Last Updated October 10, 2024
This Website HongLearn earns some Personal Data from the Users Liabilities.
This document relates to a fixed section on privacy of the users from California.
This document contains a marked house for the users in cagandabrasil and the respect to their privacy.
This document will be available for use and reference and can be printed whenever required with the printing option from any browser.
Data Collection Methods
Among the many types of Personal Data that the Website itself or third parties may collect, we can mention: Cookies; Usage Data; various types of Data; email address
Detailed description of the reasons why this type of Personal Data is being sought out is usually located within the respective sections of the privacy policy or within specific explanatory texts that are shown in advance of the relevant Data being sought.
Email addresses provided by the User shall be considered optional, while Usage Data may be collected even without Users signing up to this Website.
“In the absence of a clear indication to the contrary all Data requested by this Website shall be considered as obligatory, and in the case of one or more Data not being provided, this Website may not be able to offer its services. In discrimination of such statements made on the Website about self-restriction of collecting some Data, Users are quite at liberty to refrain from providing that Data without any implications on the availability or the performance of the Service. ”
If any User has any doubts regarding the kind of Personal Data that needs to be provided, they are invited to ask the Owner.
The use of Cookies – or of other tracking utilities – on this Website or in the third party services operated by the owners of the Website aims at the realization of the Service aimed at the User, besides other objectives mentioned in the present document and in the Cookie Policy, if so exists.
Users understand that the Data not owned by them may be obtained, published, or shared with the User through this Website, as long as the User informs the Owner that they had the permission from the third party to provide Data to the Owner.
The Owner ensures that Data is processed appropriately and only for the purposes for which it was collected.
The Owner implements measures aimed at protecting the Data against accidental or unlawful destruction or alteration, or against unauthorized disclosure or access.
With the organization’s clearly defined aims, data processing is performed mechanistically and/or with the use of ITCT facilities in accordance with pre-determined organizational methods and organizational structures. Aside from the Owner, and in other instances, the Data may be made available to some classes of designated individuals, engaged in the operation of this Website (administration, sales, marketing, legal, system administration) or to other persons outside the legal entity (for example, technical service providers, couriers, data hosting suppliers, IT corporations, advertising agencies) who may be appointed by the Owner as Data Processors if needed. The Owner shall answer the question as to who the persons are entitled to process personal data at any time, including their function.
Location
The Data is processed at the registered office of the Owner and the processing office and at such other locations as the persons processing the Data may be found.
Also where the User is contact, the transfer of such User’s Data may entail the transfer of the User’s Data to a jurisdiction outside their own. More information about the circumstances and mechanisms surrounding the processing of such transferred Data can be found in the section on the processing of Personal Data, which is further elaborated detailing what Personal Data users’ data may be processed in such sections.
Users should also have the right to be informed as to why and on what basis the Data may be transferred to a country which is not a member of the European Union or to any international body which is governed by international law or created by several nation states, including the UN and to learn the measures that the Owner has taken to protect Users’ Data.
Where there is such a transfer of Data, Users are provided with this information in other parts of these documents or they can ask the Owner for the same by utilizing the contacts provided in the contact section.
Retention Period
Personal Data shall be processed and stored for anytime necessary to the purpose the data were collected to.
The Owner may be allowed to store Personal Data for a longer period of time when the User has consented to such processing and such consent has not been withdrawn. The Owner may also, at times, be bound to keep Personal Data for a period longer than that specified for the execution of a specific task or at the request of a particular authority.
The deletion of the user’s Personal Data is done as long as the retention period has lapsed. Consequently, the right to access information, the right to withdraw or delete data, the right to rectification of information, and the right to transfer information to another service are no longer available after the period of retention is over.
Purposes of processing
The data of the user is collected so as to enable the owner of the website to offer such services, to satisfy some or all legal requirements, to answer enforcement requests, protect owner’s (or user’s or third-party’s) rights and interests, investigate the occurrence of unauthorized or illegal activities, and for such purposes as: Advertising and Commercial Spaces, Targeted Ads, Tag Management, Traffic Acquisition & Distribution Optimization, and Data Exporting Out of the European Union.
As for the details regarding the Personal Data for each of the aforementioned purposes, the respective details are provided under the “Detailed Information on the Processing of Personal Data” section.
Better description and analysis of the purpose of personal data processing.
Collected Personal Data is used to serve different purposes including:-
Advertising
This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, possibly based on User interests. This does not mean that all Personal Data are used for this purpose, details and conditions are listed below.
Some of the services listed below may use trackers to identify Users or they might use the technique of behavioral retargeting whereby ads specifically suited to the User’s domain and behavior, even behavior outside this Website, are exhibited. For more information about these services, please read the privacy policies of these services.
In addition to any opt-out offered by any of the services, Users will have an option of opting out of advertising by the Network Advertising Initiative opt-out page
Users are also able to opt out of certain advertising features, including advertising tracking settings within mobile devices or other advertising network settings.
Google AdSense (Google Ireland Limited) is an advertising service which is provided by Google; Gogle Ireland Limited. This service makes use of DoubleClick’s Cookie to gather information on the Website usage and User’s attitude towards advertisements, presented products and services offered. Users may turn off all DoubleClick Cookies by use Google Ad Settings.
The Personal Data processed concerns Trackers and Usage data where the processing is undertaken in Ireland. For additional information, users can check the Privacy Policy and see the possibilities to Opt Out.
The category of personal information collected under the California Consumer Privacy Act is internet information. Furthermore, the processing activities carried out by Google Adds are classed as a sale, or one of the events that fall under the definition of a sale as defined under the CCPA legislation. Users who want to request for removal of information concerning to such a sale will be able to get more information in this document’s section devoted for rights of Californian consumers.
Analytics
In this category, the Owner has the ability to control and evaluate website visits, and such services can serve to analyze the activities of the Users.
Google Analytics (cleared data: Google Ireland Limited), is a web analytic tool offered by Google. In addition, Google utilizes collected information when analyzing activity of this Website, tracking, and providing influence activity on this Website or other activities, and composing and distributing related reports to other google services.
The collected data may be used by Google to increase the relevance and personalization of advertisements offered by its own advertising networks.
Cookies, Usage Data are Personal Data processed. Place of processing: Ireland – Privacy Policy – Opt Out.
Internet information is the category of personal information collected according to the California Consumer Privacy Act CCPA.
While this processing involves a sale as per the definition given in CCPA, this clause does explain and seek to prevent this sale which is not in the CCPA clause from happening. Also, apart from the information in this clause, the User can find information about how to opt out the sale of their information in a section of the rights of Californian consumers.
Remarketing and Behavioral Targeting
This Website and its partners may use these services to advertise to users in active and inactive target audiences optimally based on the user’s use of this Website.
The activity is carried out by monitoring the Usage Data and using Trackers for information which is forwarded to the partners dealing with remarketing and behavioral targeting management.
Some individual services let you perform a remarket on the basis of the provided email address list.
Except for the ‘opt-out’ which might be shown on any of the services mentioned below, Users can opt out of any such advertisement on the Network Advertising Initiative opt-out page.
Users can also refuse some advertising parts through device features such as mobile advertising settings, advertising network settings etc.
Google Ads Remarketing is a service by Google Ireland Limited for admob retargeting campaigns as well as for behavior targeting. This service enables the link between this Website and the Google Ads advertising network and the DoubleClick Cookie. Users may opt out of the use of trackers by Google for the purpose of tailoring advertisements by going to Google Ads Settings. Personal Data processed: Cookies; Usage Data. Processing location: Ireland – Opt Out – Privacy Policy.
The demographic data a business collects about individuals under the CCPA regulations: internet information.
Under the CCPA rules, such processing is viewed as a sale. In addition to information contained in this section, the user can consider how to opt out of the sale in the section relating to rights of consumers in California.
Tag Management
Such an approach helps the Owner to control the tags or codes that are to be associated with this Website, comprehensively and efficiently as well.
This means that the User’s Data finds its way through these services and as a result, such data is probably retained.
Google interior & limited management in other countries is a service providing a tag management services for Google N. Personal Data processed: Usage Data. Place of processing: Ireland – Privacy Policy.
Category of personal information collected in relation to the California Consumer Privacy Act, CCPA: internet information.
This processing is deemed a sale as defined under the CCPA. Besides the information available in this section, the User can find additional information on how to opt out of the sale in the section covering the rights of california consumers.
Optimization and Distribution of Traffic
The service of this kind permits the Website to carry out content redundancy using special web servers which are set up in different countries and enhance efficiency.
The basic principle lies in an evaluation that, the Way in which, these services are applied, which varies with the location and other factors. These are aimed at clogging or easing the interactio0ns between the Website on one side and the User’s browser on the other.
Being that the system has an extensive reach, it is inconvenient to know to which geographical areas are the contents with the User’s Personal Data sent.
Contacting the User
Once the User clicks through the Contact Form (this Website) and types in his or her Data, the User gives this Website permission to find relations to any kinds of concerns such as those concerning information and quotations as specified in the heading of the form.
The following Personal Data is processed: email address.
Consumers Personal Data Classification under California Consumer Privacy Act: identifiers.
Data Transfer Outside the EU
Personal Data of consumers residing in the EU may be transferred by the Owner to a third country as defined by the GDPR only in compliance with GDPR law. Any transfer of data, in this case, will be performed on one of the legal basis presented below.
Users can ask the Owner for which legal provision, this information or service is subject to.
Consent-based data export out of the European Union. This Website was fulfilled.
If this is the legal basis, Personal Data of the Users may only be taken out of the EU to third countries where the User has confirmed such transfer after being warned about the absence of an adequacy decision and other measures of protection of such.
In those cases, the Owner accordingly informs Users and seeks their considering consent through this Site.
Personal Data processed: contextualism regarding personal data, data relating to health, sexual life, and others.
Category of personal information collected according to the California Consumer Privacy Act (CCPA): network or profiled data.
Additional Information about Personal Data
Adults only please
Users declare that they are older than the age of majority or the legal adult age in the respective jurisdiction. The use of this website is not allowed for minors.
The Age Restriction Goes Like This, Eighteen Shall Be The Least Age
Users reassure that they are of the age of majority considering the laws of the concerned jurisdiction. This Website may only be attempted by children aged less than eighteen years where the child is with a satisfactory adult caregiver. No child under the age of 13 years is allowed to use this website.
User Rights
If certain information is held by the Owner about Users, the Users may exercise certain rights concerning the processing of their Data. Namely, Users are granted the rights listed below:
Withdraw their consent at any time. The Users have the right to withdraw previously given consent to the Processing of their Personal Data.
Object to processing of their Data. The Users have the right to object to the Processing of their Data where such Processing is based on a ground other than consent. This will be discussed further in the specific section below.
Access their Data. Users are entitled to know whether the Owner is processing their Data and to obtain information regarding the processing and the Data processed.
Verify and seek rectification. Users have the right to reasonable access to their Data to ascertain its accuracy and to have it changed where necessary.
Restrict the processing of their Data. There are occasions when Users may restrict the Processing of their Data. In this case, the Owner will not Purify his Data except for storing it.
Have their Personal Data deleted or otherwise removed. A user shall have the right to request that particular Data be deleted from the Owner’s database under appropriate conditions.
Receive their Data and have it transferred to another controller. Users can expect to receive their Data in a standard structured format that is suitable for technical use and situations where data storage in other devices is applicable. This provision is applicable considering that the Data is processed by automated systems and such processing is conducted in furtherance of a contract to which the User is a party or for legal obligations prior to the provision of the contract.
Make a complaint. Users are entitled to appeal to the appropriate public authority in charge of protection of personal data against any infringements against this right.
If data is processed against the rights of a user, these rights protect the User under certain circumstances as specified by the controlling laws over data protection.
An In-Depth Exploration of the Right to Object to Processing Information
When processing Personal Data for the public good, in the implementation of an official mandate of the Owner or in reasoning, which justifies the Owner’s participation, Users can provide an objection to such processing with a reason based on their individual circumstances.
Users should be aware that where this is done for the purposes of direct marketing, such Users can opt out of their Personal Data being processed for marketing purposes any time without the need to give a reason. To know if the Owner processes Personal Data for direct marketing, Users may check relevant pages of this document.
The Content of the Procedures How to Exercise These Rights
Request or notification to invoke and exercise User rights can be addressed to the Owner by telemetry contact mentioned in this document. Such requests may be free of charge and the Owner shall respond as soon as possible and always within one month for a reasonable request.
Cookie Usage Policy of the Web Page
In this website, there are implemented trackers. For more information, Users are recommended to check the Cookies Usage Policy.
More Information on Data Gathering and Processing
Legal Matters
The User’s Personal Data could be in the possession of the Owner and be employed for legal actions in Court by the Owner or in any of the processes that could result in legal action against the abuse of the data.
The User agrees that the Owner may be called upon to explain the data upon the request of some public authority.
Additional Information of the User’s Personal Data
In this privacy policy and in the user agreement, there are other important personal information about the user that this website may request in services offered to her, or specific services being rendered or user personal data being collected.
System Logs and Maintenance
As far as the website intervention, maintenance or troubleshooting is concerned, this website and also some external services may collect system files recording events on this website (System Logs) and/or use other private information such as IP Address for this purpose.
Information Not Included in This Policy
It is possible to obtain further details on the method or reasons for Le Petit Trois Asia’s collection or processing of Personal Data from the Owner at the time. Contact details were provided on the very first page of this document.
How “Do Not Track” requests are treated by the Website
This particular Website does not advocate for compliance to “Do Not Track” quote.
You should read their Privacy Policies to see if any of the third party services used respect the requests “Do Not Track”.
Amendments to this Policy
The Owner shall be entitled in its discretion to change this privacy policy in future as it chooses and shall to inform its Users on this page and possibly within this Website and/or as far as technically and legally possible do so by way of informing Users using any of the contact information available to the Owner. It is highly advisable to look at this page regularly as it is frequently updated, as indicated by the italicized date at the end of the page.
Should any of the applicable changes affect processing activities carried out on the basis of the consent of User, the Owner shall obtain new consent from User where required.
Information for California Consumers
This part of the document is integrated and supplemented by the other parts of the privacy policy of the website which is the entity managing this website and if required, its parent, sister and or associated companies from hereon referred to as “we”, “us”, “our” for this section.
These provisions apply to all Users who are consumers and residents in California, United States of America, according to the provisions set forth in the “California Consumer Privacy Act of 2018” (hereinafter simply referred to “you”, “your”), and they are not opposite or conflicting from any other provisions of privacy policy applicable to these consumers.
In this section of the paper, the expression ‘personal information’ is used in the sense earlier described in the C CPA.
Categories of Personal Information Collected, Disclosed or Sold
In this section, we want to briefly specify the categories of personal information which we collect, disclose or sell as well as the usage of this personal information. Specifications of these activities can be found in the section titled “Detailed Information on the Processing of Personal Data” within this document.
Information We Collect: Categories of Personal Information We Collect About You
We collect the following categories of personal information about you:. These categories include identifiers and internet information.
The commitment made in this case does not apply any additional categories of personal information to be collected without prior notification.
How We Collect Information: From what sources do we collect personal information?
We receive personally identifiable information described in the earlier mentioned categories of personal information from you through the use of this website whether actively or passively.
For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate through this Website, as personal information about you is automatically observed and collected. There are also people who work for the Company; we may obtain personal information about you from these if they assist in providing certain Services in relation to the operation of this Website and its functionalities.
How We Use the Information We Collect: Sharing and Disclosure of Your Personal Information to Third Parties for Business Purposes
We may use your personal information collected from you for business purposes by providing it to third parties. For such occasions, we enter into a written agreement with the third party insisting upon the appropriate measures being taken to protect the user’s personal information from misuse with the exception of using it for the performance of the agreement.
We may also reveal your personal information to other third parties at your direct instructions or permission for the sole purpose of assisting you in our Services.
For information on the purposes of processing, see the relevant section within this document.
Selling Your Personal Information
In our context, the term “sale” means any “sale, rental, lease, release, dissemination, making available, transfer of or communicating in any manner – be it oral, written or electronic – to another business or person, for valuable consideration or otherwise, personal information pertaining to a consumer by the business, including any sale, of a device used by a consumer to capture the information.”
This means that, for example, including an advertisement in an app or a traffic or view statistic study or just using social networks plugins and so on, also constitutes sale of data.
Your Right to Opt-Out of the Sale of Personal Information
You can opt out from the sale of my personal information. This means that if you wish to cease selling our data, that is what we would do.
Such a request can be done at will present any time, without the need of providing any authentic request, merely by following the given steps.
Instructions on How to Opt-Out of the Sale of Personal Information
Anyone who wishes to seek further information or exercise the aforementioned right, in relation to sales carried out on this website and in any manner on this document, may do so by contacting using the details available in this document.
For What Purposes Do We Use Your Personal Information?
Your personal information may be used in order to ensure that this Website and its features are able to carry out an operational activity (“business purposes”). In this case, the personal data subject’s personal information will be processed in a manner which is operationally permitted and relevant to the purpose for which the data was collected.
We may additionally make use of your personal data for additional causes commercial purposes as under the section detailed information on the processing of personal data in this document as well as in fulfillment of the law and for our defense before relevant authorities whenever our rights and interests are under threat or a reasonably suffered damage.
We shall not process your personal data for purposes which are not related or are incompatible with the relevant purposes as communicated to you.
Your California Privacy Rights and How to Exercise Them
The Right to information and Translateability
You are entitled to require us to make available information that you have indicated. The limitation will be on the provision of personal information which was either collected or used in twelve months.
In the event that our response is supplied electronically, the relevant razvod informatsii in a portable form will be attached. This means that the relevant certain information is given in a form that one is able to transfer to someone else with no obstacles to them depending on the limitations imposed technologically.
The Deletion of Your Personal Data Right
You can ask us to remove any personal information that we have about you with the exception of the situations provided for by the law (for better understanding reasons, this may include when a given information pertains to such efforts as raising or fixing problem with this Website, preventing and assuring that fraudulent or criminal activities do not take place, among others, exercising some rights, etc.).
If that is not the case, we shall, as a result of exercising your right, erase your personal data concerning the abuse you have refrained from and shall instruct our contractors to perpetrate the same.
Exercising Rights
For the above mentioned rights to be exercised, you need to make a verifiable Request by reaching to us using the facility outlined at the end of this document.
Actually, we would like you to provide us with your details first before we entertain your request. They see that this clause contains rights that can only be exercised by the making of a verifiable request that must:
Where a request is made and the identity of the requester cannot be established, the response will be not answered since it cannot be determined that the information we have concerning the individual is in fact accurate.
If submitting a verifiable request is not possible for you in person, a person registered at the California Secretary of State may be appointed by you to act instead.
If you are an adult, you are able to make a verifiable request on behalf of a minor who is under your parental guardianship.
The limitation states that you may only make two requests in any twelve-month period.
How and When We Should Process Your Request
We have received your request, which can be verified, and have bolstered that this, to verify the request, confirming the letter in question was sent in be done in no more than 10 days.
Your request will be replied within 45 calendar days from its receipt. In case if we need more time we will let you know the reasons and the time frame we require. Please note that up to 90 days may be required for processing your request.
The request will include the last period of 12 months only.
If we are unable to meet your request, we will provide an explanation of the reasons leading to the rejection.
We do not charge a fee for processing or responding to your verifiable request unless it is vexatiously and obviously unjustified, or grossly disproportionate. In those circumstances we may apply a reasonable fee or not comply with the request. You will be advised of the action taken, and the reason for it will be explained if necessary.
Information for Users Residing in Brazil
This part of the said privacy statement interacts, includes and complements the information contained in the privacy statement and is made available to such website managing entity and if need be, its parent company, subsidiaries and other affiliates collectively for the purpose of this section referred to as “we,” “us,” or “our”.
Users in Brazil are subject to the rules of this subsection and their provisions extend to “All Users in Brazil, howsoever defined, or in accoradance with the words and the letters contained in, the Lei Geral de Proteção de Dados. Also to the extent that they apply to such Users, these provisions shall take precedence over any other possibly divergent or contrary provisions that may be contained in the privacy policy.
Here “personal information” means and includes information like sensitive personal data as defined and included in the romanian general data national register for protection of data or “ баз алмай, онкозарар қарсы жабдықты пайдалану”.
Bases on Which We Process Your Personal Information
We may only carry out such operations on your personal information if we are entitled to do so. The legal bases are listed below:
Consent: which, in your case, is expressed by your very acts in relation to one or several types of processing of your personal information.
Legal Obligation: which refers to any situation of which the processing must comply with laws and/or governmental regulations which center on the firm.
Policy Implementation: which refers to situations whereby the processing in question is required for the implementation of such policies as are established by the law and or by public policy entities.
Contract Performance: which includes cases where the processing is essential for the fulfillment of the specific contract you are a party to or for carrying out any pre-contractual measures you ask for.
Legitimate Interests: which corresponds to all other situations when the processing of personal data is required due to legal permits such as enhancing the quality of services, legal interests protect etc.
If you want more detailed information regarding the legal grounds, shall apply to us at any convenient for you time using the ways of contact specified in this document.
To find out which categories of your personal information are processed, you may read the “Detailed Information on the Processing of Personal Data” section in this document.
To understand the motivations behind the processing of personal data when required, One may consult “Detailed Information on the Processing of Personal Data” and “Purposes of Processing” sections of this document.
Your Brazilian Privacy Rights, how to submit a request, and how we respond to your requests
Your Brazilian Privacy Rights, how to submit a request, and our response to your requests always
You have such rights, in particular:
Confirm the fact of processing of any personal data, such as the data processing and storage.
Have copies of your data.
Rectify any errors or omissions or olded data.
Anonymize, block or instruct deletion of data which is not relevant or in excess of reasonable necessity or data which has been subjected to processing that is not in compliance with LGPD.
Data can be sent from one service or product provider to another town, subject to an explicit request and the all requirements of the regulation of the national authority including commercial and industrial secrets.
Remove personal data processed under the agreement of the data subject.
The information that there is and whom the controller has shared the information with publicly available or private organizations.
The information whether consent can be withdrawn and what any adverse effects of such withdrawal are.
Retake communication.
For exercising the rights of the children, you will never be discriminated against or face any other grievance as a result of such exercise of rights.
How to Submit Your Request
Anyone may submit their request to exercise their rights directly and free of charge, any time they wish by using contact details provided in this document or through his/her lawyer.
How and When We Will Respond to Your Request
You will be receiving a swift response to your requests as we seek to respond to them as soon as you put them across.
In any case, if it is impossible for us, we shall notify you of the all reasons or law regulation that inhibit us from proceeding with satisfactory or appliable performance concerning your request(s). OR In cases when we do not process your personal information, we will inform you of the physical or legal person who is competent to secure your requests, if we can do that.
Please clarify the form in which you would like your personal information to be when you make a request for confirmation of access or processing of data: electronic or paper.
You will also need to inform us whether you would prefer us to attend to your request ‘as a matter of urgency’- in which case, we would give a brief response to the request or that you will wait for a full report on the request.
In the former case, within 15 days following your written request, all information concerning the sources of your personal data, whether such documents are kept or not, what criteria are taken into account while processing, and why processing is done will be provided to you, subject to the confidentiality of business and industry information.
In the event that you address a request for any correction, modification, erasure or blocking of personal data, this means that we shall promptly inform other persons to whom we have transmitted your personal data who may be in a position to act on your request – unless it is evident within reason that such notification is impossible or requires undue effort on our part.
There are cases when it is allowed by law to transfer personal data outside of Brazil:
When there is an action that is ‘for the purpose of legal communication between their central intelligence, investigation, and prosecuting agencies under the law instruments approved by the international law,’this is considered to be an international legal cooperation and so it is recognized by the law as a reason for data transfer.
When it is meant to secure one’s life or security or those of other people.
When the action is endorsed by The Brazilian National Data Protection Authority.
When it is to comply with a specific action that has been agreed to under international co-operation treaties.
When the transfer is needed in order to achieve a specific task or duty prescribed by law or needed to implement public policy.
When the transferral is essential to fulfill any statutory or regulatory requirements or to perform any contractual or pre-contractual activities relating to a contract or to enforce normal legal rights in neutrals, courts or other legitimate forums.
The absence of localization applies to these situations only and does not pertain to Brazil’s law regarding the flow of personal data outside the country:
Where such transfer is required in the course of authenticating the international legal cooperation in public intelligence, investigation and legal prosecution, as provided by instruments of international law.
When such transfer is needed to safeguard your life, physical integrity or life, physical integrity or safety of third parties.
When it is As a result of a decision of the National Data Protection Authority.
When it arises as a consequence of obligation undertaken within the framework of an international cooperation agreement.
When such transfer is required to implement a legal or other public duty the effect of which is to provide public services.
When such transfer is required in order to fulfil any legal or regulatory or contractual obligations or commitments or for the purposes of entering into contract negotiations or for the purposes of legitimate judicial, administrative or arbitral proceedings.