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Privacy policy

Preamble

With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender-specific.

Responsible

AdH GmbH
Alexander d’Huc
Lofererstraße 48
5760 Saalfeldem am Steinernen Meer
Austria
Email: info[@]adhgmbh[dot]com

Imprint

Authorized representatives: Alexander d’Huc

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data
  • Contact data
  • Content data
  • Usage data
  • Meta, communication, and procedural data
  • Log data

Categories of data subjects

  • Users

Purposes of processing

  • Communication
  • Security measures
  • Reach measurement
  • Feedback
  • Profiles with user-related information
  • Provision of our online offering and user-friendliness
  • Information technology infrastructure
  • Public relations

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.

  • Consent (Art. 6 (1) (a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Legitimate interests (Art. 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer, and automated decision-making in individual cases.

Note on the applicability of the GDPR and the Swiss DSG: This privacy policy serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data,” “overriding interest,” and “sensitive personal data” used in the Swiss FADP, the terms “processing” of “personal data,” “legitimate interest,” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DSG within the scope of its applicability.

Security measures

In accordance with legal requirements, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability, and separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted, and responses are made to threats to data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, agencies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This double safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.

We will inform you whether individual service providers are certified under the DPF and whether standard contractual clauses are in place. For more information on the DPF and a list of certified companies, please visit the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/.

Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, express consent, or transfers required by law. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked or there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing operations.

If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.

Storage and deletion of data: The following general periods apply to storage and archiving in accordance with Austrian law: 

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices, as well as all necessary work instructions and other organizational documents (Federal Tax Code (BAO §132), Commercial Code (UGB §§190-212)).
  • 6 years – Other business documents: Commercial or business letters received, copies of commercial or business letters sent, and other documents, provided they are relevant for tax purposes. These include, for example, hourly wage slips, operating statements, calculation documents, price tags, and payroll documents, unless they are already accounting documents and cash register receipts (Federal Tax Code (BAO §132), Commercial Code (UGB §§190-212)).
  • 3 years – Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
    Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Provision of online services and web hosting

Hoster

Our website is made available on the Internet by a service provider (provider or host). We use the services of easyname GmbH, Canettistraße 5/10, 1100 Wien, Austria. We have concluded a data processing agreement with our provider.

We process user data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.

  • Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved). Log data (e.g., log files relating to logins or the retrieval of data or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
    Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods, and services:

  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload (especially in the case of malicious attacks, known as DDoS attacks), and to ensure server utilization and stability; legal basis: legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes ( ) is excluded from deletion until the respective incident has been finally clarified.

Use of cookies

The term “cookies” refers to functions that store and read information on users’ end devices. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online offerings and to analyze visitor traffic. We use cookies in accordance with legal requirements. To do so, we obtain the consent of users in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of consent and which cookies are used.

Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. This allows, for example, the log-in status to be stored and preferred content to be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g., when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with the legal requirements, including through the privacy settings of their browser.

  • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, processes, and services:

  • BorlabsCookie: Consent management: Procedure for obtaining, logging, managing, and revoking consent, in particular for the use of cookies and similar technologies for storing, reading, and processing information on users’ end devices and for processing such information. Service provider: Execution on servers and/or computers under own data protection responsibility; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language, types of consent, and the time of their submission are stored on the server and in the cookie on the user’s device.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter referred to as “publication medium”). Readers’ data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication medium in this privacy policy.

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Web analysis, monitoring, and optimization

Web analysis (also known as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or invite reuse. It also enables us to identify areas that require optimization.

In addition to web analysis, we can also use test procedures to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes, and information may be stored in a browser or on a device and then read. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analysis, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).

  • Data subjects: Users (e.g., website visitors, users of online services).

  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.

  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods, and services:

  • Google Analytics: Wir verwenden Google Analytics zur Messung und Analyse der Nutzung unseres Onlineangebotes auf der Grundlage einer pseudonymen Nutzeridentifikationsnummer. Diese Identifikationsnummer enthält keine eindeutigen Daten, wie Namen oder E-Mail-Adressen. Sie dient dazu, Analyseinformationen einem Endgerät zuzuordnen, um zu erkennen, welche Inhalte die Nutzer innerhalb eines oder verschiedener Nutzungsvorgänge aufgerufen haben, welche Suchbegriffe sie verwendet haben, diese erneut aufgerufen haben oder mit unserem Onlineangebot interagiert haben. Ebenso werden der Zeitpunkt der Nutzung und deren Dauer gespeichert, sowie die Quellen der Nutzer, die auf unser Onlineangebot verweisen und technische Aspekte ihrer Endgeräte und Browser.

We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It is used to assign analysis information to a terminal device in order to identify which content users have accessed within one or more usage processes, which search terms they have used, accessed again, or interacted with our online offering. The time and duration of use are also stored, as well as the sources of users who refer to our online offering and technical aspects of their terminal devices and browsers.
Pseudonymous user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR);
Website: https://marketingplatform.google.com/intl/de/about/analytics/;

Security measures: IP masking (pseudonymization of the IP address);
Privacy policy: https://policies.google.com/privacy;
Data processing agreement: https://business.safety.google/adsprocessorterms/;
Basis for third-country transfers: Data Privacy Framework (DPF), (https://business.safety.google/adsprocessorterms);
Opt-Out option: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de,
settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
Further information: https://business.safety.google/adsservices/ (types of processing and data processed).

Presence on social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce user rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For this reason, cookies are usually stored on users’ computers, in which the usage behavior and interests of users are stored. In addition, data can also be stored in the usage profiles independently of the devices used by users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: Contact details (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Communication; feedback (e.g., collecting feedback via online form). Public relations.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods, and services:

• LinkedIn: Social network – Together with LinkedIn Ireland Unlimited Company, we are responsible for the collection (but not the further processing) of visitor data used to generate “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchy level, company size, and employment status. Information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: : https://www.linkedin.com/legal/privacy-policy.

We have entered into a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum, https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland; legal basis: legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standardvertragsklauseln (https://legal.linkedin.com/dpa).

Opt-out option (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Plug-ins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be graphics, videos, or city maps (hereinafter referred to collectively as “content”).

The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, but may also be linked to such information from other sources.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness.
    Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods, and services:

  • Google Fonts (provision on our own server): Provision of font files for the purpose of user-friendly presentation of our online offering; Service provider: Google Fonts are hosted on our server; no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
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