Privacy and Terms & Conditions

COOKIE POLICY 

1. Introduction

The website www.ri.ccr.com.br/ uses cookies to enhance performance and your experience when using our website.

Therefore, we seek to explain in a transparent manner how, when and why we use cookies.

By accessing our website, you consent to the use of cookies pursuant to this Policy.

If you do not agree to the use of cookies in this form, you may: (i) set your browser settings to not allow the use of cookies or (ii) not access our site.

We remind you that disabling the use of cookies may impact your experience when accessing our website.

For any questions or concerns about this Cookie Policy, you may contact us via e-mail: encarregado.dadospessoais@grupoccr.com.br.

2. What are cookies?

Cookies are digital files with small data fragments (and usually with a unique identity), which are stored on your device through your browser or application and which store information related to your preferences.

3. What are cookies used for?

Cookies are used to enhance your experience, both in terms of performance and usability, as the content made available will be directed to your needs and expectations.

Cookies allow our website to store information about your visit, your preferred language, your location, the recurrence of your sessions and other factors that we consider relevant to make your experience much more efficient.

Cookies may also be used to compile aggregate and anonymous statistics that allow users to understand how they use and interact with our website, as well as to improve its structures and content. Since they are anonymous statistics, we cannot identify you personally through this data.

The use of cookies is a common feature on any website nowadays. Its use does not jeopardize whatsoever the devices (computers, smartphones, tablets, etc.) in which they are stored.

4. What kind of cookies we use?

We use one type of cookies on our website: functionality cookies.

• Functionality Cookies: are used to ensure the availability of additional functionalities on the site or to save the preferences set by the user whenever using the same device.

5. How can I control or exclude the cookies?

Most Internet browsers are configured to automatically accept cookies.

You can change the settings to block the use of cookies or alert you when a cookie is being sent to your device. There are multiple methods to manage cookies.

By disabling cookies, you may not be able to access some areas of our website or you may not receive personalized information when you visit a website.

If you use different devices to access our site (computer, smartphone, tablet, etc.), you must ensure that each device’s browser is set to suit your preferences regarding cookies.

To allow you to manage your cookie preferences simply and intuitively from your browser, you can use one of the links below:

• For more information about “Private Browsing” and managing cookies from the Firefox browser, click here;
• For more information about “Incognito Browsing” and managing cookies from the Chrome browser, click here;
• For more information about “Private Browsing” and managing cookies from the Explorer browser, click here;
• For more information about “Private Browsing” and managing cookies from the Safari browser, click here;
• For more information about “Private Browsing” and managing cookies from the Opera browser, click here.

6. Detailed cookie information

Below are details on the use of cookies on our website, as well as the purposes of data processing that justify them.

6.1 Functionality Cookies

Update: March 04, 2020

POLÍTICA DE PRIVACIDADE E TRATAMENTO DE DADOS DA CCR S.A

1. INTRODUCTION

This Policy aims to demonstrate the commitment of

with the privacy and protection of your Data, in addition to establishing the rules on the Treatment of your Personal Data, within the scope of the services and functionalities of www.ri.ccr.com.br (“www.ri.ccr.com.br”), in accordance with the laws in force, with transparency and clarity with You and the market in general.

As a condition for the access and use of the exclusive functionalities at www.ri.ccr.com.br, You declare that You have read this Policy fully and carefully, being fully aware, thus granting Your free and express agreement with the terms stipulated herein, including the collection of the Data mentioned herein, as well as its use for the purposes specified below. If You do not agree with the provisions of this Policy, You may terminate Your access or use of www.ri.ccr.com.br.

SPECIFIC NOTE FOR CHILDREN AND ADOLESCENTS UNDER 16 YEARS

Please do not register at www.ri.ccr.com.br if you are under 16 years old.

SPECIFIC NOTE FOR LEGAL REPRESENTATIVES

Although we prohibit registration of children and adolescents under the age of 16, parents must supervise the online activities of their underage children.

All activities of adolescents over 16 and under 18 years of age must be assisted by their parents or legal representatives.

2. ABOUT THE DATA WE COLLECT
2.1. How we collect Data. Data, including Personal Data, may be collected when You submit it or when You interact with the www.ri.ccr.com.br and services, that includes:

2.2. Required data. Most of our services depend directly on some Data informed in the chart above, mainly Registration Data. If you choose not to provide some of this Data, we may be unable to provide all or part of our services to You.

2.3. Data Update and Accuracy. You are solely responsible for the accuracy, reliability or lack of it in relation to the Data you provide or for its out-date. Be aware that it is your responsibility to ensure accuracy or keep them updated.

2.3.1.Likewise, We are not be under any obligation to process or handle any of your Data if there is reason to believe that such processing or handling may attribute to CCR S.A. any violation of any applicable law or if you are using www.ri.ccr.com.br for any unlawful, illicit, or unethical purpose.

2.4. Data base. The database constituted through the collection of Data is our property and is under our responsibility, and its use, access and sharing, when necessary, will be done within the limits and purposes of the business described in this Policy.

2.5. Technologies used. We use the following technology(s):

(i). Functionality Cookies, it is up to you to configure your Internet browser if you want to block them. In this case, some features we offer may be limited.
2.5.1. All technologies used will always respect the current legislation and the terms of this Policy.

2.6. We do not use any type of solely automated decision that impacts You.

3. HOW WE SHARE DATA AND INFORMATION

3.1. We do not share your personal data with third parties, with the following exceptions:
(i). We may share your personal data when we have gained your consent to do so;
(ii). We may share your personal data with affiliates within Grupo CCR;
(iii). We may share your personal data with Group CCR’s service providers and business partners that process personal data on the Company’s behalf;
(iv). We may share your personal data with Group CCR’s service providers and business partners to fight toll evasion and other unlawful conduct that may cause serious damage, taking into consideration Grupo CCR’s interest and the protection of third parties.
(v). We may share your personal data with government bodies in compliance with legal and contractual obligations, including within the scope of concession, permission, and authorization contracts;
(vi). We may share your personal data with police authorities as required by law or when it is reasonably necessary, so as to protect the rights, properties and/or ensure the safety of users, third parties and/or Grupo CCR; and
(vii). We may share your personal data with competent legal, administrative and government authorities whenever there is a legal determination, request or court order;
(viii). We may share your personal data when it is required to perform commercial activities and to provide our services through our website https://ri.ccr.com.br/;
(ix). We may share your personal data automatically in case of corporate changes, such as consolidation, acquisition and merger.
3.2. Data Anonymization. For the purposes of market intelligence research, disclosure of data to the press, and advertising, the data provided by You will be shared anonymously, that is, in a way that does not allow its identification.

4. HOW WE PROTECT YOUR DATA AND YOU CAN ALSO PROTECT THEM

4.1. Measures that you should take. It is very important that you protect your Data from unauthorized access to your computer, account, or password, and make sure to always click “exit” when you exit from a shared computer. It is also very important that you know that we will never send electronic messages requesting data confirmation or with attachments that can be executed (extensions: exe, .com, among others) or even links for eventual downloads.

4.2. Access to Personal Data, proportionality and relevance. Internally, the Personal Data collected are only accessed by properly authorized professionals, respecting the principles of proportionality, necessity and relevance to the objectives of our business, in addition to the commitment to confidentiality and preservation of your privacy under this Policy.

4.3. External links. When you use www.ri.ccr.com.br, you may be conducted, via link to other portals or platforms, which may collect your information and have their own Data Processing Policy.

4.3.1. You are responsible for reading the Privacy and Data Processing Policies of such platforms or portals outside our environment and it is your responsibility to accept or reject it. We are not responsible for the privacy and data processing policies of third parties and the content of any websites content or services linked to environments other than ours.

4.3.2. Third-Party Services. We have business partners that can eventually offer services through features or websites that can be accessed from www.ri.ccr.com.br. The Data You provide to these partners will be the responsibility of these partners, thus being subject to their own data collection and use practices.

4.4. Third party processing under our guidelines. In case third party companies perform the Treatment on our behalf of any Personal Data we collect, they will respect the conditions here stipulated and the information security rules, mandatorily.

4.5. Data processing agents’ legal responsibilities. As controllers of your personal data, we are responsible for:
(i). recording data processing activities;
(ii). adopting technical and administrative security measures;
(iii). ensuring information security;
(iv). respecting holders’ rights;
(v). cooperating with the National Data Protection Authority; and
(vi). ensuring compliance with the principles and legal bases of the Brazilian General Data Protection Law (LGPD).
4.6. E-mail communication. To optimize and improve our communication, when we send an email to You we can receive a notification when they are opened, provided this possibility is available. It is important that you be aware because e-mails are sent only by the domain: @grupoccr.com.br.

5. HOW WE STORE YOUR PERSONAL DATA AND ACTIVITY REGISTERS

5.1. Collected personal data and recorded activities are stored in a secure and controlled environment within our local servers.

5.2. We keep your personal data for the period necessary to comply with the purposes set out in this Privacy Policy, including to comply with legal and contractual obligations within the scope of concession, permission and authorization contracts. For specific information on the data retention periods, you may email our Data Protection Officer at encarregado.dadospessoais@grupoccr.com.br.

5.3. The Data collected will be stored in our servers located in Brazil, as well as in an environment of use of resources or servers in the cloud (cloud computing), which may require a transfer and/or processing of this Data outside Brazil.

6. WHICH ARE YOUR RIGHTS AND HOW TO EXERCISE THEIR RIGHTS. Your Basic Rights. According to the LGPD, you are entitled to:
(i). request the confirmation of whether your personal data will be processed;
(ii). request the access to your personal data;
(iii). request the correction of incomplete, inaccurate or out-of-date personal data;
(iv). request the anonymization, blocking or deletion of unnecessary or excess data, as well as data that is not processed in compliance with the LGPD, if applicable;
(v). request the portability of your personal data to another provider, subject to the regulation of the National Data Protection Authority (ANPD);
(vi). request the erasure or anonymization of personal data processed on the basis of your consent, except where the law authorizes the retention of such data on another basis;
(vii). obtain information about the public and private entities with which we have shared your personal data;
(viii). to request information about the possibility of not consenting to the processing of your personal data and the consequences of this action; and
(ix). to withdraw your consent.

6.1. In case you request the deletion of your Personal Data, it may occur that the Data need to be kept for a period longer than the request for deletion, according to article 16 of the General Data Protection Regulation, in order to (i) fulfill a legal or regulatory obligation, (ii) study by a research organization, and (iii) transfer to a third party (respecting the data process). In all cases by anonymizing the Personal Data, as long as possible.

6.2. Once the maintenance period and the legal requirement have expired, the Personal Data will be deleted using safe disposal methods or used anonymously for statistical purposes.

7. INFORMATION ON THIS POLICY

7.1. Amendment of the content and updating. You hereby agree that we have the right to change the content of this Policy at any time, for any purpose or need, as appropriate and in accordance with the law or any rule that has equivalent legal force, and it is your responsibility to check it whenever you access www.ri.ccr.com.br or use our services.

7.1.2. If there are updates to this document that require further collection of consent, You will be notified through the contact channels You inform.

7.2. Non-applicability. Should any part of this Policy be deemed inapplicable by a Data Authority or court, the remaining conditions will remain in full force and effect.

7.3. Electronic Communication. You understand that any communication made by e-mail (to the addresses informed in your registration), SMS, instant communication applications or any other digital form, are also valid, effective and sufficient for the disclosure of any matter that refers to the services we provide, your Data, as well as the conditions of its provision or any other subject addressed therein, being the exception only that this Policy provides as such.

7.3.1. Communication Channels. In case of any doubt regarding the provisions of this Privacy and Data Processing Policy, you may contact through the Communication Channel E-mail: encarregado.dadospessoais@grupoccr.com.br.

7.4. Applicable law and jurisdiction. This Policy will be interpreted according to the Brazilian legislation, in the Portuguese language, being elected the forum of its domicile to settle any controversy that involves this document, except for specific reservation of personal, territorial or functional competence by the applicable legislation.

7.4.1. If You do not reside in Brazil, and because of the services offered by Us only in the national territory, you submit yourself to the Brazilian legislation, agreeing, therefore, that in case of litigation to be resolved, the lawsuit should be proposed in the Courts of São Paulo – SP.

8. GLOSSARY

8.1. For the purposes of this Policy, the following definitions and descriptions should be considered for your best understanding:

1. Data: Any information inserted, processed or transmitted through the www.ri.ccr.com.br.
2. Personal Information: Data related to an identified or identifiable individual.
3. Anonymization: Use of reasonable and available technical means at the time of the Treatment, by which a data loses the possibility of association, directly or indirectly, to an individual.
4. In charge (Data Protection Officer -DPO): Person designated by Us to act as a communication channel between the controller, the data owners and the National Data Protection Authority (ANPD)
5. Cloud Computing: Or cloud computing, is service virtualization technology built from the interconnection of more than one server via a common information network (e.g. the Internet), aiming to reduce costs and increase the availability of sustained services.
6. www.ri.ccr.com.br: Assigns the electronic address [•] and its subdomains.
7. Cookies: Some small files sent by www.ri.ccr.com.br, saved on your devices, which store the preferences and few other information, in order to customize your navigation according to your profile.
8. IP: Abbreviation for Internet Protocol; It is an alphanumeric combination that identifies users’ devices on the Internet;
9. Logs: Activities registers of any users who use www.ri.ccr.com.br.
10. Decisions only automated: These are decisions that affect a user that have been programmed to operate automatically, without the need for a human operation, based on automated processing of personal data.
11. Treatment: Every activity executed with Personal Data, such as the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

Update: November 23, 2021

Welcome to www.ri.ccr.com.br!

The Terms and Conditions of Use (“Terms”), a document that lists the main rules that shall be observed by everyone who accesses www.ri.ccr.com.br of CCR S.A. of the CCR Group responsible for the site or uses its functionalities (“You“), are presented below.

In order to access and use the features of www.ri.ccr.com.br, You declare that you have read the rules of this document fully and carefully, taking full knowledge of its content.

If You agree with the rules presented, you must declare yourself in this sense when registering at www.ri.ccr.com.br, by selecting the checkbox “I have read, understood and agree with the Terms of Use of www.ri.ccr.com.br”, expressing your free, express and informed consent.

If You disagree with any of the provisions of these Terms, please do not access or use the services of www.ri.ccr.com.br.

1. FUNCTIONALITIES OF WWW.RI.CCR.COM.BR
   1. Functionalities. The website www.ri.ccr.com.br is a platform for users to become acquainted with the CCR Group and/or the concessionaire, obtain information on the particularities of the business and access relevant documents.
   2. Operation Mode of www.ri.ccr.com.br. Users may interact with the CCR Group and/or the concessionaire by sending messages to the Contact Us and Ombudsman.
   3. Majority. The access and use of www.ri.ccr.com.br is free for all, however some functionalities such as registration in certain environments may require acts carried out by people over 18 (eighteen) years old, according to the legislation in force.
      1. In these cases, the legal representatives shall supervise and represent children and adolescents under the age of 16 (sixteen) and assist teenagers over the age of 16 (sixteen) and under the age of 18 (eighteen), whenever applicable.
      2. CCR S.A. may decline, not approve, cancel or limit any requests if You do not provide correct data.
      3. The same shall apply while using www.ri.ccr.com.br, if it is used in any fraudulent manner, as well as if it attempts or violates these Terms or any current legislation.
   4. Eligibility. CCR S.A. may modify the eligibility criteria for access and use of www.ri.ccr.com.br at any time and at its discretion without the need of prior communication or notice to You or any third party.
   5. E-mails. By providing your data at www.ri.ccr.com.br, You agree that you may receive in the e-mail and/or phone informed in the registration, messages with warnings and advertising content of products or services of CCR S.A. and its partners. You will always have the option of not receiving such communications through www.ri.ccr.com.br.
   6. Introduction to www.ri.ccr.com.br. The webssite www.ri.ccr.com.br and its functionalities are available to You as it is and can be constantly improved and updated.
      1. In this case CCR S.A. is committed to preserving the functionality of www.ri.ccr.com.br with reasonable efforts, with Links unbroken and using Layout that respects the usability and navigability, whenever possible, as well as displaying the functionalities in a clear, complete, precise and sufficient way so that there is a correct perception of what is being practiced.
2. USE OF WWW.RI.CCR.COM.BR
   1. Integrity of www.ri.ccr.com.br. You agree not to access the programming areas of www.ri.ccr.com.br, its database, source codes or any other set of data available in these environments, as well as not to reverse engineer, translate, decompile, copy, modify, reproduce, rent, sublicense, publish, disseminate, transmit, lend, distribute or otherwise dispose of the functionalities of www.ri.ccr.com.br inappropriately.
   2. Non-mining. It is not authorized the use of data mining software from www.ri.ccr.com.br, of any type or species, as well as any other not typified here that acts in a similar way.
   3. Compensation. In the case of damages to CCR S.A. or third parties, the responsible party undertakes to incur all obligations to compensate the injured party, including those whose origin is from acts performed through its Access Account, accepting the passive pole of lawsuit or administrative procedure and requesting the exclusion of CCR S.A., and shall fully assume the expenses and procedural costs related thereto, making it free of losses and liabilities.
3. CONTENT, PROVIDED DATA AND INTELLECTUAL PROPERTY
   1. Contents. Unless otherwise stated in these Terms, all information, news, images, illustrations, icons, technologies, brands and other audiovisual or sound content, including the software of www.ri.ccr.com.br, available in any language or form, are the exclusive property of CCR S.A. or licensed by third parties to CCR S.A. (“Content”). The use of www.ri.ccr.com.br does not represent any assumption of transfer or license of such property. For this reason, You shall not commercialize the Content in whole or in part by any means, whether onerous or not, knowing that if you do so you may be punished both civilly and criminally by CCR S.A. and/or by any third party owner of the Content.
      1. The occasional removal, blocking or suspension of any Content or functionality of www.ri.ccr.com.br as a result of any claim, shall always be understood as a demonstration of good faith and intention of friendly resolution of conflicts, never as recognition of guilt or of any infraction by CCR S.A. to the right of a third party.
   2. Your Data. You are and will continue to be the holder and owner of all data, information, texts, images, messages or any other material in any form submitted and/or shared on www.ri.ccr.com.br by You (“Your Data”) as well as being solely responsible for them, and You are exclusively responsible for respecting the intellectual property of third parties or any other related rights.
   3. Legality of Your Data. CCR S.A. will not be under any obligation to process or handle any of Your Data if there is reason to believe that such processing or handling may attribute to CCR S.A. any violation of any applicable law or that www.ri.ccr.com.br is being used, in CCR S.A.‘s sole discretion, for any unlawful, illicit, or unethical purpose.
   4. No guarantees regarding Your Data and Content. CCR S.A. does not guarantee the quality, coherence, integrity, form, updating or source of the Content or Your Data, because it does not control, verify or judge this Content and Your Data. CCR S.A. is not responsible, therefore, for any untruthfulness, out-of-date or error in this Content or Your Data, and is not responsible for any damages arising from this Content, in any way.
      1. You shall in any case not make any decision, whether onerous or not, based entirely on the Content or any functionality of www.ri.ccr.com.br.
   5. Storage. CCR S.A. does not provide and www.ri.ccr.com.br does not constitute a storage service, therefore CCR S.A. has no obligation to store, retain or provide You or any third party with copies of Your Data or any Content.
   6. Algorithmic intelligence. The website www.ri.ccr.com.br, in an impersonal and automatic way, can apply statistical models and algorithmic intelligence to index, filter and organize the Content or Your Data, generated or shared through www.ri.ccr.com.br.
      1. You hereby declare that CCR S.A., if not at its sole discretion, will not disclose or provide to You or any third party any systemic or algorithmic information related to www.ri.ccr.com.br.
4. YOUR PRIVACY AND PERSONAL INFORMATION
   1. Personal Information. If You process or transmit in the scope of www.ri.ccr.com.br information regarding an identified or identifiable individual (“Personal Data”), You will be solely responsible for collecting the necessary authorizations before the holder of the Personal Data.
      1. CCR S.A. will monitor, by proper means, its own compliance with the respective Personal Data protection obligations, if applicable.
   2. Registrations. CCR S.A. may register all activities performed by You at www.ri.ccr.com.br, including identification data, the device and the connection used (“Registers”).
   3. Purpose of the Collection. The Registers can be used for the purpose of: (i) identify and serve You (ii) comply with the obligations of these Terms (iii) improve www.ri.ccr.com.br; (iv) protect rights and obligations related to the use of www.ri.ccr.com.br; and (v) comply with a judicial and/or administrative authority order.
5. EXEMPTION AND SCOPE OF LIABILITY
   1. CCR S.A. strives to maintain the continuous and permanent availability of www.ri.ccr.com.br. However, some temporary unavailability may occur due to necessary maintenance or even caused by major force, such as natural disasters, failures in communication systems and Internet access, intrusive cyber attacks, or any third party facts that are beyond the scope of surveillance and responsibility of CCR S.A.
      1. If this occurs, CCR S.A. will do all possible to restore access to www.ri.ccr.com.br as fast as possible, within the technical limitations of its services and third-party services, on which it depends to be online. For this reason, You are aware that you will not be able to claim compensation or reparation for damages in the event that www.ri.ccr.com.br is down, regardless of the reason.
      2. Any maintenance procedures that cause the unavailability of www.ri.ccr.com.br for long periods will be informed through the official communication channels of CCR S.A.
   2. Without prejudice to other conditions of these Terms, CCR S.A. is not responsible:

1. For any problems, bugs, glitches or improper functioning that occur in your devices and equipment;
2. For any direct or indirect damage caused by third party events, for example, but not limited to hacker attacks, system, server or internet connection failures, including software actions that may in some way damage your physical or logical assets as a result of accessing, using or browsing www.ri.ccr.com.br, as well as the transfer of data, files, images, texts, audios or videos contained at www.ri.ccr.com.br;
3. For navigating any external links available at www.ri.ccr.com.br, your duties are to read the Terms and Conditions of Use and Privacy Policy of the resource accessed and act as determined; and
4. For verifying, controlling, approving or guaranteeing the adequacy or accuracy of the information or data made available in such links, therefore, they are not responsible for prejudices, losses or damages occurred by the visit of such sites, being the interested party responsible for verifying the reliability of the information and data displayed there before making any decision or performing any act.

6. OTHER PROVISIONS
   1. Communication Channel. You may use the Communication Channels available at www.ri.ccr.com.br whenever you have any questions, suggestions or complaints, either about www.ri.ccr.com.br or these Terms.
   2. Terms update. These Terms are subject to continuous improvement and enhancement. Therefore, CCR S.A. has the right to modify them at any time, according to their purpose or convenience, such as for adequacy and legal compliance of a provision of law or regulation that has equivalent legal force, including regulatory agencies, i.e., You should check it whenever you access www.ri.ccr.com.br.
      1. In case of updates to these Terms, CCR S.A. will notify You by the tools available at www.ri.ccr.com.br or by the contact means provided by You.
      2. By browsing www.ri.ccr.com.br and using its functionalities, You agree to follow the Terms in force on the date of access. Therefore, it is recommended that You maintain yourself updated of the conditions in force.
   3. Novation and resignation. Failure to comply with any of the conditions of these Terms shall not constitute a waiver or novation, nor shall it prevent CCR S.A. from demanding these conditions at any time.
   4. Nullity. If any provision of these Terms is held to be unenforceable or void, the remainder shall continue in full force and effect.
   5. Communication. You hereby agree that any communication made by e-mail (to the e-mail address informed in your registration) is valid, effective and sufficient for the disclosure of any matter relating to www.ri.ccr.com.br.
   6. Date and Time. The website www.ri.ccr.com.br is based on the official date and time of Brasilia (UTC/GMT -03:00).
   7. Applicable law and jurisdiction. These Terms will be interpreted according to the Brazilian legislation, in the Portuguese language, and it is elected the forum of the district of your domicile (You) to settle any controversy, unless the applicable legislation specifically reserves other personal, territorial or functional competence.
7. GLOSSARY

1. CCR S.A.: CCR S.A., a private legal entity, headquartered at Avenida Chedid Jafet, 222, Bloco B, 5º andar, Bairro Vila Olímpia, in the city and state of São Paulo, registered in the Corporate Taxpayer’s ID (CNPJ/MF) under no. 02.846.056/0001-97, in this document represented in the form foreseen in its Bylaws

5. www.ri.ccr.com.br: Online tool, made available by CCR S.A. for the website is a platform for users to become acquainted with the CCR Group and/or the concessionaire, obtain information on the particularities of the business and access relevant documents.
6. Anti-Spam: System that prevents unsolicited mail, such as massive advertising, by blocking messages or moving them to a specific folder.
7. Communication Channels: invest@grupoccr.com.br
8. Layout: A combination of aesthetics, design and processes of www.ri.ccr.com.br.
9. Link: Terms for Internet address.

Update: May 08, 2021