Diletta De Cicco

    Diletta De Cicco

    Counsel

    diletta.decicco@squirepb.com View Full Bio

    Diletta De Cicco advises clients on cybersecurity, data and privacy issues. In particular, she assists clients to comply with existing EU and national cybersecurity, data and privacy laws, such as the NIS Directive, GDPR and the Cybersecurity Act, and on upcoming developments, such as the AI Act and the ePrivacy Regulation.

    She has experience managing incidents in a cross-border context, where it is necessary to consider multiple cybersecurity, privacy and other regulatory and enforcement frameworks. Her work helps clients in developing compliance and awareness programmes and dealing with global data transfer mechanisms and the negotiation of data processing agreements.

    Diletta holds a Certified Information Privacy Professional/Europe (CIPP/E) certification, as well as a Data Protection Officer Certificate from Maastricht University. She is a member of the International Association of Privacy Professionals (IAPP), now a chair of the Brussels KnowledgeNet Chapter and a member of the IAPP Diversity in Privacy Board. She also serves as a project lead at W@Privacy.

    Diletta is an academic assistant at CRIDES, UCLouvain, part of the research group Data, Robotics, Artificial Intelligence, Law and Society (DRAILS). In 2022, she was recognised as one of the 100 most powerful cyber women by the Women4Cyber Foundation in its book Hacking gender barriers: Europe’s top cyber women. She speaks English, Italian and French.

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    Explore
    • Assisted a cryptocurrency player in the cybersecurity and privacy compliance aspects of its global operations and online platforms taking EU GDPR as a benchmark.
    • Assisted a podcast platform in dealing with information requirements under the GDPR and ePrivacy Directive, including drafting the website’s privacy notice and cookies notice.
    • Worked on the development and setup of an API used to facilitate acceptance by merchants of cryptocurrency as means of payment on their platforms. From a privacy compliance point of view, the indirect collection of data and complexity of the supply chain made the representation particularly innovative.
    • Participated in the deployment of a cryptocurrency designed as digital cash on phones by reviewing privacy settings and disclosure language.
    • Counselled various clients with global operations in assessing the impact of the EU developments around personal data transfers post-Schrems II decision and in implementing supplementary measures for data transfers. A data transfer tool we developed was used for assessing and documenting the steps undertaken to authorise the data transfers to take place on the basis of standard contractual clauses.
    • Contributed (in a personal capacity) to the INTERLINK consortium, a Horizon 2020 project, aiming at developing a new collaborative governance model between administrations and private partners, including citizens. INTERLINK will provide a set of digital building blocks, called “Interlinkers”, with the view to implement the defined governance model and standardise the basic functionalities needed to enable private actors to cooperate in the delivery of a service.
    • Assisted a global insurance brokers group of companies in ensuring their readiness for uninterrupted personal data flows at the end of the Brexit transition period, taking into account the upcoming revision of standard contractual clauses and the post-Schrems II situation.
    • Assisted a client in developing a line of defence and arguments to challenge the request from a non-EEA-based enforcement to access the personal data of some of its EU-based customers, while preserving a good level of cooperation and constructive dialogue.
    • Counselled an international financial service institution in assessing roles of parties under GDPR and consequent compliance steps (including applicable contractual settings) in relation to the development of an e-wallet API. The representation included a determination of the likely GDPR nexus arising from the specifics of the EMV SRC “Click to Pay” standards.
    • Represented ILGA Europe on a pro bono basis in the privacy and cybersecurity aspects of the Hub, a resource-sharing tool for LGBTI activists in Europe and Central Asia.
    • Represented a major insurance group in its integration of EU operations from a cybersecurity and data privacy point of view.*
    • Assisted a regulated institution in the management, follow-up and remediation of a data breach. The representation includes dealing with the cross-border regulatory context.*
    • Counselled a chemical manufacturer in the privacy aspects of the deployment of a whistleblowing hotline solution.*
    • Advised, on a pro bono basis, the Red Cross EU Office, the European Council on Refugees and Exiles, Medair and the International Lesbian, Gay, Trans & Intersex Association in the review of their data mapping, legal basis for processing, privacy notices and privacy policies, and in their vendor remediation exercise.*
    • Represented clients in the cybersecurity and data privacy aspects of due diligence, SPA negotiation and integration.*
    • Counselled a Chinese financial institution in relation to the technical standards, organisational measures and incident reporting under the PSD2 and the interplay with GDPR and national laws implementing the NIS Directive.*
    • Assisted US B2B marketing companies, email service providers, payment services providers and an actor in the entertainment industry in assessing the impact of GDPR on their operations.*
    • Represented a hospitality client in the management of a high-profile data breach of its booking platform.*
    • Counselled an international financial service institution in designing and implementing a cloud-based SaaS monitoring tool aiming to protect the integrity of its systems and networks.*
    • Advised the United Nations regarding international legal issues related to e-evidence and processing of personal data for law enforcement purposes.*
    • Represented an Italian brand of shoes and clothing in its GDPR readiness exercise.
    • Assisted a global company providing payment solutions for an e-commerce app in assessing its role (data controller/data processor) and related requirements under GDPR.*
    • Advised clients in a number of industries, such as financial, marketing and insurance, in the drafting and negotiation of Art. 28 GDPR data processing agreements, representing both controllers and processors.*
    • Represented a leading supplier of automotive parts in dealing with the data privacy aspects of its global HR management and operations. The representation includes the assessment of the role of various group entities and analysing appropriate data transfer mechanisms to support the exchange of data necessary for staff appraisal.*
    • Developed a structured approach to GDPR compliance for several trade associations in multiple EU countries.*
    • Contributed to the HTNG Working Group on GDPR. The outcome is a white paper and self-assessment tool adopted in March 2018. The white paper describes key considerations of GDPR for the hospitality industry. The assessment tool aims to help professionals in the industry to evaluate their company’s ability to comply with the new regulation. Over 50 companies (from hotel brands, to software companies) participated in HTNG’s GDPR for Hospitality Workgroup.*

    *Matters handled at a prior firm.

    Education

    • Maastricht European Center of Privacy and Cybersecurity, DPO Certification Course, 2016
    • College of Europe, LL.M., 2016
    • Salento University, Master’s Degree, 2015

    Admissions

    • Brussels, 2020
    • Lecce, 2019

    Languages

    • English
    • Italian
    • French
    • Recognized as one of the 100 most powerful cyber women by the Women4Cyber Foundation in its book Hacking gender barriers: Europe’s top cyber women.

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    Speaking Engagements

    • Speaker, International Association of Privacy Professionals Mentor Q&A, 22 February 2023.
    • Speaker, “Practical Perspectives on International Transfers”, CPDP Conference, Brussels, 25 May 2022.
    • Speaker, “Cookies ... Old Recipe, Bad Taste?” IAPP Virtual Conference, 30 March 2022.
    • Speaker, “Virtual New Delhi KnowledgeNet”, IAPP KnowledgeNet Meeting, 25 March 2022.
    • Speaker, “The EU Al Act – Towards a ‘Human-Centric’ Al”, Law & Tech Course UCLouvain, 2 March 2022.
    • Speaker, “The Challenges of the Digitalization of the Sector: Artificial Intelligence Cyberattacks?” Abilways (Belgium) Compliance and Insurance Conference, 25 February 2022.
    • Speaker, “Law & Tech Governance Inaugural Lecture”, Law & Tech Course UCLouvain, 9 February 2022.
    • Speaker, “Workshop: Cybersecurity & Pharma: Patient Data, Public Perception & Preventing Attacks”, European Pharma Law Academy Day 5, Brexit & Beyond – Legal & Regulatory Compliance Issues, 21 January 2022.
    • Speaker, “Open Talk Around the EU Regulation of #AI”, Research Group on Data, Robotics, Artificial Intelligence, Law & Society (DRAILS), 4 May 2021.
    • Speaker, “2021 Privacy Challenges: Women Leading Privacy Have Their Say”, International Association of Privacy Professionals International Women’s Day Virtual Event, 11 March 2021.
    • Speaker, “Privacy is Fundamental, Right?” EU Law and Human Rights Course of the CEELI Institute, Prague, Czech Republic, 26 February 2021.
    • Speaker, “Shifting Responsibilities: The Challenges of Joint-Controllership”, Computer, Privacy & Data Protection International Conference, 28 January 2021.
    • Speaker, “Brexit and International Transfers of Personal Data 5 Action Points in 15 Days”, BIPAR Webinar, 14 December 2020.
    • Speaker, “Privacy & Cybersecurity Brexit Planning: 15 Actions in 15 Days Before the UK Goes Away”, CLEPA Webinar Series, 9 December 2020.
    • Speaker, “Data as a (New) Core Company Asset to Protect: Who’s Who?” UCLouvain Cybersecurity Month Seminars, 29 October 2020.
    • Speaker, “A Fireside Chat with Commissioner Didier Reynders on Europe’s Digital Future & Where Does Privacy Stand?” IAPP Brussels KnowledgeNet Chapter Meeting, Brussels, Belgium, 27 October 2020.
    • Speaker, “Cybersecurity as a Key European Policy: Right or Wrong?” Louvain-La-Neuve University Online Courses, 22 October 2020.
    • Speaker, “An Inside View from the Lawyer that Defended Max Schrems”, IAPP Brussels, Luxembourg, and Paris Joint KnowledgeNet Chapter Meeting, 24 September 2020.
    • Speaker, “Workshop: Cybersecurity & Pharma: Patient Data, Public Perception & Preventing Attacks”, EU Pharma Law Academy, 24 September 2020.
    • Speaker, “GDPR Second Year Anniversary Quiz”, International Association of Privacy Professionals, 25 May 2020.
    • Speaker, “Is Certification the Future of Privacy? Yes, No, Maybe?” International Association of Privacy Professionals Brussels KnowledgeNet Chapter, 3 February 2020.
    • Speaker, “Celebrate Data Privacy Day 2020”, International Association of Privacy Professionals Brussels KnowledgeNet Chapter, 28 January 2020.
    • Speaker, “Brexit, What does it mean?” Annual Hotels Technology Next Generation (HTNG) European Conference, Monte Carlo, Monaco, 18-19 November 2019.
    • Speaker, “University of Louvain Debate: Would You Trade Privacy Rights Against Data Security? Is There A (Healthy) Cyber Balance?” University of Louvain, Louvain, Belgium, 31 October 2019.
    • Speaker, “WWW (or What we Want for your Website)”, European Pro Bono Alliance, 25 October 2019.
    • Speaker, “Cybersecurity & Pharma: Patient Data, Public Perception & Preventing Attacks”, European Pharma Law Academy, Cambridge, UK, 9-12 September 2019.
    • Speaker, “GDPR After GDPR Day: Which Rating Does it Deserve?” Data Protection Forum Association of Consumer Credit Information Suppliers, Brussels, Belgium, 13 March 2019.
    • Speaker, “Drafting Vendor Agreements to Comply With EU GDPR: Steps to Take Now”, Strafford Webinar, 31 January 2019.
    • Speaker, “The Impact of GDPR on Clinical Trials”, Patient Engagement Through Education (EUPATI) Webinar, 29 October 2018.
    • Speaker, “GDPR & Data Breaches Management: 5 Lessons Learned”, European Conference of Hotel Technology Next Generation (HTNG), Lisbon, Portugal, 23-24 October 2018.
    • Speaker, “Public Affairs Post-GDPR: What You Need to Know”, Public Affairs Council Webinar, 12 June 2018.
    • Speaker, “GDPR Workshop – GDPR is There: Are you Ready?” European Council of Optometry and Optics Annual General Assembly, Pula, Croatia, 30 May 2018.
    • Speaker, “GDPR Workshop – GDPR is Coming: Are you Ready?” European Council of Optometry and Optics, 11 May 2018.
    • Speaker, “General Data Protection Regulation and NGOs: Are you Ready?” Advocates for International Development, 24 April 2018.
    • Speaker, “GDPR Breakfast Session”, United Network of Interventional Corporate Events Organizers, 30 March 2018.
    • Speaker, “Skills Development Program”, European Public Affairs Consultancies’ Association (EPACA), 26 March 2018.
    • Speaker, “General Data Protection Regulation”, Association of Mutual Insurers and Insurance Cooperatives in Europe (AMICE), Brussels, Belgium, 21 March 2018.
    • Speaker, “Legal Perspectives”, Humentum Legal Roundtable Covering Trending Cyber & Data Issues, Washington DC, 8 March 2018.

    Publications

    • Co-author, “Client Alert: Divergence or Re-brand? The UK AML Government Reveals More Information about its Proposals for a New Data Protection Regime Post-Brexit”, 28 June 2022.
    • Co-author, “All Things Seem to Come in Threes: The EU Continues with its Sanctions Against Cyber-Attackers for the Next Three Years”, 24 May 2022.
    • Co-author, “Client Alert: Stay Resilient: EU Reaches Agreements to Improve the Cybersecurity of Businesses Operating in Critical Sectors of the Economy”, 20 May 2022.
    • Co-author, “Client Alert: UK Government Announces Extensive Post-Brexit Changes to Data Privacy Laws”, 11 May 2022.
    • Co-author, “Client Alert: European Court Boosts Representative Actions for GDPR Infringements”, 5 May 2022.
    • Co-author, “Client Alert: Towards a European Data Economy? The EU’s Draft Data Sharing Rules”, 24 February 2022.
    • Co-author, “Client Alert: The UK Consults on Its Cyber Resilience Journey: Catching Up with EU Train or Changing Direction?” 2 February 2022.
    • Co-author, “Client Alert: Brexit One Year On”, 14 January 2022.
    • Co-author, “Client Alert: Losing Control: The Supreme Court Effectively Blocks Data Privacy Class Actions in the United Kingdom”, 10 November 2021.
    • Co-author, “Client Alert: European Commission Proposes to Overhaul Framework with New Legislative Package”, 16 August 2021.
    • Co-author, “Belgium: Balancing Data Protection and National Security”, July 2021.
    • Co-author, “Personal Data Transfers After Year Zero: A More Appealing Set of EDPB Recommendations?” July 2021.
    • Co-author, “Personal Data Transfers After Year Zero: Are the New SCCs a Paradigm Shift?” 30 July 2021.
    • Co-author, “Client Alert: European Commission Releases Proposed Regulation on Artificial Intelligence”, 22 April 2021.
    • Co-author, “Client Alert: NIST Gives Eight Keys to Better Lock (Back)Doors in Supply Chain Management”, 1 March 2021.
    • Co-author, “Client Alert: The Council Agrees on ePrivacy Regulation … Or When a Deal is Not ‘THE’ Deal”, 15 February 2021.
    • Co-author, “Recent EU Privacy Developments Are Not Just an EU Problem”, Bloomberg Law, 19 January 2021.
    • Co-author, “The Garante Public Consultation on Draft Cookies Guidelines: Our Response and Comments”, 12 January 2021.
    • Co-author, “Client Alert: The Urgent Need to Assess and Respond to Russian Supply Chain Attacks”, 22 December 2020.
    • Co-author, “New EU Cybersecurity Proposals: NIS 2 and Cyber Resilience of Critical Entities”, 21 December 2020.
    • Co-author, “Client Alert: European Commission Unveils Ambitious and Far-Reaching Legislative Proposals for Regulating Platforms, Hosting Services and Online Intermediaries”, 17 December 2020.
    • Co-author, “Client Alert: How to Protect the Internet of Things’ Supply Chain? Map and Act: ENISA is out with Guidelines”, 18 November 2020.
    • Co-author, “Client Alert: The 5 Things We Like – and the 5 We Do Not – in the EDPB Post-Schrems II Recommendations”, 12 November 2020.
    • Co-author, “Client Alert: How Does the EU Sanction Regime Impact the Ability to Pay Cyber Hackers?” 10 November 2020.
    • Co-author, “Client Alert: The How, Who and Why of Cyber Attacks In 2019/2020: Part 1 – Know Your Enemies”, 26 October 2020.
    • Co-author, “Client Alert: US DOE and NIST Partner to Improve Cybersecurity in Energy, Maritime Transportation Industries”, 22 October 2020.
    • Co-author, “Client Alert: Five Key Takeaways from OFAC and FinCEN’s Ransomware Advisories”, 20 October 2020.
    • Co-author, “Client Alert: CNIL Guidelines and Recommendations for Cookies’ Compliance are Now there to Stay”, 5 October 2020.
    • Co-author, “Client Alert: Boosting Innovation by Increased Oversight and Cybersecurity Resilience: The EU Cryptic Way of Promoting a Digital Single Market for Finance”, 1 October 2020.
    • Co-author, “Client Alert: Il Buono, Il Brutto, Il Cattivo – The EU, ‘AdTech’ and Social Media”, 16 September 2020.
    • Co-author, “Client Alert: Revised Guidelines on Controller & Processor under GDPR: The EDPB Is Back to School with Its First Philosophical Essay”, 9 September 2020.
    • Co-author, “Belgium: DPO Conflict of Interest”, OneTrust DataGuidance, June 2020.
    • Co-author, “Cybersecurity as a Driver of Trust in Connected and Automated Vehicles: Does the Current EU Framework(s) Pass the Crash Test?” From Autonomous Vehicles to Artificial Intelligence, Law, Politics and Ethics, 2020.
    • Co-author, “EU to Keep Its Ability to Sanction Foreign Cyber Attackers for One More Year”, Legal Update, 20 May 2020.
    • Co-author, “Undoing and Redoing Is Still Working (but Scrolling Down and Swiping Through Is Not Consenting)”, 7 May 2020.
    • Co-author, “Financial Stability Board Proposes Cyber Incident Response and Recovery Best Practices”, Legal Update, 4 May 2020.
    • Co-author, “EU Positions on Contact Tracing Applications During COVID-19: No Lockdown for Privacy & Cybersecurity”, 28 April 2020.
    • Co-author, “Data Protection Rules (Such as the GDPR) Do Not Hinder Measures Taken in the Fight Against the COVID-19 Pandemic”, 22 April 2020.
    • Co-author, “Advancing Software Security in the EU – The Role of the EU Cybersecurity Certification Framework: ENISA Puts Another Brick Towards a Wall of Cybersecurity Certification Schemes”, 21 April 2020.
    • Co-author, “Irish Data Protection Commission (DPC) Report on the Use of Cookies – No Need to Digest It All; We Serve Up the Tastiest Morsels”, 10 April 2020.
    • Co-author, “No One Is Perfect … Not Even the GDPR – #TellTheEUWhy”, 6 April 2020.
    • Co-author, “Sharing geolocation data during the COVID-19 pandemic in Europe”, Legal Update, 2 April 2020.
    • Co-author, “The European Commission proposes the creation of a single European data space”, Legal Update, 30 March 2020.
    • Co-author, “Managing Cybersecurity and Privacy Risks Through COVID-19”, 23 March 2020.
    • Co-author, “EU Commission Publishes Its White Paper on Artificial Intelligence: Will the EU Be (Again) a Rule Maker?” 19 February 2020.
    • Co-author, “10 Commandments for Processing Personal Data Through Video Devices in the EU”, 12 February 2020.
    • Co-author, “EDPB Issues Draft Guidelines on Processing Personal Data for Connected Vehicles”, 7 February 2020.
    • Co-author, “Cookies Consent: CNIL Steps in with a Proposal for Compliance”, 14 January 2020.
    • Co-author, “A Proposal for a European Cybersecurity Taxonomy – The End of the Tower of Babel?” Legal Update, 9 December 2019.
    • Co-author, “EU Cybersecurity Act Published”, 7 June 2019.
    • Co-author, “The GDPR: One Year On”, Legal Update, 24 May 2019.
    • Co-author, “Foreign Cyber Attackers to Face EU Sanctions”, Legal Update, 22 May 2019.
    • Co-author, “Using Performance of a Contract as a Legal Basis for Processing in the context of Online Services”, Legal Update, 2 May 2019.
    • Co-author, “One Size Does Not Fit All: EU Commission Recommendations on Cybersecurity in the Energy Sector”, 16 April 2019.
    • Co-author, “EU Cyber Threat Landscape and Outlook: What You Should Know about the ENISA 2018 Report”, Legal Update, 6 February 2019.
    • Co-author, “Free Flow of Personal Data Between the European Union and Japan Starts Now”, 23 January 2019.
    • Co-author, “Keeping It Private: GDPR and Developments in Data Privacy in 2018”, 14 January 2019.
    • Co-author, “EU-US Privacy Shield Undergoes Second Review by EU Commission and (Re)Passes the Test – For Certifying Companies, Santa Has Come to Town”, Legal Update, 26 December 2018.
    • Co-author, “The EU Cybersecurity Act is (Almost) There”, Legal Update, 12 December 2018.
    • Co-author, “EDPB’s new draft guidelines on the territorial scope of the GDPR”, Legal Update, December 2018.
    • Co-author, “5 Considerations for General Counsel Regarding the EU General Data Protection Regulation”, 30 October 2018.
    • Co-author, “How Many Stars Does France Deserve on Its GDPR Jersey? The French Umpire Makes Its Call”, 28 September 2018.
    • Co-author, “The GDPR Patchwork: What Does Italian Style Bring to the Show?” 21 September 2018.
    • Co-author, “The Clock Is Ticking: Negotiating an Enhanced EU Cybersecurity Framework”, 14 September 2018.
    • Co-author, “5 Lessons Learned on Data Breach Management after 2 Months of GDPR: Friday Is Calling”, Legal Update, 25 July 2018.
    • Co-author, “ePrivacy Regulation: What to Expect (and When) or Why Does It Take Two (or Even Three) to Tango?” Legal Update, 22 June 2018.
    • Co-author, “Toward an Enhanced EU Cybersecurity Framework: Political Agreement Reached on EU Cybersecurity Act”, Legal Update, 11 June 2018.
    • Co-author, “GDPR: European Data Protection Board Adopts Final Guidelines on Derogations Under Art. 49 and Draft Guidelines on Certification Under Art. 42”, Legal Update, 5 June 2018.
    • Co-author, “The GDPR: The Changes that Will Affect Your Business”, Legal Update, 25 May 2018.
    • Co-author, “GDPR Is (Almost) Here: What Does It Mean for Recruitment and Headhunting Companies?” Legal Update, 16 April 2018.
    • Co-author, “Exporting the EU Privacy Regime Through Trade Instruments?” Legal Update, 19 March 2018.
    • Co-author, “Electronic Discovery & Information Governance – Tip of the Month: Impact of New EU Privacy Law on US E-Commerce Businesses”, 27 February 2018.
    • Co-author, “How Will the GDPR Impact E-Commerce Businesses?” Legal Update, 9 February 2018.
    • Co-author, “New Draft Consent Guidelines under the GDPR: What You Need to Know”, Legal Update, 15 December 2017.
    • Co-author, “EU Commission: Privacy Shield Framework Adequate but More Can Be Done”, Legal Update, 20 October 2017.
    • Co-author, “Data Breach Notification Requirements Coming from EU Expand Obligations for Organizations Worldwide”, Legal Update, 21 September 2017.
    • Co-author, “EU Data Protection Authorities Issue Draft Guidance on When Data Protection Impact Assessments Are Required under New GDPR”, Legal Update, 20 April 2017.
    • Co-author, “Electronic Discovery & Information Governance – Tip of the Month: Preparing to Comply with the EU General Data Protection Regulation”, 7 March 2017.
    • Co-author, “WP29 Guidance on GDPR Implementation Issued – Have Your Say”, In Brief, 16 December 2016.
    • Co-author, “A new EU framework on cybersecurity: the Network and Information Security Directive”, Legal Update, 26 July 2016.
    • Co-author, “Privacy Shield is Here. Now What?” Legal Update, 15 July 2016.
    • Co-author, “Recent Developments Regarding the New EU-US Privacy Shield Framework”, Legal Update, 8 March 2016.
    • Co-author, “EU and US agree scheme to replace Safe Harbor: EU-US Privacy Shield”, Legal Update, 3 February 2016.
    • Co-author, “Redefining Data Protection? Court of Justice of the European Union Strikes Down the Commissions ‘Safe Harbor’ Decision”, 8 October 2015.
    • Co-author, “Court of Justice of the European Union holds that ‘Safe Harbor’ decision of European Commission is invalid”, Legal Update, 6 October 2015.
    • Co-author, “Cybersecurity Cross-Border Map”, DataGuidance, September 2019.
    • Co-author, “EU Cyber Threat Landscape and Outlook: What You Should Know About the ENISA Report”, Pratt’s Privacy & Cybersecurity Law Report, June 2019.
    • Co-author, “Preparing for the EU’s New Data Protection Regime”, Corporate Secretary, 2 January 2018.
    • Co-author, “E-Privacy Regulation – An Outlook on the New Framework”, The European Files, September 2017.

    Note these publications were produced while at a former firm.

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