long as permitted by the CCPA, we will not provide the foregoing deletion rights for B2B Personal Information or Workforce Personal Information.

c. Exercising Your Rights to Know or Delete

To exercise your Right to Know or your Right to Delete described above, please submit a request by either

• Calling us at 800-877-6738;
• Emailing us at customerservice@propetfootwear.com; or
• Visiting www.propetfootwear.com.

Only you or your authorized representative may make a verifiable consumer request related to your personal information. You may only make a Request to Know, Data Access Request, or Data Portability Request twice within a twelve (12) month period. Your Request to Know, Data Access Request, or Data Portability Request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or are an authorized representative of such person, which may include:
  • Information which we already maintain; or
  • If we cannot verify your identity based on information already maintained by us, such information that we or our representatives request from you.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

d. Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within this timeframe, please contact us as provided in Section 11

(How to Contact Us).

We try to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. We cannot respond to your request or provide you with personal information unless we can verify your identity or authority to make the request and confirm the personal information relates to you. If we cannot verify your request within forty-five (45) days of its receipt, we may deny your request.

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. For instructions on exercising your sale opt-out or opt-in rights, see Section 8.A.V.e (Personal Information Sales Opt-Out and Opt-In Rights) below.

e. Personal Information Sales Opt-out and Opt-in Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell personal information and therefore do not sell the personal information of Consumers we actually know are less than 16 years old. 

f. Non-Discrimination; Notice of Financial Incentives

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program is entirely voluntary and requires your prior opt-in consent, which you may revoke at any time.

From time to time, we may offer programs, benefits, or other offerings which are considered financial incentives under the CCPA. Unless otherwise disclosed in a separate set of terms and conditions related to a specific financial incentive, we may collect the same categories of personal information in connection with a financial incentive as are described in this Policy and may use, share, and sell personal information in connection with a financial incentive in the same manner as described in this Policy. By opting to participate in a financial incentive which we offer, you are agreeing to the collection, use, and disclosure of your personal information as described herein.

B. European Economic Area and United Kingdom Privacy Notice

This Section 8.B applies exclusively to visitors and users of the Services who are located in the European Union, the United Kingdom, the European Economic Area, or who are otherwise considered "data subjects" ("Data Subjects") under the EU General Data Protection Regulation ("GDPR"), the General Data Protection Regulation of the United Kingdom, their successor regulations, or any similar laws or regulations similar to or administered under the GDPR promulgated in any country in the European Union, United Kingdom, or the European Economic Area (collectively "European Privacy Laws").

I. Rights of Data Subjects

If you are a Data Subject, you may have the following rights under European Privacy Laws:

• The right to request copies of your personal information. If you require more than one copy, we may charge you a reasonable fee.
• The right to request that we correct any personal information that you believe is inaccurate, or complete any personal information which you believe is incomplete.
• The right to request that we erase your personal information, under certain circumstances.
• The right to request that we restrict the processing of your personal information, under certain circumstances.
• The right to object to our processing of your personal information, under certain circumstances.
• The right to request we transfer data that we have collected to you or directly to another organization, under certain circumstances.
• The right to withdraw your consent, explicit or otherwise, at any time. If we rely on your consent as the sole legal basis for our processing of your personal information, we cease such processing at the time you withdraw your consent.

For the purposes of European Privacy Laws, Propet is the data controller (i.e., responsible for controlling the processing of personal information covered by this Policy). If you are a Data Subject and would like to exercise any of the foregoing rights, please contact us as provided in Section 11 (How to Contact Us).

II. Transfer of Personal Information

The Site is operated and managed on servers located and operated within the United States. Any information collected through the Site as described in this Policy may be stored in the United States or any other country in which Propet or its service providers maintain facilities. The United States is not recognized as having adequate safeguards under European Privacy Laws. If you are located outside of the United States, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the United States.

C. Nevada Privacy Notice

This Section 8.C applies exclusively to visitors and users of the Site who reside in the state of Nevada. Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada residents who wish to exercise this sale opt-out right may email us at customerservice@propetfootwear.com. Please include "Nevada" in your email subject line and include the following information in your email: (i) your name, (ii) Nevada resident address, and (iii) email address. However, please know we do not currently sell data triggering that statute's opt-out requirements.

9. Security

We implement various security measures in accordance with industry standards to protect the security of your personal information both online and offline. The safety and security of your information also depends on you. Where you have a password for access to certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.  We urge you to be careful about giving out personal information in public areas of the Site such as product reviews or comments. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

10. Changes to this Policy

It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will notify you through a notice on the Site's home page. The date this Policy was last revised and/or reviewed is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting the Site and this Policy to check for any changes. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.

11. How to Contact Us

For questions, comments or assistance, we invite you to contact us. To ask questions or comment about this Policy, our privacy practices, or privacy-related issues, please contact us:

Via mail:
Propet Footwear
2415 West Valley Highway
N Auburn, WA 98001

Via email at:  
customerservice@propetfootwear.com

Via phone at:      
800-877-6738 

 If you are a Data Subject and feel we have not resolved a privacy concern related to personal information processed or transferred by Propet, you have the right to submit a complaint to a supervisory authority.