1.INTRODUCTION

When you use SPDY, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

Last modified: May 15, 2023
Effective date: May 15, 2023

2.OVERVIEW

A.SCOPE

This notice applies to users of SPDY’s services anywhere in the world, including users of SPDY’s apps, websites, or other services.
This notice describes how SPDY and its affiliates, collect and use personal data. This notice applies to all users of our apps, websites, features or other services anywhere in the world, unless covered by a separate privacy notice. This notice specifically applies to:

*Customers: individuals who request or receive contracting services
*Contractors: Contractors who provide services at the request of customers individually or through partner contractor companies

This notice also governs SPDY’s other collections of personal data in connection with SPDY’s services. For example, we may collect the contact information of individuals who use accounts owned by SPDY for Business customers. We may also collect the personal data of those who start but do not complete applications to be registered to receive contractor leads offered by other companies through the SPDY app, or in connection with our mapping technology and features.

All those subject to this notice are referred to as ‘users’ in this notice.

*For California users: Information regarding SPDY’s privacy practices related to the California Consumer Privacy Act (CCPA) is available here.
*For guest users: The personal data of those who order contractor services via partner websites or apps, or arranged by other account owners (collectively ‘Guest Users’) is used solely to provide such trips, deliveries or other services requested through a third party, and for purposes of safety and security, customer support, research and development, enabling communication between users, and in connection with legal proceedings and requirements, each as described in ‘How we use personal data’ below. Guest User data may be shared with third parties for these purposes. Such data may be associated with, and accessible by, the owner of that account. This specifically includes Guest Users who order services for SPDY for Business accounts, or who receive contractor leads ordered by friends, family members or others. To submit questions, comments or complaints regarding Guest User data, or to submit requests regarding such data, please visit here.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us here or through the addresses below with any questions regarding our practices in a particular country or region.

B.DATA CONTROLLER AND TRANSFER

SPDY Technologies LLC. is the data controller for the personal data collected in connection with use of SPDY’s services anywhere in the United States of America.
SPDY Technologies Inc. is the data controller for the personal data collected in connection with use of SPDY’s services anywhere else.

SPDY operates, and processes data, globally. We may also transfer data to countries other than the one where our users live or use SPDY’s services. We do so in order to fulfill our agreements with users, such as our Terms of Use, or based on users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.

Questions, comments, and complaints about SPDY’s data practices can be submitted here. You may also use this form to submit a question to SPDY’s Data Protection Officer.

3.DATA COLLECTION AND USES

A.THE DATA WE COLLECT

SPDY collects:

*Data provided by users to SPDY, such as during account creation
*Data created during use of our services, such as location, app usage, and device data
*Data from other sources, such as SPDY partners and third parties that use SPDY APIs
The following data is collected by or on behalf of SPDY:

1-Data provided by users. This includes:

*User profile: We collect data when users create or update their SPDY accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This may include vehicle or insurance information of drivers, emergency contact information, user settings, and evidence of health or fitness to provide services using SPDY apps.
We may use the photos submitted by users to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data.”
*Background check and identity verification: We collect background check and identity verification information for drivers and delivery persons. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on SPDY’s behalf. Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
*User content: We collect the information users submit when they contact SPDY customer support, provide ratings or compliments for other users or contractors, or otherwise contact SPDY. This may include feedback, photographs or other recordings collected by users.

2-Data created during use of our services. This includes:

*Location data (contractor driver): SPDY collects this data when the SPDY app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
*Location data (Customer requesting services). We collect precise or approximate location data from customers’ who request contractor services if they enable us to do so. SPDY collects this data from the time a contractor service is requested until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps, including to improve customer service locations, enable safety features, and prevent and detect fraud.
SPDY collects contractor driver location data, and links location data collected during a trip with their customer’s account, even if the rider has not enabled us to collect location data from their device. This enables us to offer services to the customer like receipt generation and customer support.
*Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
*Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Notice.
*Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
*Communications data: We enable users to communicate with each other and SPDY through SPDY’s mobile apps and websites. For example, we enable contractor providers and customer requesting services, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, SPDY receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. SPDY may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.

3-Data from other sources. This includes:

*User feedback, such as ratings, feedback, or compliments.
*Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.
*SPDY account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of SPDY for Business accounts.
*Users or others providing information in connection with claims or disputes.
*SPDY business partners through which users create or access their SPDY account, such as payment providers, social media services, or apps or websites that use SPDY’s APIs or whose APIs SPDY uses.
*Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
*Partner contractor companies (for technicians who use our services through an account associated with such a company).
*Publicly available sources.
*Marketing service providers.

SPDY may combine the data collected from these sources with other data in its possession.

B.HOW WE USE PERSONAL DATA

SPDY collects and uses data to enable reliable and convenient provisioning of contractor services, and other products and services. We also use the data we collect:

*To enhance the safety and security of our users and services
*For customer support
*For research and development
*To enable communications between users
*To send marketing and non-marketing communications to users
*In connection with legal proceedings

SPDY does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

SPDY uses the data it collects for purposes including:

1- Providing services and features. SPDY uses the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to:

*Create and update users’ accounts.
*Verify contractors’ identity, background history, and eligibility to work.
*Offer, process, or facilitate payments for our services.
*Track and share the progress of contractor requested services.
*Enable features that allow users to share information with other people, such as when customers submit a compliment about a contractor provider, refer a friend to SPDY, or share ETA and location with their contacts.
*Enable features to personalize users’ SPDY accounts, such as creating bookmarks for favorite places, and to enable quick access to previous contractor providers or previous contractor customers.
*Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends. 2-Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

*Screening contractor providers before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe providers.
*In certain regions, using information derived from driver’s license photos, and other photos submitted to SPDY, for safety and security purposes. This includes SPDY’s Real-Time ID Check feature, which prompts drivers and delivery persons to share a selfie before going online to help ensure that the driver or delivery persons using the app matches the SPDY account we have on file. This also includes comparing photographs that we have on file against photographs (i) of other users to prevent identity-borrowing, and (ii) from public databases to verify user identity.
*Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
*Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating drivers and delivery persons with low ratings or who otherwise violated such guidelines in certain countries.
3-Customer support. SPDY uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

*Direct questions to the appropriate customer support person
*Investigate and address user concerns
*Monitor and improve our customer support responses and processes

4-Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5-Enabling communications between users. For example, a contractor may message or call a customer requesting service to confirm a destination location, a customer requesting service may contact a contractor provider to provide more specific directions or location information.

6-Marketing. SPDY may use the data we collect to market our services to our users. This includes sending users communications about SPDY services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by SPDY partners. For example, if a user has placed an SPDY order for AC Repairs, we may provide recommendations, promotions, or ads about similar home owner opportunities offered by other SPDY partners. Although we may send users communications about SPDY partners’ products and services, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of SPDY’s services, and user preferences and settings.

We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, SPDY may notify some users by email of ballot measures or pending legislation relating to the availability of SPDY’s services in those users’ areas.

7-Non-marketing communications. SPDY may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of SPDY or its partners.

8-Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of SPDY’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

9- Automated decision-making

We use personal data to make automated decisions relating to use of our services. This includes:

*Enabling dynamic pricing, in which the price of a lead for a contractor, is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of services requested by customers using SPDY at a given moment.
*Matching available Contractors providers users requesting services. Users can be matched based on availability, proximity, and other factors. Please see here for further information about our matching process.
*Determining contractor provider ratings, and deactivating contractor providers and customers, with low ratings. For more information about how ratings are determined and used, please see here for contractor provider ratings, here for customer ratings. Please also see the section below titled “Ratings look-up” for further information.
*Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm SPDY, its users, and others. In some cases, such as when a user is determined to be abusing SPDY’s referral program, such behavior may result in automatic deactivation.
*Using driver location information, and communications between contractor providers and customer users, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a contractor provider is delaying travel to the customer user in order to induce a cancellation, we will not charge the customer user a cancellation fee and will adjust the amounts paid to the driver to omit such a fee. To object to such adjustment, please contact SPDY customer support.

Click the links in this section for more information about these processes. To object to a deactivation resulting from these processes, please contact SPDY customer support.

C.COOKIES AND THIRD PARTY TECHNOLOGIES

SPDY and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.
Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. SPDY uses cookies and similar technologies for purposes such as:

*Authenticating users
*Remembering user preferences and settings
*Determining the popularity of content
*Delivering and measuring the effectiveness of advertising campaigns
*Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

Please see our Cookie Notice for more information regarding the use of cookies and other technologies described in this section.

D.DATA SHARING AND DISCLOSURE

Some of SPDY’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.
SPDY may share the data we collect:

1-With other users

This includes sharing:

*Customer Users’ first name, rating, and service location with contractor provider.
*For contractor providers, we may share data with the customer user, including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of services provided; length of use of the SPDY app; contact information (depending upon applicable laws); and contractor profile, including compliments and other feedback submitted by past users.

We also provide contractor providers with receipts containing information such as a breakdown of amounts charged, first name, photo, route map, and such other information required on invoices in the country or region where the driver or delivery person operates.
*For those who participate in SPDY’s referral program, we share certain personal data of referred users, such as assigned customer lead count, with the user who referred them, to the extent relevant to determining the referral bonus.

2-At the user’s request

This includes sharing data with:

*SPDY business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, SPDY may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate or other SPDY business partners and their users in connection with promotions, contests, or specialized services.

3-With the general public

Questions or comments from users submitted through public forums such as SPDY blogs and SPDY social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4- With the SPDY account owner

If a user requests services using an account owned by another party, we may share their service request, including real-time location data, with the owner of that account. This occurs, for example, when:

*A customer uses their employer’s SPDY for Business profile, such as when they request provider services arranged through employers account.
*A contractor provider uses an account owned by or associated with a SPDY partner contractor company.
*A customer user rider requests contractor services arranged by a friend or under a Family Profile

5- With SPDY subsidiaries and affiliates

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, SPDY processes and stores data in the United States on behalf of its international subsidiaries and affiliates.

6-With SPDY service providers and business partners

SPDY provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

*Payment processors and facilitators
*Background check and identity verification providers (contractor providers only)
*Cloud storage providers
*Google, in connection with the use of Google Maps in SPDY’s apps (see Google’s privacy policy for information on their collection and use of data)
*Facebook, in connection with the use of the Facebook Business Tools in SPDY’s apps and websites (see Facebook’s privacy policy for information on their collection and use of data)
*Marketing partners and marketing platform providers, including social media advertising services
*Data analytics providers
*Research partners, including those performing surveys or research projects in partnership with SPDY or on SPDY’s behalf
*Vendors that assist SPDY to enhance the safety and security of its apps
*Consultants, lawyers, accountants, and other professional service providers

7-For legal reasons or in the event of a dispute

SPDY may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect SPDY’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including order information, with the owner of that credit card.

Please see SPDY’s Guidelines for Law Enforcement Authorities for more information.

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8- With consent

SPDY may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

E.Data retention and deletion

SPDY retains user data for as long as necessary for the purposes described above.

Users may request deletion of their accounts at any time. SPDY may retain user data after a deletion request due to legal or regulatory requirements or for the reasons stated in this policy.
SPDY retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data.
Users may request deletion of their account at any time through the Settings > Privacy menus in the SPDY app, or through SPDY’s website (customer users here; contractor providers here).

Following an account deletion request, SPDY deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to contractor providers, this generally means that we retain their account and data for a minimum of 7 years after a deletion request. For customer users, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

F. Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of SPDY’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.
We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

A-To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

*User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their requests for contractor services and accounts.
*Background information, which is used to verify an applicant’s eligibility to be a contractor provider.
*Contractor provider location data, which we use to track location and availability of contractor providers and assist with navigation.
*Usage data, which is necessary to maintain, optimize, and enhance SPDY’s services, including to determine incentives, connect contractor providers and customer users, and calculate costs of assigned leads
*Transaction information
*Information relating to customer support

B- For purposes of the legitimate interests of SPDY or other parties

This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of SPDY’s apps. We also use usage data to prevent matching of contractor providers and customer users for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other users).

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing SPDY’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

C- To fulfill SPDY’s legal obligations

For example, SPDY is subject to laws and regulations in many cities and countries that require it to collect and retain data about our users’services, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

SPDY may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. SPDY may also share information with public health authorities where required or permitted by law. For more information about such sharing, please see SPDY’s Guidelines for Law Enforcement Authorities – United States, Guidelines for Law Enforcement Authorities – Outside the US, and Guidelines for Third Party Data Requests and Service of Legal Documents.

D- With consent SPDY may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.
A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

CHOICE AND TRANSPARENCY

SPDY enables users to access and control the data that SPDY collects, including through:

*In-app settings
*Device permissions
*In-app ratings pages
*Marketing opt-outs
SPDY also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that SPDY restrict its processing of user personal data.

A- Privacy settings

Settings menus in the SPDY app for customer users give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from SPDY. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.

*Location data
SPDY uses customer users’ device location services to make it easier to get contractor services whenever they need them. Location data helps improve our services, including proximity to contractor, navigation, and customer support. Customer users’ may enable or disallow SPDY to collect location data from their mobile devices through the Settings > Privacy menus in the SPDY app. Riders and delivery recipients can enable or disallow such collections through the settings on their mobile device.

*Share Live Location (Customer User)
Customer users’ who have enabled SPDY to collect location data from their mobile device may also enable SPDY to share their location with their contractor provider from the time the service is requested to the time of contractor provider arrival. This can help improve contractor provider and customer user connection times and reduce wasted time in finding customer user location.
Customers’ may enable or disable this feature through the Settings > Privacy menus in the SPDY app.
Riders may enable or disable this feature through the Settings > Privacy menus or the Safety Center in the SPDY app.

*Notifications: account and trip updates
SPDY provides users with trip status notifications and updates related to activity on their account. These notifications are a necessary part of using the SPDY app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menus in the SPDY app.

*Notifications: discounts and news
Users may enable SPDY to send push notifications about discounts and news from SPDY. Push notifications may be enabled or disabled through the Settings > Privacy menus in the SPDY app.

*Communications from contractor partners
Customer Users’ who have opted in to communications from contractor provider partners may stop sharing their data with each contractor provider partner in their SPDY account settings.

B- Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the SPDY app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the SPDY app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

C-Ratings look-up

After every trip, contractor providers and customer users are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, contractor ratings are available to customer users from whom they request contractor services, and customer users ratings are available to contractor providers.
This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for drivers and riders.
Customer users can see their average rating in the main menu of the SPDY app.
Contractor providers can see their average rating after tapping their profile photo in the SPDY provider app.

D- Marketing opt-outs

Users may opt out of receiving promotional emails from SPDY here. Users may also opt out of receiving emails and other messages from SPDY by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for services provided or information about their account.

E-User data requests

SPDY provides users with a variety of ways to learn about, control, and submit questions and comments about SPDY’s handling of their data. To make a request, please go here.

*Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.
*Receiving data: Users can ask for a copy of data that SPDY collects from them with their consent or as necessary to provide our services.
*Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in SPDY’s apps or contractor provider portal. They may also ask that SPDY change or update their data, including if they believe such data is inaccurate or incomplete.
*Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the SPDY app, or through SPDY’s website
*Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. SPDY may continue to process data after such objection or request to the extent required or permitted by law.

In addition, depending on their location, users may have the right to file a complaint relating to SPDY’s handling of their personal data with the data protection authority in their country.

UPDATES TO THIS NOTICE

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.