Jürgen Liebisch GmbH
legally represented by the managing director: Berkefeld, Guido
Phone: +49 40 253 066-0
Data Protection Officer
Phone: +49 175 820 36 42
Status: May 2023
- Basic information on data processing and legal basis
- Types of data processed / categories of data subjects
- Safety measures
- Disclosure of data to third parties and third-party providers
- Use of usercentrics
- Provision of contractual services
- Web hosting
- Cookies & Reach Measurement
- Reach analysis with Matomo
- Application platform
- Processing of your personal data on Facebook and Instagram
- LinkedIn profile
- Rights of the data subject
- Data deletion
- Right of objection
1. Basic information on data processing and legal basis
1.2. The terms used, such as "personal data" or their "processing" refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
2. Types of data processed / categories of data subjects
2.1. The personal data of users processed within the framework of this online offer include:
- Inventory data (e.g., names and addresses of customers),
- Contact data (e.g., email, phone numbers),
- Communication data,
- Contract data (e.g., services used, names of clerks)
- Usage data (e.g., the web pages visited on our website, interest in our products)
- Meta/communication data (e.g., device information, IP addresses) and
- Content data (e.g., entries in the contact form).
2.2. The term "user" includes all categories of persons affected by data processing. They include our business partners, customers, interested parties and other visitors to our online offering. The terms used are to be understood as gender-neutral.
2.3. We process users' personal data only in compliance with the relevant data protection provisions. This means that user data will only be processed if we are legally permitted to do so, in particular if the data processing is necessary or legally required to provide our contractual services (e.g., processing of orders) and online services, or if we have the consent of the user, as well as on the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation and security of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR, in particular in the case of range measurement, creation of profiles for advertising and marketing purposes as well as collection of access data and use of third-party services.
2.4. We point out that the legal basis for the consents Art. 6 para. 1 lit. a. and Art. 7 GDPR, the legal basis for the processing for the fulfillment of our services and implementation of contractual measures Art. 6 para. 1 lit. b. GDPR, the legal basis for processing to fulfill our legal obligations Art. 6 para. 1 lit. c. GDPR, and the legal basis for processing to protect our legitimate interests Art. 6 para. 1 lit. f. GDPR is.
2.5. The following persons are affected by the data processing:
- contract and business partners,
- users of our online offering,
- Interested parties who are interested in our online offer or contact us for other reasons and
3. Security measures
We take appropriate organizational, contractual and technical security measures in the sense of Art 32. GDPR according to the state of the art, taking into account the implementation costs and the nature, scope, circumstances and purposes of the data processing, as well as the varying likelihood and severity of the risk to the rights and freedoms, in order to ensure an adequate level of protection for your data. We hereby ensure compliance with the provisions of data protection laws and protect this data against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.
3.1. The security measures include in particular the encrypted transmission of data between your browser and our server. You can recognize such encrypted connections by the fact that the URL in the address bar of your browser begins with "https://". This is a communication protocol with which data can be transmitted in a tap-proof manner as part of a transport encryption.
4. Disclosure of data to third parties
4.1. Data is only passed on to third parties within the framework of legal requirements. We only pass on user data to third parties if this is necessary, for example, on the basis of art. 6 Para. 1 lit. b GDPR for contractual purposes or on the basis of legitimate interests pursuant to Art. 6 Para. 1 lit. f. GDPR in the economic and effective operation of our business
4.2. We only use subcontractors to provide our services if we have taken suitable legal precautions and appropriate technical and organizational measures to ensure the protection of the personal data processed in accordance with the relevant statutory provisions.
4.3. Insofar as content, tools or other means described within the scope of this data protection declaration are used by other providers (hereinafter collectively referred to as "third-party providers"), we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
4.4. If we use a third-party provider whose registered office is located in a third country (outside the European Union (EU) or the European Economic Area), it must be assumed that data is transferred to the countries where the third-party provider is based. The transfer of data to third countries only takes place if there is an adequate level of data protection, user consent or otherwise legal permission.
5. Use of Usercentrics
5.1. We use the services of Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, Germany (hereinafter "Usercentrics") to obtain and manage consent in relation to cookies and other technologies used on our website. Usercentrics supports us in maintaining your data protection and complying with the requirements of the General Data Protection Regulation (GDPR).
5.3. The data processing is carried out on the basis of Art. 6 (1) lit. c GDPR for the fulfillment of the legal obligation incumbent upon us. As the Controller, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.
5.4. We have concluded an order processing agreement with Usercentrics, by which we oblige Usercentrics to protect the data of visitors to our website and not to pass it on to third parties.
6. Provision of contractual services
6.1. We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 para. 1 lit b. GDPR. We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g., in online forms, by means of special marking (e.g., colors) or symbols (e.g., asterisks or similar), or in person. Within the scope of applicable law, we only disclose this data to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with your consent (e.g., to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities).
6.2. We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after the expiry of 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner within the scope of a contractual relationship in accordance with the requirements of the contract, generally after the contractual services have been performed.
7. Getting in touch
7.1. When contacting us (via contact form or e-mail), the user's details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) lit. b GDPR. Here, we only process the data that we need to process your request.
7.2. User information may be stored in our Customer Relationship Management System ("CRM System") or comparable inquiry organization.
8. Web hosting
8.1. In order to provide our online offer securely and efficiently, we use the services of Mittwald CM Service GmbH & Co.KG as a web hosting provider, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
8.2. We collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
8.3. Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.
8.4. The web hosting services also include sending, receiving as well as storing e-mails. For these purposes, the addresses of the recipients and senders, but also further information about the e-mail dispatch (e.g. the providers involved), including contents of the respective e-mails are processed. Even though our e-mail communications have transport route encryption, they are not encrypted on the servers from which they are sent and received. The content of e-mail communications is therefore fundamentally susceptible to manipulation.
9. Cookies & Reach Measurement
- A distinction must be made between cookies that are set by the website operator when you visit a website (also known as "first-party cookies") and cookies that are set by third-party providers (also known as "third-party cookies"). We only have technical control over the first-mentioned cookies. We further differiate between the following cookies.
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
- Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
- Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g., to store logins or other user inputs or for security reasons).
- Statistical, marketing and personalization cookies: Cookies are also generally used in the context of range measurement and when a user's interests or behavior (e.g., viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as "tracking", i.e., tracking the potential interests of users. We will inform you separately about the use of "tracking" technologies in our data protection declaration or in the context of obtaining consent.
9.2. If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser.
10. Reach analysis with Matomo
10.1. Based on your consent, we use Matomo, an open-source software for statistical evaluation of user access, for the analysis, optimization and economic operation of our online offer. The service is hosted by ourselves.
10.2. The IP address of the users is shortened before it is stored. Matomo uses temporary 1st-party cookies, which are stored on the user's computer and which enable an analysis of the use of this online offer by the user. The cookies are deleted after the end of their use of our online offer. Thereby, pseudonymous usage profiles of the users can be created from the processed data.
10.3. The information generated by the cookie about your use of this online offer is stored on our server and not passed on to third parties. Specifically, this is the following data: Anonymized IP addresses by removing the last 2 bytes, Pseudo anonymized location (based on the anonymized IP address), Date and time, Title of the page accessed, URL of the page accessed, URL of the previous page (if it allows this), Screen resolution, Local time, Files clicked and downloaded, External links, Duration of page load, Country, Region, City (with low accuracy due to IP address), Main language of the browser, User agent of the browser and Interactions with forms (but not their content).
11.1. With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the described procedures.
11.2. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our products, offers, promotions and our company.
11.3. The registration for our newsletter takes place in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.
11.4. To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to provide a name for the purpose of personal address when registering for the newsletter.
11.5. The newsletters contain a so-called "web beacon", i.e., a pixel-sized file that is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
11.6. You can cancel the receipt of our newsletter at any time, i.e. revoke your consents. This will simultaneously terminate your consent to its dispatch by the dispatch service provider and the statistical analyses. A separate cancellation of the dispatch by the dispatch service provider or the statistical analysis is unfortunately not possible. A link to cancel the newsletter can be found at the end of each newsletter. If users have only registered for the newsletter and cancelled this registration, their personal data will be deleted.
12. Application platform
12.1. We offer an applicant platform on our website. As part of the application process, we process the following categories of personal data:
- Contact details in your application profile (e.g., first and last name, country, email, phone number).
- Information from the application form (this includes, for example, your desired salary, your motivation, information about your disability (only if relevant to the advertised position).
- Application documents (including, for example, CV, cover letter, career development data, qualifications and language skills).
- If applicable, references you provide or other information.
12.2. Your personal data will be processed exclusively for the following purposes:
- Initiation and establishment of the employment relationship
- To contact you should you be considered for an alternative position.
- To contact you based on your unsolicited application.
- To send you personalized information about job vacancies with us in accordance with the consent you have given.
12.3. We collect and process your personal data in order to offer advertised positions and to carry out the selection process. The provision of your personal data as part of the application process is voluntary. However, the provision of personal data is necessary for the processing of your application or the conclusion of an employment contract with us. The legal basis for the personality test is your consent pursuant to Section 26 (2) BDSG/Art. 6 (1) lit. a GDPR.
12.4. You also have the option of having the personal data relevant to the application transferred to us via the platform of rexx systems GmbH, Süderstrasse 75-79, 20097 Hamburg "finest jobs". In doing so, the data released by you will be transferred for the aforementioned purpose.
12.5. Furthermore, we may process personal data about you as part of the application process, insofar as this is necessary for the defense of asserted legal claims against us arising from the application process. The legal basis for this is Art. 6 (1) lit. b and f GDPR. The legitimate interest is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG). This personal data is deleted after a period of 6 months.
13. Processing of your personal data on Facebook and Instagram
13.2. When you visit or interact with our pages on Facebook or Instagram, Meta may collect, process and store personal data about you. This includes information about your interactions with us and our content, your IP address, information from cookies, pixels or similar technologies, and other information that you provide to Meta or that Meta may collect based on your use of its services. The data may also be processed in countries outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights.
13.3. We have no influence on the type and scope of the data that Meta collects, nor on its further processing and use. We also have no knowledge of the full scope of the data collection, its legal basis, the purposes and the storage periods. Therefore, we cannot provide any meaningful information about the processing of your data by Facebook.
13.4. We ourselves do not collect and process any personal data from you in this context. If, in exceptional cases, we do receive personal data, we will process it in accordance with the applicable data protection regulations, in particular the General Data Protection Regulation (GDPR).
13.6. Please note that you can also manage and adjust the settings for advertisements in your user profile on Facebook itself. Facebook and we are jointly responsible for processing your data when you visit our Facebook page, as set forth in the shared responsibility agreement we have with Facebook.
13.7. To ensure an appropriate level of data protection for processing in third countries, we have concluded standard contractual clauses with Meta (https://www.facebook.com/legal/EU_data_transfer_addendum).
13.8. From the point of view of data protection law, we are aware that we are to be classified as a joint controller alongside Meta. For this purpose, we have concluded a joint responsibility agreement (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transmission of data to Meta. The further processing of the data is the sole responsibility of Meta. This applies in particular to the transfer of data to the parent company Meta Platforms, Inc. in the USA on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.
14. LinkedIn Profile
14.1. We maintain a profile on LinkedIn, which is operated by LinkedIn Corporation, 1000 W Maude Avenue, Sunnyvale, CA 94085, USA (hereinafter "LinkedIn"). LinkedIn is represented in the EU by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
14.2. Please note that when you visit our LinkedIn profile, you are transferring your data to LinkedIn for processing. This may also involve a transfer of data outside the European Union or the European Economic Area, which may result in different data protection standards applying.
14.3. We do not ourselves collect or process any personal data from you on our LinkedIn profile outside of the processing operations that LinkedIn provides to us. If you have any questions about the processing of your personal data by us or about exercising your rights, you can contact us.
14.5. We recommend that you regularly review and adjust the privacy settings of your LinkedIn account to protect your data.
15. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
15.1. Right of access by the data subject
You may request confirmation from the controller as to whether personal data concerning you is being processed by us.
If there is such processing, you may request information from the controller about the following:
- the purposes for which the personal data are processed;
- the categories of personal data which are processed;
- the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
- the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration;
- the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
- the existence of a right of appeal to a supervisory authority;
- any available information on the origin of the data, if the personal data are not collected from the data subject;
- the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.
15.2. Right to rectification
You have a right to rectification and/or completion vis-à-vis the controller, insofar as the processed personal data concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
15.3. Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
- if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
- the controller no longer needs the personal data for the purposes of processing, but you need them for the assertion, exercise or defense of legal claims, or
- if you have objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.
Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of their storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
15.4. Right to erasure
a) Obligation to erasure
You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete such data without undue delay, if one of the following reasons applies:
- The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
- You revoke your consent on which the processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a GDPR and there is no other legal basis for the processing.
- You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
- The personal data concerning you have been processed unlawfully.
- The deletion of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data concerning you was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
The right to erasure does not exist insofar as the processing is necessary to
- to exercise the right to freedom of expression and information;
- for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
- for the assertion, exercise or defense of legal claims.
15.5. Right to inform controllers
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed about these recipients by the data controller.
15.6. Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that
- the processing is based on consent pursuant to Art. 6 (1) a GDPR or Art. 9 (2) a GDPR or on a contract pursuant to Art. 6 (1) b GDPR and
- the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
15.7. 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 relating to you which is carried out on the basis of Article 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
If the personal data concerning you is processed for the purpose of direct marketing, 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.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services - notwithstanding Directive 2002/58/EC - to exercise your right to object by means of automated procedures using technical specifications.
15.8. Right to withdraw the consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
15.9. Automated decision in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
- is necessary for the conclusion or fulfillment of a contract between you and the controller,
- is permitted by legislation of the Union or the Member States to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
- is done with your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms of, and the legitimate interests of, the data subject, which shall include, at least, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
15.10. Right to complain to a 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 residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
16. Right to erasure
16.1. The data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion is not contrary to any statutory retention obligations. Deletion will also take place in particular if other permissible circumstances cease to apply. If user data is not deleted because it is required for other and legally permissible purposes, its processing is restricted, i.e. the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for reasons of commercial or tax law.
16.2. In accordance with legal requirements, storage is for 6 years pursuant to Section 257 (1) HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years pursuant to Section 147 (1) AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
17. Right of objection
Users may object to the future processing of their personal data in accordance with the legal requirements at any time. The objection can be made in particular against the processing for purposes of direct advertising.