1. Information on the handling of personal data

We are very pleased about your interest in our website - and thus in our company. The protection of your private rights and freedoms is very important to us; we only use your data for the purposes intended. Since it is important to us that you are aware at all times of the extent to which we collect, use and, if necessary, transfer your data to third parties, we will provide you with the following comprehensive information on the processing of your personal data collected by us or stored by us.

We do not process data without a legal basis or without your informed consent. When processing personal data, we strictly adhere to the requirements of the General Data Protection Regulation (GDPR) and any other applicable data protection regulations.

2. Name and address of the controller

Transporeon GmbH
Heidenheimer Straße 55/1
89075 Ulm

Phone: +49 (0) 7 31 1 69 06 -0
Website: https://transporeon.com

info[at]transporeon.com

3. Data protection officer of the controller

You can send data protection questions to Transporeon\'s data protection officer by e-mail to dataprotection[at]transporeon.com or you can send your request by mail to the following address:

Transporeon GmbH
Data Protection Officer
Heidenheimer Straße 55/1
89075 Ulm
Germany

4. Rights of data subject

The General Data Protection Regulation (GDPR) provides for extensive rights for data subjects in Chapter III, which we explain to you accordingly below with regard to the processing of your personal data:

4.1. Right to information

This requirement concerns in particular information on the following details of data processing:

  • Processing purposes
  • Data categories
  • Recipients or categories of recipients, if applicable
  • If applicable, the planned storage duration or the criteria for determining this duration.
  • Note on the respective right of correction, deletion, restriction or objection
  • Existence of the right to complain to a supervisory authority
  • If applicable, origin of the data (if not collected from you)
  • If applicable, existence of automated decision-making including profiling, including meaningful information about the logic involved, the scope and the effects to be expected
  • If applicable, (planned) transfer to a third country or international organization
4.2. Right to rectification

We will correct any erroneous data immediately, provided that you inform us of the circumstance accordingly.

4.3. Right to erasure (right to be forgotten)

Provided that the processing is no longer necessary and one of the following conditions is met:

  • Discontinuation of the purpose of processing
  • Withdrawal of their consent and absence of any other legal basis for processing
  • Objection to processing without an important reason to the contrary
  • Unlawful processing
  • Required to fulfill a legal obligation
  • Data collection was carried out in accordance with Art. 8 (1) GDPR
4.4. Right to restriction of processing

Provided that one of the following conditions is met:

  • You dispute the accuracy of your data (restriction can be made for the duration of the review on our side)
  • In the event of unlawful processing and if the data is not to be deleted, restriction of processing shall take the place of deletion
  • If the processing purposes cease to apply, at the same time you need your data for the assertion, exercise or defense of legal claims
  • After you have lodged an objection pursuant to Art. 21 (1) GDPR and for the duration of the examination as to whether our legitimate reasons outweigh yours.
4.5. Right to data portability

If it is technically possible and does not affect the rights and freedoms of other persons, we will - at your request - transfer your data to another recipient (responsible party).

4.6. Right to object

If we collect or have collected and process personal data from you (on the basis of Art. 6 (1) e or f or Art. 9 (2) a GDPR), you have the right to object to the data processing (including profiling) at any time (with effect for the future). In exceptional cases, the objection may be ineffective, e.g. if we can demonstrate compelling interests worthy of protection for the processing that outweigh your interests or processing serves the assertion, exercise or defense of legal claims. If we process your personal data for the purpose of direct marketing, you have the right to object to such processing at any time. This also applies to profiling, insofar as it is associated with such direct advertising. You also have the right to object to processing of your data concerning you which is carried out by us for scientific or historical research purposes or for statistical purposes pursuant to Article 89 (1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

4.7. Automated decisions in individual cases including profiling

If we collect or have collected and process personal data from you, you have the right not to be subject to any decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. Exceptions to this requirement apply if the decision is necessary for the conclusion or performance of a contract between you and us or you have expressly consented to the processing. In any case, we will take reasonable steps to safeguard your rights and freedoms and legitimate interests, including at least the right to obtain the intervention of a person on our part, to express our own point of view and to contest the decision.

4.9. Right to complain to a supervisory authority

A list of the supervisory authorities responsible in Germany can be found on the website of the Federal Commissioner for Data Protection or at the following link: https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

5. General information on data processing on the website

The following information applies to the data processing on our website in general. If there are exceptions or additions to this information, these are described in detail in the relevant sections.

5.1. Data security information

We secure our website and other systems through technical and organizational measures against loss, destruction, access, modification or distribution of your data by unauthorized persons. In addition, we have implemented SSL encryption (SHA256) on our website to protect your data. However, despite regular checks, complete protection against all dangers is not possible.

5.3. Our legitimate interest

Our legitimate interest as defined in Article 6 (1) f GDPR is based on the performance of our business activities to maintain our operational capability as well as securing the employment of our employees.

In addition, our legitimate interest follows from the following purposes:

  • Ensuring a comfortable use of our website (e.g. by optimizing the display),
  • Ensuring a smooth connection to the website,
  • Evaluation of system security and stability.
  • 5.4. General deadlines for data erasure

    In principle, the data is deleted immediately in accordance with our deletion concept, provided that there is no obligation to retain it, the need to fulfill the contract or a legitimate interest.

    5.5. Deletion of personal data

    We only store your personal data for the period of time necessary to fulfill the specified purpose. Your data will be deleted immediately after the purpose has ceased to exist and any retention periods have expired. You have the option to request the deletion of your personal data at any time. In addition, twice a year we perform a deletion of records in the trading database if all of the following three criteria are met:

    • You are not in an active sales process (based on the opportunity record in CRM)
    • You have not had any contact with us in the last 12 months (based on activity record – phone, email or appointment activity in CRM)
    • You have not been digitally active in the last 12 months (not interacting with our content, events, etc.)

    5.6. Collection of general data and information

    As soon as you visit our website, our web server collects some general data and technical information - as shown in the table below:

    Browser types and versions used

    Correct display of the page content

    Operating system used, visitor origin (referrer, e.g. Google), subpages clicked onOptimization of our website content
    Date and time of access to the website as well as IP address and internet service provider of the visitorEnsuring the permanent functionality of our IT systems (for the operation of the website) and prevention of misuse
    Other data and information for security in the event of attacksProviding relevant information to law enforcement agencies in the event of a cyberattack

    The above information is temporarily stored in a so-called log file. The following information is collected without your participation and stored until it is automatically deleted no later than 7 days after the last login. The legal basis for data processing is Art. 6 Para. 1 Subparagraph 1 Letter f GDPR (i.e. our legitimate interest). Our legitimate interest arises from the data collection purposes listed above.

    6. Information about specific data processing on the website

    If applicable, in deviation from or in addition to the above-mentioned general information, you will find details of the individual data processing on our website below.

    6.1. Newsletter
    Purpose of processing

    Provision of information in the form of electronic newsletters. This newsletter relates to the area of process optimization in transport logistics for the affiliated companies mentioned in "Data Sharing" and contains, for example, industry information, product updates, results of completed analyses and case studies of reference customers.

    Legal basis (according to Art. 6 / 9 GDPR)

    Informed consent (Art. 6 para. 1 a GDPR). In the context of an existing customer relationship (Art. 7 (3) UWG).

    Recipient (if applicable)

    See 8 (Data sharing).

    If applicable, intention of forwarding to a third country or int. organization (incl. info on adequacy decision of the Commission or suitable guarantees)

    See 8 (Data sharing).

    If known: Duration of data storage

    See 5.4 (General deadlines for data deletion).

    Obligation to provide personal data (e.g. due to legal or contractual regulations) / necessityThere is no obligation to provide personal data. Newsletters are only sent after registration via a double opt-in procedure (voluntary and revocable informed consent in accordance with Article 6 Paragraph 1 a GDPR) or after a purchase contract has been successfully concluded and the e-mail address was collected in this process (according to § 7 Abs. 3 UWG).
    DOI registration

    Double opt-in means that after your registration we will send you an email to the email address you provided, asking you to confirm your subscription to the newsletter via a confirmation link. If you do not confirm your subscription, your data will be blocked and automatically deleted after 1 month. In addition, we store the IP addresses you use and the times of subscription and confirmation. This procedure is used to confirm your subscription and to detect possible misuse of your personal data.

    Mandatory informationThe only requirement for sending the newsletter is that you provide your e-mail address. The specification of further, separately marked data is voluntary and will be used to address you personally. Following your confirmation, we will save your e-mail address for the purpose of sending the newsletter. The legal basis here is Art. 6 Para. 1 Subparagraph 1 Letter a GDPR.
    Consequences of non-compliance (in case of failure to provide the required data)Non-compliance (i.e. not providing the required data) would result in the newsletter not being delivered to you.
    If applicable, existence of an automated decision-making processIn this context, we do not use automatic decision-making.
    If applicable, origin of the data (if not collected directly from the data subject)The data comes from the data subject himself.
    Revocation of consent / deregistration

    You can revoke your consent to receive our newsletter at any time by unsubscribing. You can unsubscribe by clicking on the link contained in every newsletter e-mail or by sending an e-mail to unsubscribe[at]transporeon.com.

    6.2. Use of our information services

    If you have expressly given your consent in accordance with Art. 6 Para. 1 Subparagraph 1 Letter a GDPR via our corresponding form (see below), we will use your e-mail address to inform you regularly about the desired services. All this information (see below) relates to the area of process optimization in transport logistics for the affiliated companies mentioned in "Data sharing" and differs as follows:

    DemoIf you request a demo, one of our Account Managers will contact you via email or phone to demonstrate our products and their benefits.

    Webinars

    A webinar is an online seminar that introduces you to the latest trends and developments in transport logistics as well as our products and their advantages.
    Fact Sheets / Insights / Whitepaper / EBooks / Blog Article (together “Fact Sheets”)A fact sheet describes the challenges in transport logistics and how you can solve them with the help of our products. It also explains how our products work and the advantages they offer.

    Product data sheets

    A product data sheet describes the functions, advantages and possible uses of a product.

    Training courses

    As part of training courses, specialists from our Shipper Consulting Team will show you how you can optimally use the functions of our e-sourcing tool. During the training courses, you will have access to our demo system and can understand and implement the learning content directly.
    Case Studies / Success Stories / Interviews / Reference Videos (collectively "Case Studies")The introduction of our products at a reference customer is presented in case studies. In it we describe the situation before the introduction of our products and the results that could be achieved with their use.
    Events & MeasureWe regularly invite you to our internally organized events, workshops and seminars as well as to externally organized trade fairs and events. At these events you will receive useful information on the subject of transport logistics.

    Forwarding database

    The forwarding database is a database of logistics service providers. Shippers can find suitable service providers for tenders here. By using filter criteria, shippers can determine before the tender how many service providers are included in our global bidder pool.

    The further statements on the "Newsletter" apply here accordingly to the registration, the mandatory information, the revocation and the tracking.

    6.3. Use of our social media fan pages
    Purpose of processingWe are represented on the social network Facebook with a "Facebook fan page" to give you the opportunity to constantly find out new information about us and our products (e.g. events, articles and studies) and to contact us directly.
    Legal basis (according to Art. 6 / 9 GDPR)The legal basis here is Art. 6 Para. 1 Subparagraph 1 Letter f GDPR. Our legitimate interest is based on providing a modern form of contact exchange via a social network.
    Other necessary informationYou can find the detailed data protection notice on our Facebook fan page here: https://www.facebook.com/notes/transporeon-group/datenschutzzettel-facebook-fanpage/2318723048192369/
    6.4. Contact form
    Purpose of processingProcessing and, if necessary, answering the request from the form sender. For questions of any kind, we offer you the opportunity to contact us using a form provided on the website.
    Legal basis (according to Art. 6 / 9 GDPR)

    Data processing for the purpose of contacting us is carried out in accordance with Art. 6 para. 1 letter a GDPR on the basis of your voluntarily given consent.

    Recipient (if applicable)

    See 8 (Sharing data).

    If applicable, intention of forwarding to a third country or int. organization (incl. info on adequacy decision of the Commission or suitable guarantees)

    See 8 (Sharing data).

    If known: Duration of data storage

    See 5.4 (General deadlines for data deletion).

    Obligation to provide personal data (e.g. due to legal or contractual regulations) / necessityThere is no obligation.
    Mandatory informationA valid email address is required so that we know who sent the request and how we can respond. Further information can be provided voluntarily.
    Consequences of non-compliance (in case of failure to provide the required data)

    None

    If applicable, existence of an automated decision-making processIn this context, we do not use automatic decision-making.
    If applicable, origin of the data (if not collected directly from the data subject)The data comes from the data subject himself.
    Change of purpose if necessary

    None

    6.5. Contact form: Participation in our partner program

    In some subject areas we work together with various partners. If you give your voluntary consent in accordance with Art. 6 Para. 1 Subparagraph 1 Letter a GDPR, we will also forward your (personal) data from the respective contact form to these partners. After completion of the transfer, your (personal) data will be stored and can be deleted at your request or in accordance with our data deletion process.

    The further statements on the "contact form" apply here accordingly to the registration, the mandatory information, the revocation and the tracking.

    6.6. Contact form: LinkedIn forms for lead generation
    Purpose of processingWe are on LinkedIn and use the network\'s lead generation forms. These forms are pre-populated with the data you\'ve already made public on LinkedIn and give you the ability to share information with just a few clicks.
    Legal basis (according to Art. 6 / 9 GDPR)

    The legal basis for data processing is Art. 6 Para. 1 Subparagraph 1 Letter a GDPR on the basis of your consent. You can revoke your consent at any time in the future by sending an email to unsubscribe[at]transporeon.com.

    Recipient (if applicable)
    • LinkedIn
    • company See 8 (Sharing data).
    If applicable, intention of forwarding to a third country or int. organization (incl. info on adequacy decision of the Commission or suitable guarantees)
    • LinkedIn
    • company See 8 (Sharing data).
    If known: Duration of data storage

    See 5.4 (General deadlines for data deletion).

    Obligation to provide personal data (e.g. due to legal or contractual regulations) / necessityThere is no obligation.
    Consequences of non-compliance (in case of failure to provide the required data)

    None

    If applicable, existence of an automated decision-making processIn this context, we do not use automatic decision-making.
    If applicable, origin of the data (if not collected directly from the data subject)The data you enter will be transmitted to us by LinkedIn and used to process your request. The data usually contains your first and last name, the name of your company and your e-mail address.
    Change of purpose if necessary

    None

    6.7. Direct purchases

    If you are directly purchasing a standalone product (e.g. within Market Insights) or a ticket to any event organized by Transporeon, the legal basis for this is Art. 6 Para. 1 clause. 1 lit. b GDPR and/ or Art. 6 Para. 1 clause. 1 lit. f GDPR. Our legitimate interest is based on offering these services/ events for business customers, without the need for prior sales calls. Once the forwarding is completed, your (personal) data is stored and can be deleted if requested or in accordance with our deletion process (see 5.5 (Deletion of personal data)) and subject to statutory retention obligations of applicable laws (e.g. HGB, AO, etc.).

    In some cases we use third-party payment service provider Stripe (Stripe Payments Europe, Limited

    (SPEL) with its registered address at 1 Grand Canal Street Lower Grand Canal Dock, Dublin, D02 H210,
    Ireland) to process your payments. Stripe will collect information from you to process a payment, including your name, email address, mailing address, payment card information, other billing information as well as identifying information about the devices that connect to its services for the purposes of early detection of fraudulent behaviour. For more details on data processing by Stripe, please see Stripe Privacy Policy:
    https://stripe.com/privacy as well as further information published in Stripe Privacy Center:
    https://stripe.com/en-de/legal/privacy-center.

    Transporeon does not collect or store your card information, such as card number, expiration date, or pin number. For the purposes of ticket purchase verification and ticket issuance and management, Transporeon receives and retains transaction details that allow us to verify that you paid for the services, tickets or transaction, including price, currency, date of payment, payment method, name, and account name.

    6.8. Salesloft Cadence Automation
    Purpose of processing

    We use Salesloft platform in order to optimize our customer journey and automate communication steps with potential customers. Salesloft built-in flexibility allows us to create more dynamic and personalized experiences when processing your contact requests and forms. When synchronized with our internal CRM system, Salesloft platform allows us to send out personalized emails from inside the platform. When potential customers respond, automation rules route these responses to the best workflow with the most relevant messages. Your contact data will be stored on a server located within the European Union. You can learn more about Salesloft security compliance here: https://salesloft.com/security-compliance/.

    Legal basis (according to Art. 6 / 9 GDPR)

    The legal basis for data processing is Art. 6 Para. 1 Subparagraph 1 Letter a GDPR on the basis of your consent. You can revoke your consent at any time in the future by sending an email to unsubscribe[at]transporeon.com.

    Recipient (if applicable)
    • Salesloft, Inc., 1180 West Peachtree St. NW, Suite 600, Atlanta, GA 30309, USA.
    • See 8 (Sharing data).
    If applicable, intention of forwarding to a third country or int. organization (incl. info on adequacy decision of the Commission or suitable guarantees)
    • Salesloft, Inc., 1180 West Peachtree St. NW, Suite 600, Atlanta, GA 30309, USA.
    • See 8 (Sharing data).
    If known: Duration of data storage

    See 5.4 (General deadlines for data deletion).

    Obligation to provide personal data (e.g. due to legal or contractual regulations) / necessityThere is no obligation.
    Consequences of non-compliance (in case of failure to provide the required data)

    None

    If applicable, existence of an automated decision-making processIn this context, we do not use automatic decision-making.
    If applicable, origin of the data (if not collected directly from the data subject)

    In case you have given your consent in accordance with Art. 6 Para. 1 clause 1 lit. a GDPR to be contacted by our representatives, your contact information may be transferred and stored in the Salesloft platform operated by Salesloft Inc.

    Change of purpose if necessary

    None

    6.9. Online surveys
    Purpose of processing

    Conducting surveys on the Internet.

    Legal basis (according to Art. 6 / 9 GDPR)

    Data processing for the purpose of online surveys is carried out in accordance with Art. 6 Para. 1 Subparagraph 1 Letter a GDPR on the basis of your voluntarily given consent.

    Recipient (if applicable)
    • SurveyMonkey (Momentive Europe UC, 2nd Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland)
    • See 8 (Sharing data).
    If applicable, intention of forwarding to a third country or int. organization (incl. info on adequacy decision of the Commission or suitable guarantees)

    See 8 (Sharing data).

    If known: Duration of data storage

    See 5.4 (General deadlines for data deletion).

    Obligation to provide personal data (e.g. due to legal or contractual regulations) / necessityThere is no obligation.
    Mandatory informationA valid email address and company may be required so that we know who the reply came from and how we can better evaluate the data. Further information can be provided voluntarily.
    Consequences of non-compliance (in case of failure to provide the required data)

    None

    If applicable, existence of an automated decision-making processIn this context, we do not use automatic decision-making.
    If applicable, origin of the data (if not collected directly from the data subject)The data comes from the data subject himself.
    Change of purpose if necessary

    None

    6.10. Online events
    Purpose of processing

    Transporeon uses Welcome digital events platform to host virtual events and provide you a great attendee experience.

    Legal basis (according to Art. 6 / 9 GDPR)

    Data processing for the purpose of online events is carried out in accordance with Art. 6 Para. 1 Subparagraph 1 Letter a GDPR on the basis of your voluntarily given consent.

    Recipient (if applicable)
    • Gather Wholesale, Inc., 440 N Barranca Ave, 8588, Covina, CA US 91723, USA.
    • See 8 (Data Sharing).
    If applicable, intention of forwarding to a third country or int. organization (incl. info on adequacy decision of the Commission or suitable guarantees)

    See Recipient above.

    If known: Duration of data storage

    Once the forwarding is completed, your (personal) data is stored and can be deleted if requested or in accordance with our deletion process (see 5.5. (Deletion of personal data)). Your user account with Gather is deleted automatically after 12 months if you did not register for any event during this period.

    \n

    Obligation to provide personal data (e.g. due to legal or contractual regulations) / necessityThere is no obligation.
    Mandatory information

    A valid email address, your name and company may be required so that we know who will attend the event. Further information can be provided voluntarily.

    Consequences of non-compliance (in case of failure to provide the required data)

    None

    If applicable, existence of an automated decision-making processIn this context, we do not use automatic decision-making.
    If applicable, origin of the data (if not collected directly from the data subject)The data comes from the data subject himself.
    Change of purpose if necessary

    None

    6.11. Cookies

    We use cookies on this website. These are small text files that are placed or stored on your computer via your internet browser (e.g. Google Chrome, Safari, Firefox, Edge). These cookies are used for various purposes: many cookies are technically necessary to provide you with certain website functions (e.g. saving your login information and language preference), other cookies are used to ensure the security of your data or the website and some cookies can be used to analyze your user behavior. The latter cookies may contain a so-called cookie ID - a unique identifier consisting of a string of characters that allows Internet pages and servers to be assigned to the storing browser. Cookies that are necessary to carry out the transmission of a message via a public telecommunications network and cookies that are absolutely necessary to provide you with an expressly requested function are referred to as "technically necessary cookies" and may be set without your explicit consent (Section 25 (2) TTDSG). All other cookies are subject to consent (§ 25 para. 1 TTDSG). Please see the details on the used cookies in 6.12 (Web tracking technologies - managed with Usercentrics). You can manage your choices either in 6.12 or in the Cookie Settings in the footer of the website.

    6.12. Web tracking technologies - managed with Usercentrics

    8. Data sharing

    We share your personal data with our affiliates, which are listed at the following address: https://legal.transporeon.com/transporeon_website.pdf Transporeon\'s affiliates in Europe and outside the European Union/European Economic Area have implemented and written down the EU standard contractual clauses to ensure an adequate level of data protection and compliance with the legal requirements of Art. 44 ff. DSGVO. The legal basis for the data transfer here is Art. 6 (1) subparagraph 1 letter a DSGVO based on your consent depending on the services requested.

    9. US Residents’ Privacy Rights and Choices (including under the California Consumer Privacy Act)

    Subject to certain limitations, residents of California and certain other US states have rights relating to their personal information as further explained below and on the Your Privacy Choices (for US residents) page of the Trimble Privacy Center. If you seek to exercise your rights through an authorized agent, we may ask for evidence that you\'ve provided your agent with a power of attorney, or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you\'re an authorized agent seeking to make a request, you will need to provide verification of your agency authorization.

    Employees and candidates of Trimble should view the appropriate candidate/applicant/employee privacy notice located in the Trimble Privacy Center.

    California residents should also review the California Notice at Collection which is incorporated by reference into and is made a part of this Privacy Notice.

    Right to Know/Access: We acknowledge that California consumers have the right to know the categories and purposes of personal information collected, sold or otherwise disclosed by Trimble (the “right to know”), and the right to request that we provide you with a copy of the personal information Trimble holds about you (and if information is provided electronically, to provide it to you in a portable format) (the “right to access”). This Notice at Collection and the Trimble Privacy Notice provides information on the categories and purposes of personal information collected, sold or otherwise disclosed by Trimble. If you want to exercise your right to know and/or access, you may submit a request online through this page, or by phone by calling 1-800-TRIMBLE. You may be required to verify your identity in connection with your exercise of this right.

    Right to Correct: We acknowledge that California consumers have the right to correct any inaccurate personal information about you held by Trimble. Many of our software, services, websites and apps allow you to edit your personal information by accessing "my account," "my profile," or a similar feature of the app or website. If you are not able to do so, you may submit a request to correct your personal information online through this page, or by phone by calling 1-800-TRIMBLE. You may be required to verify your identity in connection with your exercise of this right.

    Right to Deletion: We acknowledge that California consumers have the right to request deletion of their personal information from our systems and we will do so unless we are required to retain such information in order to provide services to you, we require such information to comply with our legal and business obligations under applicable law, or where retention is otherwise permitted for a valid purpose under CCPA or its implementing regulations. If you want to exercise your right to deletion, you may submit a request online through this page, or by phone by calling 1-800-TRIMBLE. You may be required to verify your identity in connection with your exercise of this right.

    Right to Opt-Out: Although none of the information noted above is sold, we acknowledge that California consumers have the right to direct us not to sell or share (as those terms are defined under CCPA) your Personal Information covered by CCPA. Consumers in other states may also be entitled to opt out of the sharing of their Personal Information for targeted advertising. To exercise this right, you may do so online through this page, or by phone by calling 1-800-TRIMBLE. You may be required to verify your identity in connection with your exercise of this right.

    You also have the right to not be discriminated against for exercising any of these data rights.You have the right to exercise the rights listed above free of charge or penalty, but we may limit the number of requests you make or charge reasonable fees as legally permitted.