We ask that you read this privacy statement carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and, where applicable, supervisory authorities in the event you have a complaint.
INTRODUCTION
Living Church of God (International), Inc. (subsisting under the laws of North Carolina, United States) (NC SOSID: 0783290) (“Living Church of God USA”) and its international affiliated religious or charitable organizations (together referred to as the “Living Church of God”) operate under the Living Church of God name. At Living Church of God we respect your privacy and the laws governing it and are committed to protecting and safeguarding your personal information.
Personal information that is voluntarily submitted to the Living Church of God is not shared with entities outside of the Living Church of God other than appropriate service providers who assist the Living Church of God in carrying out the outreach and operational functions of the Living Church of God. Unless otherwise provided in this privacy statement, such personal information is not sold or transferred outside the control of the Living Church of God or its successors.
This privacy statement will inform you as to how we look after your personal information when you visit our website (regardless of where you visit it from) or provide us with, or we collect, your personal information online, via electronic communication, or otherwise and, where applicable, tell you about your privacy rights and how the law protects you.
This privacy statement is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of this privacy statement here www.lcg.org/legal/privacy-statement.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL INFORMATION COLLECTED
4. HOW WE USE YOUR PERSONAL INFORMATION
5. DISCLOSURES OF YOUR PERSONAL INFORMATION
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY STATEMENT
This privacy statement aims to give you information on how the Living Church of God collects and processes your personal information through your use of this website or personal information you provide us with or we collect online, via electronic communication, or otherwise, including any data you may provide through this website when you sign up to or request our publications (including Tomorrow’s World and News & Prophecy), subscribe to or request or order a product or service from us or register or take part in any event or activity organized by us or on our behalf.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy statement together with any other privacy statement or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy statement supplements the other notices and is not intended to override them.
CONTROLLER
The Living Church of God is made up of different legal entities and organisations, details of which can be found here. This privacy statement is issued on behalf of the Living Church of God so when we mention the Living Church of God, “we”, “us” or “our” in this privacy statement, we are referring to the relevant entities or organizations forming part of the Living Church of God responsible for processing your data as data controllers in their own right. On occasions, for certain processing activities, one of the entity or organisation forming part of the Living Church of God may act as a data processor for another entity and organisation forming part of the Living Church of God.
Certain personal information that we collect and process is regulated by a) the European Union’s General Data Protection Regulation (“GDPR”) which applies across the European Union and to the extent such regulation is adopted by the member countries of the European Economic Area (“EEA”) by such EEA countries (“EEA Personal Information”) and b) the GDPR as transposed into UK national law by the operation of section 3 of the EU (Withdrawal) Act 2018 (the “UK GDPR”), the Data Protection Act 2018 and any other relevant data privacy legislation in the UK (“UK Personal Information”). We are responsible as ‘controller’ of that EEA or UK Personal Information for the purposes of those laws.
Where appropriate, we will let you know which entity or organization will be the controller for your EEA/UK Personal Information (as applicable) when you sign up to or request our publications (including Tomorrow’s World and News & Prophecy), subscribe to or request or order a product or service from us or take part in any event or activity organized by us or on our behalf. Living Church of God USA is the controller and responsible for this website and any EEA or UK Personal Information that is provided to us via this website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
CONTACT DETAILS
Our full details are:
Full name of legal entity: Living Church of God (International), Inc.
Title of data privacy manager: Co-Data Privacy Manager(s)
Email address: [email protected]
Postal address: P.O. Box 3810
Charlotte, NC 28227-7705
APPOINTED REPRESENTATIVE IN THE EUROPEAN ECONOMIC AREA AND UK (“EEA or UK”)
Under Article 27 of the GDPR (in the UK, the GDPR as transposed into UK national law by the operation of section 3 of the EU (Withdrawal) Act 2018) we are required to provide a contact in the UK and EEA that will act as our data protection representative. In respect of the EEA Personal Information that we collect or otherwise process, you have the right to make a complaint at any time to your local data protection regulator. We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance.
As Living Church of God USA is based in the United States, and Living Church of God UK is based in the UK, the following companies have been appointed to act as our representative in the UK and in the EEA:
Our Representative in the UK is:
Company name: GDPR Local Ltd
Contact name: Adam Brogden
Email: [email protected]
UK Office Tel: + 441 772 217 800
Reporting website: https://livingchurchofgodinternationalinclivingchurchofgod.gdprlocal.com/eu
Reporting email: [email protected]
Address: GDPR Local Ltd 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
For more information about your rights please refer to: https://ico.org.uk/your-data-matters/
Our Representative in the EEA is:
Company name: INSTANT EU GDPR REPRESENTATIVE LTD
Contact name: Adam Brogden
Email: [email protected]
Dublin Office tel: +353 1 5549700
Reporting website: https://livingchurchofgodinternationalinclivingchurchofgod.gdprlocal.com/eu
Reporting email: [email protected]
Address: INSTANT EU GDPR REPRESENTATIVE LTD, Office 2 - 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland
These companies will act on our behalf to resolve any issue you might have so don't hesitate to contact them with any concerns you might have.
For more information about your rights please refer to: https://gdpr-info.eu/chapter-3/
CHANGES TO THE PRIVACY STATEMENT AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 28 December 2020 and historic versions are archived and can be obtained by contacting us.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal information or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect personal information of our adherents, volunteer workers, supporters, donors, enquirers and others who access, request, subscribe to or order our products or services or attend our events or activities (together the “Participants”).
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, family relationships with other Participants, adult/child status, title and date of birth.
- Contact Data includes delivery address, email address and telephone numbers.
- Participation Data includes details of your participation or involvement with the Living Church of God or any of its events or activities, details relating to your health, spiritual needs and sex life and other personal matters and needs and details of any criminal convictions and offences.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products or services you have ordered or subscribed to or requested from us or activities or events you have participated in or intend to participate.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or any software applications we make available to you.
- Usage Data includes information about how you use our website and products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us, your communication preferences and information in connection with the fulfilment of your request for our marketing information.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy statement.
We may also collect and process Special Categories of Personal information, as defined in the GDPR and the UK GDPR. This personal information may include religious or philosophical beliefs, sex life, sexual orientation, information about your health and about your criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
Where we need to collect personal information by law, or under the terms of a contract we have with you, or when we have to deal with your request or enquiries, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or deal with your request or enquiries (for example, to provide you with products or services) or provide you with any support you are seeking from us. In this case, we may have to cancel the contract or not provide you with a product or service or support you have requested or subscribed to, ordered or need from us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or applications or by communicating with us by post, phone, email or otherwise. This includes personal information you provide or we collect in connection with:
- dealing with your requests/enquiries and providing you with our products or services and support;
- the furtherance of our aims, objective (including fulfilling our mandate of Christian Evangelism and discipleship), operations and activities and events;
- counselling, guidance, discipleship, mentoring and follow-up activities requested by or provided to you or our Participants;
- becoming a volunteer worker for the Living Church of God and/or in connection with the support and our guidance we provide to such volunteer workers;
- registration and provision of online bible courses;
- the facilitation of one to one sessions with pastors or ministers as requested by you;
- donations, including administering, and maintaining a record of, donations;
- becoming a Participant and/or in connection with the support we provide to Participants;
- marketing and provision of publications requested by or sent to you;
- registering to attend or attending our events (including festivals, camps, etc.) or activities;
- giving us feedback;
- any tax and gift aid matters relating to your donations, contributions and other payments you make to us;
- any communications we have with each other;
- ensuring we do not send you unwanted information once you have informed us that you do not wish to receive it;
- analyzing and improving our products, services, publications, events and other activities; or
- compliance with any legal or regulatory requirements.
- Automated technologies or interactions. As you interact with our website or software applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy http://www.lcg.org/legal/cookie-policy for further details.
- Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
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Technical Data from analytics providers such as Google based outside the EEA or UK;
Non‑identifying Information – Like many other organizations’ websites, ours automatically collect certain non‑identifying information regarding website users, such as the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access this website, the Internet address of the website from which you linked directly to this website, the operating system you are using, the sections of this website you visit, the website pages read and images viewed, and the materials you post to or download from this website. This non‑identifying information is used for this website and system administration purposes and to improve this website. Your non‑identifying information may be disclosed to others and permanently archived for future use in order to facilitate your online experience and to gather broad demographic information. We make no attempt to link this information with the identity of individuals visiting this website.
We have also implemented the Google Analytics Demographics and Interest Reporting Feature of Google Analytics for Display Advertisers at our website services – This third party service uses various technologies, including cookies and other anonymous identifiers, to collect and store information about your use of our website services and third party sites. Data collected through the Google Analytics for Display Advertisers service allows Google to provide us with demographic information about our audience, such as age, gender and interests. We use this non-identifying information to better understand our audience, to improve our website services and tailor our website services to our audience.
For more information on how Google Analytics collects and processes data, see “How Google uses data when you use our partners’ sites or apps” at https://www.google.com/policies/privacy/partners .
If you do not wish your data to be used by Google Analytics, you may install the Google Analytics Opt Out Browser Add on at https://tools.google.com/dlpage/gaoptout.
You can also visit Ad Settings to opt-out of Google Analytics for Display Advertising and edit the settings that control the types of Google ads you see on others’ sites here {links to https://www.google.com/settings/ads/anonymous}.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Authorize.net (based in the United States) based outside the EEA or UK.
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4. HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where you have given us your explicit consent or consent by voluntarily providing your personal information in connection with a purpose or request or event or activity.
- Subject to any local law restrictions, we may process your Special Categories of personal information for our legitimate activities.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Legitimate Interest means the interest of our church and as a ministry in conducting and managing our aims, objectives and operations to enable us to give you the best service/product or support and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Where the processing of your personal information by us is based solely on your consent, subject to applicable law, you have the right to withdraw your consent by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION
We have set out below, in a table format, a description of all the ways we plan to use your EEA/UK Personal Information, and which of the legal bases we rely on to do so.
Note that we may process your EEA/UK Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your EEA/UK Personal Information where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
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To manage our relationship with you which will include:
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To administer and protect our aims, objectives, principles, operations, activities, Participants and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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To deliver relevant website content and publications to you and measure or understand the effectiveness of the publications sent to you or events or activities you attend or subscribe to |
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To use data analytics to improve our website, activities and operations, products/services, events, marketing, Participant relationships and experiences |
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Necessary for our legitimate interests (to define types of Participants for our products and services, to keep our website updated and relevant, to develop our outreach and operations as a Church and ministry, and to inform our marketing strategy) |
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To send information or make suggestions and recommendations to you about products or services or publications or events or activities that may be of interest to you |
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Necessary for our legitimate interests (to develop our products/services, publications, events, activities and expand our outreach and operations as a Church and ministry,) |
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To comply with legal and regulatory requirements (including for the prevention and detection of crime) |
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Any bank account or payment card details that you provide to us for billing and related purposes is shared with Authorize.net, a United States based payment services provider. You consent to sharing your Contact Data and Financial Data with Authorize.net who will process and store this information. You can find more information on Authorize.net here https://www.authorize.net/company/privacy/.
MARKETING
We strive to provide you with choices regarding certain personal information uses, particularly around marketing, events and activities. You may communicate your updated information and/or preferences by Contacting us.
PROMOTIONAL OFFERS FROM US
We may use your Identity Data, Contact Data, Usage Data and Participation Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which publications, products, services, events, activities and offers may be relevant for you (we call this marketing).
You may receive marketing communications (including being added as a subscriber to our Tomorrow’s World Magazine and/or our News & Prophecy newsletter) from us if you are a Participant or subscribed to, requested or ordered products or services or publications from us or if you provided us with your details when you made a donation or registered for an event or activity and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We never trade, sell or share your information with any unrelated parties except as necessary or appropriate to conduct our legal, administrative and operational activities, subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party, or to further your interests or as permitted or required by law or as authorized or directed by you.
OPTING OUT
You can ask us to stop sending you marketing messages or information at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
Where you opt out of receiving these marketing messages or publications, this will not apply to personal information collected by or provided to us in connection with a specific purpose, request, order, event or activity or any dealings with you.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see http://www.lcg.org/legal/cookie-policy.
CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose to do so, or is a use otherwise permitted by law.
Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal information with the parties set out below (who may be based outside the EEA or UK) for the purposes set out in paragraph 4 above.
- Organizations which form part of the Living Church of God, in particular in connection with activities undertaken jointly or in common with such organizations and/or provide IT and system administration services and undertake management reporting.
- Third parties such as:
- Service providers who provide IT and system administration services, billing and/or payment services, email or identity verification services, postal services or e-communication services. Please see paragraph 4 above for information on Authorize.net.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- IRS, HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our administration or operations or our assets.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
This website is hosted in the United States. Personal information that is voluntarily provided on or via this website or online, via electronic communication, or otherwise to the Living Church of God, may be maintained or accessed in servers or files located in the United States, which the European Commission has not deemed to provide "adequate" privacy safeguards. If you do not consent to having your personal information processed and stored in the United States, please do not provide it to the Living Church of God. By voluntarily providing your personal information to or via this website or any organisation forming part of the Living Church of God, you consent to its transfer, processing and storage in the United States.
Organizations forming part of the Living Church of God based outside the United States (including those based in the EEA or UK) (“Regional Offices”) may share your personal information that they collect with Living Church of God USA in connection with support services provided by Living Church of God USA on behalf of such Regional Offices. Regional Offices may also share your personal information with each other. This may involve transferring your EEA/UK Personal Information outside the EEA or UK (as applicable).
Many of our third party service providers are based outside the EEA or UK so their processing of your EEA or UK Personal Information will involve a transfer of data outside the EEA or UK, as applicable.
Whenever we transfer your EEA/UK Personal Information out of the EEA or UK (as applicable), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your EEA or UK Personal Information to countries that have been deemed to provide an adequate level of protection for EEA or UK Personal Information by the European Commission.
- Where we use certain providers, we may use specific standard contractual clauses approved by the European Commission which give EEA/UK Personal Information the same protection it has in Europe or the UK.
- Please Contact us if you want further information on the specific mechanism used by us when transferring your EEA/UK Personal Information out of the EEA or UK (as applicable).
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, volunteer workers, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR?
We will only retain your EEA/UK Personal Information while you are a Participant or for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, any legitimate administrative or operational purposes, your requirements, or reporting requirements. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements and your expectations and requirements.
In view of the nature of our organizations and their activities, we endeavour to maintain a lifelong relationship with our Participants. Accordingly, unless you object to our retention of your personal information, we may retain a Participant’s EEA/UK Personal Information for a period of up to 4 years following our last communication with such Participant or such other longer period necessary to satisfy any legal, accounting or any legitimate administrative or operational purposes.
If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
When it is no longer necessary to retain your EEA/UK Personal Information, we will securely delete or in some circumstances we may anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under the relevant privacy laws of the EEA or the UK (as applicable) in respect of your EEA/UK Personal Information you may have a number of important rights. In summary, those may include rights to:
- access to your Personal Information and to certain other supplementary information that this privacy statement is already designed to address.
- require us to correct any mistakes in your Personal Information which we hold.
- require the erasure of Personal Information concerning you in certain situations.
- receive the Personal Information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations.
- object at any time to processing of Personal Information concerning you for direct marketing.
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
- object in certain other situations to our continued processing of your Personal Information.
- otherwise restrict our processing of your Personal Information in certain circumstances.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the European Union’s General Data Protection Regulation.
If you would like to exercise any of those rights, please:
Contact us and
- let us have enough information to identify you,
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates.
If you would like to unsubscribe from any email publication you can also click on the ‘unsubscribe’ button at the bottom of the relevant email publication. It may take up to 20 days for this to take place.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.