sms compliance
sms compliance
Privacy Policy & Data Protection Notice | GDPR, CCPA, COPPA Compliance – Sent, Inc.
Comprehensive privacy policy detailing how Sent, Inc. collects, uses, and protects your personal information. Full compliance with GDPR, CCPA/CPRA, COPPA, and TCPA regulations. Learn your data privacy rights and how to exercise them.
Privacy Notice
Last Updated/Effective Date: October 13, 2025
Sent, Inc. (“Sent,” “we,” “us,” or “our”) respects your privacy. This Privacy Notice describes how we collect, store, use, and/or share Personal Information (defined below) when you use our website and services that link to this Privacy Notice (“Service”) or otherwise interact with us, including when you apply for a job with us. It also describes rights you may have under applicable laws. Please read this Notice carefully to understand our policies and practices regarding your Personal Information and how we will treat it.
1. Sent’s Processing of Personal Information on Behalf of Clients
To the extent Sent processes Personal Information on behalf of organizations (“Clients”) that want to engage with individual consumers (“Client Consumers”) through the Service, Sent acts as a data processor or service provider on behalf of these Clients. Our processing of Client Consumers’ Personal Information is described in this Privacy Policy and is governed by Sent’s agreements with those Clients.
Client Consumers who wish to exercise any privacy rights in connection with their Personal Information that has been submitted to us by a Client should inquire with the Client directly. Because we only process Client Consumers’ data upon instruction from that Client, Client Consumers who make a request directly to us should provide to us the name of the Client who submitted their Personal Information to us. If we are able to verify the Client, we will refer the request to that Client and support them as needed in responding to the request within a reasonable timeframe.
2. Personal Information We Collect
Personal Information We Collect from Clients’ Representatives and Other Site Visitors.
We collect the following categories of Personal Information for our own business purposes, as set out below:
- Identifiers, including your first and last name, email address, and phone number;
- Preferences for receiving communications about our services and publications, and details about how you engage with our marketing communications;
- Information you provide when you interact with our Site;
- Information you provide in connection with requests to contact us or requests for customer service; and
- Information you provide in connection with your participation in a contest, sweepstakes, research study, or email survey.
- Employment-related information if you apply for employment with us, including your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
Personal Information about Client Consumers that Clients Provide to Us.
Clients may provide us with information about Client Consumers through the Service or offline for inclusion in the Service. Such information may include Client Consumers’ name, email address, and telephone number. As the data controllers with respect to this information, our Clients are responsible for providing notice and obtaining appropriate consents necessary for us to process this Personal Information.
Personal Information We Automatically Collect.
Like most online services, we may automatically receive and store certain Personal Information about individuals who interact with our Service through their browser or device. As discussed further below, we and our service providers may use a variety of technologies, including cookies, to assist in collecting this information.
- Device Information. We collect technical information associated with the device(s) you use to access our Service, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, and other information such as your device type.
- Usage Information. We collect a variety of information to better understand how individuals use our Service. This may include the webpage that you were visiting before accessing our Service, the pages or features of our Service you use, how much time you spend there, date and time of use, and information about your usage preferences.
- Transaction Information. We also collect information to help us verify transactions completed using our Service. This may include the names and email addresses of parties to a transaction, subject line, history of actions that individuals take on a transaction (e.g., reviewing and approving transactions, providing payment method details), and authentication methods.
3. How We Collect Personal Information
- Directly From You – We collect Personal Information that you provide to us directly, for example, if you choose to contact us, request information from us, or sign up to receive updates.
- From Third Parties – We may collect Personal Information from third parties, including but not limited to business partners, advertising networks, social networks, data analytics providers, mobile device providers, Internet or mobile service providers, recruiters and job application portals, and background check providers.
- Through Online Tracking Technologies – We use cookies and similar technologies to collect Personal Information related to activity on our Site. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.
4. How We Use Personal Information
To the extent permitted by applicable law, we use Personal Information to:
- To provide our Service, including providing customer service, maintaining accounts, verifying customer information, creating and maintaining business records, and undertaking or providing similar services.
- For internal research and development, such as testing, verifying, and improving the quality of our Site.
- For marketing, such as sending information about our business, including using your information to send you messages, notices, newsletters, surveys, promotions, or news about events.
- For communicating with you, such as responding to your questions and comments.
- For marketing and advertising, including using your information to send you messages, notices, newsletters, surveys, promotions, or event invitations about our own or third parties’ products and services that may be of interest to you. We also use Personal Information to conduct interest-based advertising as discussed in the Cookies and Other Tracking Technologies section below. You can unsubscribe from any marketing emails or text messages that we may send you by following the instructions included in the email or text correspondence.
- For legal, security, or safety reasons, such as protecting our and our customers’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
- As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.
- To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.
If you are applying for employment with us, we also use Personal Information to process your job application, to verify the information you have provided in your application, conduct interviews, perform background and reference checks, to communicate with you and answer your questions, to confirm your eligibility for employment, and improve our recruiting processes. We may also save your Personal Information for future employment opportunities with us.
5. How We Disclose Personal Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose your Personal Information in the following circumstances:
- Employees and Other Personnel – We may share Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.
- Service Providers – We disclose your Personal Information with the service providers that we use to support our business, including but not limited to, data analytics providers, website hosting providers, and other technology providers. If you are applying for a job with us, this may include service providers such as background check providers and human resource providers.
- Business Partners – We may disclose Personal Information with trusted business partners. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with.
- Ad Tech Companies and Other Providers – We may share or make available limited Personal Information (such as a mobile device identifiers) with ad tech companies and other online service providers. When we share your Personal Information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.
- Legal Obligation, Compliance or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Sent, its employees and customers, or the public against harm.
- Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.
- Other – We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
6. Cookies and Other Tracking Technologies
To collect the information in the “Personal Information We Automatically Collect” section above, we and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Service. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Service, to enhance your experience through personalization, and to help us better understand the features of our Service that you and other users are most interested in.
Chat-based Customer Support – We use a live chat feature powered by a third party (FeatureBase), and which may utilize artificial intelligence, to enable live customer service and technical support via our Service. When you engage in the chat enabled by this service provider, you may be interacting with an automated and artificial system, not a human representative. Additionally, to provide customer service and technical support enabled by this interactive system, we will automatically collect and share certain information (such as personal identifiers, usage information, and message content) with the supporting vendor. Any Personal Information disclosed with that third party via this interactive tool will be handled in accordance with FeatureBase’s Privacy Policy.
Analytics – We use analytics services that use cookies and other technologies that collect your Personal Information, to assist us with analyzing our Service traffic and site usage to optimize, maintain, and secure our Site and inform subsequent business decisions (including, e.g., advertising). These include, but are not limited to, the following third-party services:
- Google Analytics: To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
- Pixels: We use X (formerly known as Twitter) pixels to track user activity on our Service and improve downstream offerings, including interest-based advertising for our services and those of our partners and service providers.
Interest-Based Advertising – We may also allow or enable third parties to collect Personal Information to provide their interest-based advertising on behalf of our products and services, or their own. Interest-based advertising occurs when advertisements are shown to you based on information collected from your online interactions over time and across multiple websites, devices, or online services that you visit or use. Some companies may engage in cross-context behavioral advertising to predict your preferences and show you advertisements that are most likely to be of interest or relevant to you.
We do not control these third parties’ collection or use of your information for these purposes, or the opt-out options they may individually offer you via their terms, conditions, and privacy policies. If you have any questions about an advertisement or other targeted content, you should contact the applicable provider directly. Examples of the third-party service providers we engage to serve interest-based advertisements include Google Ads and X advertising. It is in this context that we may provide advertising networks, data analytics providers, social networks, and video sharing platforms with Personal Information such as your IP address, device information, Internet and other electronic network activity information, and geolocation information in the last twelve months.
Selling Personal Information – While we do not sell Personal Information in exchange for monetary consideration, we do disclose Personal Information for other benefits that could be deemed a “sale” under various data protection laws because it is sometimes broadly defined to include activities such as the delivery of interest-based advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.
Cookie Choices – To manage your preferences with respect to these technologies, you can:
- Change your cookie preferences by updating your preferences in our cookie consent tool or customizing your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Service may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
- Block the collection and use of your information by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the opt out pages of the self-regulatory programs of which those companies are members: National Advertising Initiative and Digital Advertising Alliance (or the European Interactive Digital Advertising Alliance, if you are located in the European Economic Area). Please note that even if you opt out of interest-based advertising, you may still see “contextual” ads which are based on the context of what you are looking at on the websites and pages you visit.
- Review and execute any provider-specific instructions to customize your preferences or opt-out of certain processing, including interest-based advertising, by third-party service providers. For example, to opt-out of this type of advertising by X, go to your account settings and turn off personalized ads.
7. How Long We Keep Your Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes described in this Privacy Notice, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether we need your Personal Information to provide you with our Service; we continue to have a relationship with you; you have requested information from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal Information; or we have another business purpose for retaining your Personal Information.
8. How We Protect Personal Information
We use commercially reasonable efforts to protect the confidentiality and security of Personal Information. However, despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.
9. International Use of our Site and Cross Border Data Transfers
If you are using our Service from outside of the United States, please note that our Service is hosted in the United States. Where permitted by applicable law, we may transfer Personal Information to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Notice.
For individuals in the European Union, European Economic Area, Switzerland, and United Kingdom: Sent will only transfer Personal Information to third parties located outside of this region when it has ensured appropriate safeguards for such Personal Information through use of the standard contractual clauses or other lawful and approved methods. To request a copy of applicable cross-border data transfer agreements, please reach out using the information in the Contact Us section**.**
10. Children’s Policy
We do not knowingly collect or solicit any Personal Information from children, as defined under applicable law without verified written parental consent, and we have no actual knowledge of selling such Personal Information of minors under 16 years of age. If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you believe we might have any information from or about a child, you can email us at privacy@sent.dm.
11. SMS Opt-In Data
Sent does not sell, rent, or otherwise share mobile information, including SMS opt-in data and consent, with third parties for promotional or marketing purposes. All categories of data sharing described in this Privacy Notice expressly exclude text messaging originator opt-in data and consent. Such information will not be disclosed to any third party, except as necessary to provide messaging services.
Sent may disclose Personal Information, including SMS opt-in data or consent status, to third-party service providers that support the provision and delivery of messaging services, including but not limited to platform providers, telecommunications carriers, and vendors that assist in the transmission or delivery of text messages.
12. Links to Third-Party Websites
We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party’s privacy notice.
In some cases, we offer links to social media platforms (like X (formerly known as Twitter) and GitHub) that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the terms of use and privacy policies for those platforms.
13. Individuals in the European Union, Economic Area, Switzerland, and the United Kingdom
This section provides additional information regarding [Company Shorthand Name]’s processing of personal data of people located in the European Union (EU), European Economic Area (EEA), Switzerland, and the United Kingdom (UK) in accordance with the EU Data Protection Regulation, UK Data Protection Regulation, and the Swiss Federal Data Protection Act.
Legal Bases for Processing
Our legal basis for processing Personal Information depends on the Personal Information involved and the context in which we process it. Where Sent acts as a controller, we process your Personal Information: with your consent; where necessary to perform a contract; to comply with our legal obligations; and where doing so is in our legitimate interests (including the purposes described in this Notice) and such interests are not outweighed by your rights and freedoms.
Special Category Data
Sent does not intend to collect any Special Category Data, which is any data that reveals your racial or ethnic origin, political opinions, religious, moral or philosophical beliefs, trade union membership, political views, the processing of genetic data, biometric data for the purpose of identifying a person, and data concerning health or a person’s sex life and/or sexual orientation. Please refrain from sending us any Special Category Data.
14. Exercising Your Privacy Rights
Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:
- Access – The right to request access to and obtain a copy of any Personal Information we may have about you.
- Deletion – The right to delete your Personal Information that we have collected or obtained, subject to certain exceptions.
- Correction – The right to request that we correct any inaccuracies in your Personal Information, subject to certain exceptions.
- Opt Out – The right to: (a) opt out of the processing of your Personal Information for purposes of targeted or cross-context behavioral advertising, and (b) opt out of the sale of your Personal Information.
- Objection/Restriction of Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.
- Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.
- Automated Decision-Making – The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right, depending on your location, to consent or opt out of (a) this automated decision-making or (b) any profiling in furtherance of decisions that produce legal or similarly significant effects. We do not profile you or other individuals in a manner that would result in legal or similarly significant effects, or engage in automated decision-making, so we do not offer an opt out of such activity.
- Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.
To exercise any of the privacy rights afforded to you under applicable data protection laws, please e-mail us at privacy@sent.dm. You may also exercise your opt out rights by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). We honor Opt-Out Preference Signals, including GPC. If you choose to use an Opt-Out Preference Signal, you will need to turn it on for each supported browser or browser extension you use.
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Notice. However, should you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some, or all, certain features of our Service to you.
Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. We may need to verify your identity before fulfilling certain requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making certain requests on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.
15. California Residents
This section provides additional information regarding our practices pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.
Please see the chart below for detailed information about the categories of Personal Information we have collected from California residents during the twelve months preceding the date on which this Notice was last updated and the categories of third parties to whom we Sell or Share Personal Information (as those terms are defined in the CCPA). For each category of Personal Information set forth in the chart below, the categories of third parties to whom we disclose it for a business or commercial purpose are set forth in the How We Disclose Personal Information section above.
| Personal Information Category set forth in Cal. Civ. Code § 1798.140 | Categories of Third Parties to Whom We Sell or Share Personal Information |
|---|---|
| Personal identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers. | Third-party marketers and other third parties that set cookies and other online tracking technologies on our Service. |
| California Customer Records Personal Information (Cal. Civ. Code § 1798.80(e)), such as name, signature, physical characteristics or description, address, telephone number, etc. | We do not Sell or Share this category of Personal Information. |
| Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | We do not Sell or Share this category of Personal Information. |
| Internet and other electronic network activity information, such as browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement. | Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Service. |
| Geolocation data, such as your IP address. | Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site. |
| Professional or employment-related information. | Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Service. |
Shine the Light – Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us using the information in the Contact Us section below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
16. Marketing Communications
To opt out of marketing emails, please email us at privacy@sent.dm or by following the instructions included in the email or text correspondence. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.
17. Changes to this Privacy Notice
Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We will provide you notice if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to our Site.
18. Contact Us
If you have any questions about our practices or this Privacy Notice, please contact us at privacy@sent.dm. You may also write to us at:
Sent, Inc.
157 W 18th St, Fl 7
New York, NY 10011, US
Frequently Asked Questions
How does Sent collect my personal information?
Sent collects personal information directly from you when you interact with their website or services, through online tracking technologies like cookies, and from third-party sources. They may collect identifiers like your name and email, device information, usage information, and information from social media interactions. They collect information related to the Client's use of their service, as well as from those that visit the Sent website.
What personal information does Sent collect?
Sent collects various types of personal information, including identifiers like name, email, and phone number; device information such as IP address and browser details; usage information about your interaction with their services; transaction information for verifying completed transactions; and information from social media if you engage with their accounts there. Sent acts a data processor for its Clients. Clients provide Sent with their customer's data to use the services provided by Sent. Sent collects data from individuals who visit the Sent website.
How does Sent use my personal information?
Sent uses your personal information for purposes such as internal research and development, marketing communications, responding to your inquiries, ensuring legal and security compliance, and potentially as part of a corporate transaction. Sent uses information gathered about Client consumers to conduct business on behalf of the Client, per the contracted agreement between Sent and the Client. They may also aggregate or anonymize data for statistical analysis to improve their services. Sent uses data from its Website visitors to conduct business and maintain its Site.
How long does Sent keep my personal information?
Sent retains your personal information for as long as necessary to fulfill the purposes outlined in their privacy notice, unless legal obligations require a longer retention period. These purposes include providing their Services, maintaining a relationship with you, legal compliance, recordkeeping obligations, or other business purposes.
How does Sent protect my personal information?
Sent uses commercially reasonable efforts to protect the confidentiality and security of your personal information through various security measures. However, they cannot guarantee absolute security during transmission or storage, as is the nature of data storage and transfer.
What are Sent's data collection practices for children?
Sent does not knowingly collect or solicit any Personal Information from children under the age of 13 without verified written parental consent. If they become aware of having collected information from a child under 13, they will promptly delete it.
What are cookies and how does Sent use them?
Cookies are small text files placed on your device when you visit a website. Sent uses cookies and similar technologies to collect information about your website activity, personalize your experience, understand your browsing preferences, and deliver targeted advertising. They also use technologies like web server logs, tags, SDKs and tracking pixels for similar purposes.
How can I manage or opt-out of cookies and tracking technologies?
Most browsers allow you to block, delete, or disable cookies, and mobile devices may offer settings to limit tracking. However, disabling these features may impact the functionality of the Sent website. For personalized ad opt-out from Google, visit Google’s Ad Settings.
What should I do if I have questions about Sent's privacy policy?
If you have questions about Sent's privacy practices or their Privacy Notice, you can contact them via email at privacy@sent.dm or by mail at Sent, Inc., 838 Walker Rd., Suite 21-2, Dover, DE 19904.
How can California residents request information about data sharing?
California residents can request information about the disclosure of certain categories of their Personal Information to third parties for direct marketing purposes. This request can be made once per calendar year by contacting Sent through the provided contact information.
How does Sent handle Personal Information on behalf of Clients?
Sent acts as a data processor for its Clients, meaning they process Personal Information on behalf of organizations engaging with individual consumers. If you have questions about your data processed through a Client, you should contact the Client directly. Sent commits to aiding the Client in processing your request, upon verification. You should provide the name of the Client who submitted your information to Sent.
Does Sent respond to "Do Not Track" signals?
Sent currently does not respond to "Do Not Track" (DNT) signals sent by web browsers.
How can I opt out of Sent’s marketing emails?
You can opt-out of marketing emails by contacting Sent via email at privacy@sent.dm or by following the instructions included in the marketing email itself. Note that even after opting out of marketing, you might still receive essential transactional or administrative messages.
How does the international use of the site affect my data?
Sent's Site is hosted in the United States. If you access the Site from outside the US, your data is transferred to, stored, and processed in the US. Keep this in mind, as US data protection laws may differ from those in your own jurisdiction.
When was Sent's privacy policy last updated?
Sent's privacy policy was last updated on May 7, 2025. It's recommended to review it periodically for any changes, which are effective immediately upon posting to their site unless otherwise indicated.