site_policies/languagenut_privacy.txt

SITE:  languagenut_privacy
URL:   https://www.languagenut.com/en-au/privacy-policy/


PRIVACY POLICY

   Languagenut Limited ("we", "us", "our") is committed to protecting and
   respecting your privacy.

   This privacy policy, ("Privacy Policy") and any other documents
   referred to in it, sets out the basis on which we collect and process
   your personal data as a data controller when you use our website or
   services.

   Please read the following carefully to understand our views and
   practices regarding your personal data and how we will treat it. By
   visiting www.languagenut.com, ("Site") or using our services or apps,
   ("Services") you are accepting and consenting to the practices
   described in this Privacy Policy.

   Please note:

   This Privacy Policy does not apply to any data you provide to us when
   we process personal data on your behalf as your data processor i.e.
   where we process customer data within the cloud service we provide to
   you, as a business to business service provider.

   DATA CONTROLLER

   For the purposes of EU and UK data protection laws and any applicable
   national implementing laws, regulations and secondary legislation
   relating to the processing of personal data (together "Data Protection
   Law"), the data controller is Languagenut Limited of Projects The
   Lanes, Nile House, Nile Street, Brighton, BN1 1HW, England, company
   number insert 07401600.

   DATA PROTECTION OFFICER

   We have appointed a data protection officer ("DPO") who is responsible
   for overseeing questions about this Privacy Policy who can be contacted
   as set out at the end of this Privacy Policy.

   LEGAL BASIS FOR PROCESSING

   We will only use your personal data when the law allows us to. Most
   commonly we will use your personal data in the following circumstances:
     * To fulfil our contractual obligations to you.

     * Where it is necessary for our legitimate business interests (or
       those of a third party) and your interests and fundamental rights
       do not override those interests.
     * To comply with a legal obligation

   To the extent we process your personal data for any other purposes, we
   ask for your consent in advance or require that our partners obtain
   such consent.

   PERSONAL DATA WE MAY COLLECT ABOUT YOU

   We may collect and process personal data about you. Personal data, or
   personally identifiable information, means any information about an
   individual from which that individual can be identified. It does not
   include data where the identity has been removed (anonymous data). We
   collect, use, store and transfer different kinds of personal data about
   you which we have grouped together as follows:
     * Identity Data: includes first name, last name, user name or similar
       identifier.
     * Contact Data: includes billing address, name and address, of
       school, email address and telephone numbers.
     * Financial Data: includes bank account and payment card details.
     * Transaction Data: includes details about payments to and from you
       and other details of products and services you have purchased from
       us.
     * Technical Data: includes internet protocol (IP) address, your login
       data, browser type and version, time zone setting and location,
       browser plug-in types and versions, operating system and platform,
       and other technology on the devices you use to access this Site or
       the Services.
     * Profile Data: includes your username and password, purchases or
       orders made by you, your interests, preferences, feedback and
       survey responses.
     * Usage Data: includes information about how you use our Site and
       Services, including the full Uniform Resource Locators (URL)
       clickstream to, through and from our Site and Services (including
       date and time); products you viewed or searched for; page response
       times, download errors, length of visits to certain pages, page
       interaction information (such as scrolling, clicks, and
       mouse-overs), and methods used to browse away from the page and any
       phone number used to call our customer service number.
     * Marketing and Communication Data: includes your preferences in
       receiving marketing from us and our third parties and your
       communication preferences.
     * Location Data: We also use GPS technology to determine your current
       Some of our location-enabled Services require your personal data
       for the feature to work. If you wish to use the particular feature,
       you will be asked to consent to your data being used for this
       purpose. You can withdraw your consent at any time by disabling
       Location Data in your settings.
     * Aggregated Data: We also collect, use and share statistical or
       demographic data for any purpose. This Aggregated Data could be
       derived from your personal data but is not considered personal data
       in law as this data will not directly or indirectly reveal your
       identity. For example, we may aggregate your Usage Data to
       calculate the percentage of users accessing a specific website
       feature. However, if we combine or connect Aggregated Data with
       your personal data so that it can directly or indirectly identify
       you, we treat the combined data as personal data which will be used
       in accordance with this Privacy Policy.
     * Special Category Data: We do not collect, store and/or use special
       category data about you. This includes details about your race or
       ethnicity, religious or philosophical beliefs, sex life, sexual
       orientation, political opinions, trade union membership,
       information about your health, and genetic and biometric data.

   If you fail to provide personal data

   Where we need to collect personal data by law, or under the terms of a
   contract we have with you, and you fail to provide that data when
   requested, we may not be able to perform the contract we have or are
   trying to enter into with you (for example, to provide you with goods
   or services). In this case, we may have to cancel a product or service
   you have with us but we will notify you if this is the case at the
   time.

   HOW PERSONAL DATA IS COLLECTED

   We use different methods to collect data from and about you including
   via:
     * Direct You may give us your Identity, Contact and Financial Data
       when you fill in forms or correspond with us by post, phone, email
       or otherwise. This includes personal data you provide when you
       register to use our Site or to receive our newsletter, subscribe to
       use our Services, create an account to use our Site or Services,
       request marketing to be sent to you, search for a product or place
       an order on our Site, participate in discussion boards or other
       social media functions on our Site, enter a competition, promotion
       or survey, attend a conference or webinar, give us feedback or
       contact us and when you report a problem with our Site or Services.
     * Purchases: If you make purchases via our Site or within any
       Services, or register for an event or webinar, we may require you
       to provide your Identity, Contact, Financial and Transaction Data.
     * Community: If you register for an online community that we provide,
       we may ask you to provide us with Identity, Contact, Profile and
       Technical Data.
     * Automated Technologies or Interactions. As you interact with our
       Services, Sites or emails, we automatically collect Technical Data
       about your device, browsing actions, patterns, Location Data and
       Usage Data. We collect this personal data by using cookies, server
       logs, web beacons, pixels, and similar technologies about your
       device, and your use of our Site and Services. We may also receive
       Technical Data and Location Data about you if you visit other
       websites using our cookies. Please see the Cookie section below for
       further details.

   PERSONAL DATA WE RECEIVE FROM OTHER SOURCES

   We work closely with the third parties set out in our Third Party
   Supplier List which includes, for example, business partners,
   sub-contractors in technical, payment and delivery services,
   advertising networks, analytics providers, search information
   providers, credit reference agencies and may receive the following
   personal data about you from them:
     * Technical Data: from analytics providers, advertising networks and
       search information providers
     * Contact, Transaction and Financial Data: from providers of
       technical, payment and delivery services.
     * Identity and Contact Data: from providers of
       chat/communication/helpdesk services with customers including via
       email.
     * Email Communications and Contact Data: from providers of email
       communications service providers.
     * Business Contact and Financial Data: from CRM service providers who
       manage contacts and keep a record of communications/ interactions
       with customers.
     * Contact Data and Financial Data: from cloud accounting systems that
       store email and names of persons sent invoices by email.

   PERSONAL DATA WE COLLECT FROM OTHER SOURCES

   We also collect personal data about you from publicly available
   sources. We may combine this information with personal data provided by
   you. This helps us update, expand, and analyse our records, identify
   new customers, and create more tailored advertising to provide services
   that may be of interest to you. We also use this for the purposes of
   targeted advertising, delivering relevant email content, event
   promotion and profiling, determining eligibility and verifying Contact
   Data. The personal data we collect includes:
     * Identity and Contact Data: from publicly available sources such as
       Companies House.
     * Identity, Contact and Profile Data: that is published about you on
       social media profiles: such as LinkedIn, Facebook, Twitter.

   COOKIES

   We use cookies or similar technology, on our Site and in the Services
   to distinguish you from other users of our Site and Services. This
   helps us to provide you with a good experience when you browse our Site
   and also allows us to improve the Site and Services.

   What are cookies

   Cookies are small text files that are placed on your computer by
   websites that you visit. They are widely used in order to make websites
   work, or work more efficiently, as well as to provide information to
   the owners of the website. Cookies can be "persistent" or "session"
   cookies.

   We use persistent cookies and session cookies.

   Persistent Cookies

   A persistent cookie is stored on a user's device in between browser
   sessions which allows the preferences or actions of a user across the
   Site (or in some cases across different websites) to be remembered. We
   use persistent cookies to save your login information for future logins
   to the Site or Services.

   Session Cookies

   A session cookie allows the Site or Services to link your actions
   during a browser session. We use session cookies to enable certain
   features of the Site or Services, to better understand how you interact
   with the Site or Services and to monitor aggregate usage by users and
   web traffic routing on the Site. Unlike persistent cookies, session
   cookies are deleted from your computer when you log off from the Site
   or Services and then close your browser.

   Which cookies we use and why

   The table below explains the cookies we use and why we use each of
   them.
   Cookie Type Purpose Duration
   Google Analytics Tracking cookies

   These cookies are used to collect information about how visitors use
   our Site. We use the information to compile reports and to help us
   improve the Site. The cookies collect information in an anonymous form,
   including the number of visitors to the Site, where visitors have come
   to the Site from and the pages they visited. If you do not allow these
   cookies we will not be able to include your visit in our statistics.
   You can read the full Google Analytics    privacy    policy    at:

   http://www.google.com/policies/privacy/.
   1 week
   Anonymous Analytics Analytics cookies.

   We use analytics cookies to tell us whether

   you have visited the Site previously, and to gather statistics about
   visits to a page.
   1 week
   Geotargeting Location cookies

   These cookies are used by software which tries to work out what country
   you are in from information supplied by your browser when it requests a
   web page. This cookie is completely anonymous, and is only used to

   help target content.
   1 week
   Registration Signin cookies

   When you sign in, we generate cookies that let us know whether you are
   signed in or not. Our servers use these cookies to work

   out which account you are signed in with.
   1 week


   You can set up your browser options, to stop your computer accepting
   cookies or to prompt you before accepting a cookie from the websites
   you visit. If you do not accept cookies, however, you may not be able
   to use the whole of the Site or all functionality of the Services.

   To find out more about cookies, including how to see what cookies have
   been set and how to manage and delete them,
   visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of
   being tracked by Google Analytics across all websites
   visit http://tools.google.com/dlpage/gaoptout.

   Do not track

   We do not support Do Not Track ("DNT").

   Do Not Track is a preference you can set in your web browser to inform
   websites that you do not want to be tracked. You can enable or disable
   Do Not Track by visiting the "Preferences" or "Settings" page of your
   web browser.

   USES MADE OF PERSONAL DATA

   We have set out below, in a table format, a description of all the ways
   we plan to use your personal data, and which of the legal bases we rely
   on to do so. We have also identified what our legitimate interests are
   where appropriate.

   Note that we may process your personal data for more than one lawful
   basis depending on the specific purpose for which we are using your
   data. Please contact us if you need details about the specific legal
   ground we are relying on to process your personal data where more than
   one ground has been set out in the table below.
   Purpose/Activity                  Type of Data Lawful basis for processing
   To register you as a new customer

   (a)  Identity Data

   (b)  Contact Data
   Performance of a contract with you

   To process and deliver your order including:

   (a)   Manage payments, fees and charges

   (b)      Collect    and    recover money owed to us

   (a)  Identity Data

   (b)  Contact Data

   (c)  Financial Data

   (d)  Transaction Data

   (e)        Marketing     and Communications Data

   (a)  Performance of a contract with you

   (b)   Necessary for our legitimate interests (to recover debts due to
   us)

   To manage our relationship with you which will include:

   (a)      Notifying you about changes to our terms, this Privacy Policy,
   the Site or Services

   (a)  Identity Data

   (b)  Contact Data

   (c)  Profile Data

   (d)        Marketing     and Communications Data

   (a)  Performance of a contract with you

   (b)   Necessary to comply with a legal obligation

   (c)   Necessary for our legitimate interests (to keep our records


   (b) Asking you to leave a review or take a survey updated and to study
   how customers             use             our products/services)
   To enable you to partake in a prize draw, competition or complete a
   survey

   (a)  Identity Data

   (b)  Contact Data

   (c)  Profile Data

   (d)  Usage Data

   (e)        Marketing     and Communications Data

   (a)  Performance of a contract with you

   (b)   Necessary for our legitimate interests (to study how customers
   use our products/services, to develop them and grow our business)
   To administer and protect our business and this Site (including
   troubleshooting, data analysis, testing, system            maintenance,
   support, updates, reporting and hosting of data)

   (a)  Identity Data

   (b)  Contact Data

   (c)  Technical Data

   (a)   Necessary for our legitimate interests (for running our
   business,          provision          of administration and IT
   services, network security, to prevent fraud and in the context of a
   business reorganisation or group restructuring exercise)

   (b)   Necessary to comply with a legal obligation
   To deliver relevant Site and Services content and advertisements to you
   and measure or understand the effectiveness of the advertising we serve
   to you

   (a)  Identity Data

   (b)  Contact Data

   (c)  Profile Data

   (d)  Usage Data

   (e)        Marketing     and Communications Data

   (f)  Technical Data
   Necessary for our legitimate interests (to study how customers use our
   products/services, to develop them, to grow our business and to inform
   our marketing strategy)
   To use data analytics to improve our Site and Services,
   marketing, customer relationships and experiences

   (a)  Technical Data

   (b)  Usage Data
   Necessary for our legitimate interests (to define types of customers
   for our products and services, to keep our website updated and
   relevant, to develop our business and to inform our marketing strategy)
   To make suggestions and recommendations to you about goods or services
   that may be of interest to you

   (a)  Identity Data

   (b)  Contact Data

   (c)  Technical Data

   (d)  Usage Data

   (e)  Profile Data

   (f)      Marketing      and Communications Data
   Necessary for our legitimate interests (to develop our Services and
   grow our business)

   We will not sell or rent your personal data to anyone.

   We will only use your personal data for the purposes for which we
   collected it, unless we reasonably consider that we need to use it for
   another reason and that reason is compatible with the original purpose.
   If you wish to get an explanation as to how the processing for the new
   purpose is compatible with the original purpose, please contact us.

   Please note that we may process your personal data without your
   knowledge or consent, in compliance with the above rules, where this is
   required or permitted by law.

   DISCLOSURE OF YOUR PERSONAL DATA

   Personal data we share with third parties. We may share your personal
   data with the third parties set out in our Third Party Supplier List
   for the purposes set out in the table above. Below is a summary of the
   types of third parties used:
     * Any member of our group, which means our subsidiaries, our ultimate
       holding company and its subsidiaries, as defined in section 1159 of
       the UK Companies Act 2006.
     * Business partners, suppliers and sub-contractors for the
       performance of any contract we enter into with them or you to
       provide services such as IT and system administration services,
       email communications, hosting services, backup services, credit
       card processing, research, development, marketing and customer
       support.
     * Analytics and search engine providers that assist us in the
       improvement and optimisation of our Site and Services.
     * Professional advisors acting as service providers to us in relation
       to the Site or Services - including lawyers, bankers, auditors, and
       insurers who provide consultancy, banking, legal, insurance and
       accounting services.
     * Tax authorities, regulators and other authorities who require
       reporting of processing activities in certain circumstances.
     * Advertisers and advertising networks that require the data to
       select and serve relevant adverts to you and others. We do not
       disclose personal data about identifiable individuals to our
       advertisers, but we may provide them with Aggregated Data about our
       users (for example, we may inform them that 250 men aged over 25
       have clicked on their advertisement on any given day). We may also
       use such Aggregated Data to help advertisers reach the kind of
       audience they want to target (for example, women living in London).
       We may make use of the personal data we have collected from you to
       enable us to comply with our advertisers' wishes by displaying
       their advertisement to that target audience.
     * Credit reference agencies for the purpose of assessing your credit
       score where this is a condition of us entering into a contract with
       you.

   Personal data we disclose to third parties. We may disclose your
   personal data to third parties:
     * In the event that we sell or buy any business or assets, in which
       case we may disclose your personal data to the prospective seller
       or buyer of such business or assets.
     * If we or a member of our group of companies or substantially all of
       their assets are acquired by a third party, in which case personal
       data held by them about their customers will be one of the
       transferred assets.
     * If we are under a duty to disclose or share your personal data in
       order to comply with any legal obligation, or in order to enforce
       or apply our terms and conditions, terms of use and/or any other
       legal agreements; or to protect our rights, property, safety, our
       customers or others. This includes exchanging information with
       other companies and organisations for the purposes of fraud
       protection and credit risk reduction.
     * Including Aggregated Data in the normal course of operating our
       business; for example, with other Site or Services users, our
       customers or publicly to show trends or benchmark the general use
       of our Site and Services.

   INTERNATIONAL TRANSFERS

   Our Services are global and your personal data may be stored and
   processed in any country where we have operations, our staff are
   located or where we engage service providers engaged in, among other
   things, the fulfilment of your order, the processing of your payment
   details or the provision of support services. This will involve a
   transfer of your personal data to countries outside of your country of
   residence, where data protection rules are different from those of your
   country of residence.

   Processing of your personal data will involve a transfer of data to
   countries outside the European Economic Area ("EEA"), Switzerland or
   the UK.

   We will take all steps reasonably necessary to ensure that your
   personal data is treated securely and in accordance with this Privacy
   Policy. In particular, this means that your personal data will only be
   transferred to a country that provides an adequate level of protection
   (for example, where the European Commission or the UK Data Protection
   Authority, ("ICO") has determined that a country provides an adequate
   level of protection) or where the recipient is bound by standard
   contractual clauses according to conditions provided by the European
   Commission or ICO.

   Our Site and Services are accessible via the internet and may
   potentially be accessed by anyone around the world. Other users may
   access the Site or Services from outside the EEA, Switzerland or the
   UK. This means that where you chose to post your personal data on our
   Site or within the Services, it could be accessed from anywhere around
   the world and therefore a

   transfer of your personal data outside of the EEA, Switzerland or the
   UK may be deemed to have occurred.

   DATA SECURITY

   We have put in place appropriate security measures to prevent your
   personal data from being accidentally lost, used or accessed in an
   unauthorised way, altered or disclosed. For example, all information
   you provide to us is stored on our secure servers. Any credit card
   information or payment transactions will be encrypted using SSL
   technology. Where we have given you (or where you have chosen) a
   password which enables you to access certain parts of the Site or
   Services, you are responsible for keeping this password confidential.
   We ask you not to share any password with anyone. In addition, we limit
   access to your personal data to those employees, agents, contractors
   and other third parties who have a business need to know. They will
   only process your personal data on our instructions and they are
   subject to a duty of confidentiality.

   We have put in place procedures to deal with any personal data breach
   and will notify you and any applicable regulator of a breach where we
   are legally required to do so.

   Unfortunately, the transmission of information via the Internet is not
   completely secure. Although we will endeavour to protect your personal
   data, we cannot guarantee the security of your personal data
   transmitted to our Site or the Services. Any transmission is at your
   own risk. Once we have received your personal data, we will use strict
   procedures and security features to try to prevent unauthorised access.

   LINKS TO OTHER WEBSITES

   Our Site and Services may, from time to time, contain links to and from
   the websites of our partner networks, advertisers and affiliates. If
   you follow a link to any of these websites, please note that these
   websites have their own privacy policies and that we do not accept any
   responsibility or liability for these policies. Please check these
   policies before you submit any personal data to these websites.

   USE OF BLOGS, FORUMS AND CHAT ROOMS

   Any information that you post to areas of the Site or Services that are
   viewable by others (for example, to a blog, forum or chat-room) will
   not be treated as proprietary, private, or confidential. We have no
   obligation to monitor such posts to the Site or Services or to exercise
   any editorial control over such posts; however, we reserve the right to
   review such posts and to remove any material that, in our judgment, is
   not appropriate. Posting, transmitting, promoting, using, distributing
   or storing content that could subject us to any legal liability,
   whether in tort or otherwise, or that is in violation of any applicable
   law or regulation, or otherwise contrary to commonly accepted community
   standards, is prohibited, including without limitation information and
   material protected by copyright, trademark, trade secret, nondisclosure
   or confidentiality agreements, or other intellectual property rights.

   YOUR RIGHTS

   You have the right under Data Protection Law, free of charge, to
   request:
     * Access to your personal data.
     * Rectification or deletion of your personal data.
     * A restriction on the processing of your personal data.
     * Object to the processing of your personal data.
     * A transfer of your personal data (data portability) in a
       structured, machine readable and commonly used format.
     * Withdraw your consent to us processing your personal data, at any
       time.

   If you wish to exercise any of the above rights, please contact us as
   set out at the end of this Privacy Policy. We will respond to such
   queries within 30 days and deal with requests we receive from you, in
   accordance with the provisions of Data Protection Law. Occasionally it
   could take us longer, if your request is particularly complex or you
   have made a number of requests. In this case, we will notify you and
   keep you updated.

   You will not have to pay a fee to access your personal data (or to
   exercise any of the other rights). However, we may charge a reasonable
   fee if your request is clearly unfounded, repetitive or excessive.
   Alternatively, we could refuse to comply with your request in these
   circumstances.

   We may need to request specific information from you to help us confirm
   your identity and ensure your right to access your personal data (or to
   exercise any of your other rights). This is a security measure to
   ensure that personal data is not disclosed to any person who has no
   right to receive it. We may also contact you to ask you for further
   information in relation to your request to speed up our response.

   MARKETING COMMUNICATIONS
     * Marketing: We may use your Identity, Contact, Technical, Usage and
       Profile Data to form a view on what we think you may want or need,
       or what may be of interest to you. This is how we decide which
       products, services and offers may be relevant for you (we call this
       marketing).
     * Promotional Offers from us: We will send you marketing emails if
       you "opt in" to receive marketing emails when registering on our
       Site, or if you have enquired about, or purchased any of our goods
       or services from us and you have not opted out of receiving such
       marketing.
     * Third Party Marketing: We will obtain your express opt-in consent
       before we share your personal data with any third party for
       marketing purposes.
     * Opt out: Please note that, if you change your mind about being sent
       marketing emails you can "opt out" at any time by clicking the
       "unsubscribe" link at the bottom of any marketing email. Once you
       "opt out", you will no longer receive any marketing emails from us.
       We will continue to communicate with you regarding your service
       billing and support via email and where we send push notifications
       from time to time in order to update you about any service updates,
       events and promotions we may be running. If you no longer wish to
       receive these communications, please disable these in the settings
       on your device.

   DATA RETENTION

   We retain personal data for as long as reasonably necessary to fulfil
   the purposes for which it was provided or collected, including for the
   purposes of satisfying any legal, regulatory, tax, accounting or
   reporting requirements. We may retain your personal data for a longer
   period in the event of a complaint, if we reasonably believe there is a
   prospect of litigation in respect of our relationship with you, to
   comply with law enforcement requests, maintain security, prevent fraud
   and abuse, resolve disputes, enforce our legal agreements, or fulfil
   your request to "unsubscribe" from further messages from us.

   To determine the appropriate retention period for personal data, we
   consider the amount, nature and sensitivity of the personal data, the
   potential risk of harm from unauthorised use or disclosure of your
   personal data, the purposes for which we process your personal data and
   whether we can achieve those purposes through other means, and the
   applicable legal, regulatory, tax, accounting or other requirements.

   This will be for as long as we provide access to the Site or Services
   to you, your account with us remains open or any period set out in any
   relevant contract you have with us. After you have closed your account
   or ceased using the Services as set out below.

   We will retain some anonymised information after your account has been
   closed and we may use this for research or statistical purposes, in
   which case we may use this information indefinitely without further
   notice to you.

   Please note: After you have closed your account or deleted information
   from your account, any information you have shared with others will
   remain visible. We do not control data that other users may have copied
   from the Site or Services. Your profile may continue to be displayed in
   the services of others (e.g. search engine results) until they refresh
   their cache.

   COMPLAINTS

   Our intention is to meet the highest standards when collecting and
   using personal data. For this reason, we take complaints we receive
   very seriously. We encourage users to notify us if they think that our
   collection or use of personal data is unfair, misleading or
   inappropriate. If you have any complaints about our use of your
   personal data, please contact us as set out at the end of this Privacy
   Policy or contact your local data protection supervisory authority.

   For UK individuals: The Information Commissioner's Office at, Wycliffe
   House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

   Our EU representative is reachable at suppliers@languagenut.com.

   CHANGES TO OUR PRIVACY POLICY

   Any changes we may make to our Privacy Policy in the future will be
   posted on this page and, where appropriate, notified to you by email.
   Please check back frequently to see any updates or changes to our
   Privacy Policy.

   This Privacy Policy was last updated on 4^th October 2022 and this
   version replaces any other Privacy Policy previously applicable from
   this date.

   CONTACT

   Our DPO is reachable at suppliers@languagenut.com.

   If you have any questions, comments, or requests regarding our privacy
   practices or about this Privacy Policy please contact us as follows:

   By post: Languagenut Limited, Projects The Lanes, Nile House, Nile
   Street, Brighton, BN1 1HW

   By email: support@languagenut.com.

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