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CLICK HERE TO PRINT THE BNI®
PRIVACY POLICY IN ENGLISH.
Effective/Last Updated: May 25, 2018
BNI®
BNI Worldwide Development Ltd controls data related to BNI’s
operating management system known as BNI Connect®
for and on behalf of BNI Global, LLC, together with its related
affiliates BNI Singapore Enterprises Pvt Ltd, BNI India
Enterprises Pvt Ltd, BNI Franchising, LLC, BNI Connect Global,
LLC, BNI Hong Kong Enterprises Pvt Ltd, BNI Lanka Enterprises
Pvt Ltd, and BNI Enterprise Business Network (Guangzhou) Co Ltd
(“BNI”, “our”
or “we”)
prioritizes the privacy of our
users, and has developed this privacy policy to show our
commitment to that and to explain how we use certain information
("Privacy Policy").
This Privacy Policy is intended to explain to you, as a user of
BNI or our services, what information we collect, how we use
that information, with whom it may be shared, and your options
about such uses and disclosures. If you have any questions or
suggestions regarding this Privacy Policy, please email our Data
Protection Officer (“DPO”) at
dpo@bni.com.
We encourage you to read this Privacy Policy carefully when
using our Sites or services or transacting business with us. By
using our Sites and associated products and/or services, you are
accepting the practices described in this Privacy Policy and the
data collection and use practice described in this policy.
As with
BNI’s
ToS, the mere act of visiting our Sites or web-accessed or
mobile applications (our “Sites”), even without reading the
subject legal document, will be viewed as acceptance of the
terms contained in the Privacy Policy.
In the event of inconsistency between any terms of this contract
and any translation into another language, the English version
will control and prevail on any question of interpretation or
otherwise.
Privacy Philosophies
Information We Collect About You
A.
General.
In order to better provide you with the products and
services offered on the Site, we collect two types of
information about our users: personally identifiable information
and aggregate information.
Personally identifiable information refers to information that
lets us know the specifics of who you are. When you engage in
certain activities on our Sites, such as registering for an
account, purchasing a product, submitting content and/or posting
content on any of our blogs, or sending us feedback, we may ask
you to provide certain information about yourself. Examples of
personally identifiable information may include your first and
last name, email address, mailing address, telephone numbers,
age group, gender and other identifying information. When
setting up your profile on our Sites, you may be asked to
provide an e-mail address, phone number, and address.
Aggregate information refers to information that does not by
itself identify a specific individual. We gather certain
information about you based upon where you visit on our Sites,
and what other sites may have directed you to us. This
information, which is collected in a variety of different ways,
is compiled and analyzed on both a personal and an aggregated
basis. This technology
enables us to determine (i) your IP Address of your
computer and its geographic location from installing the
Applications onto your computer, mobile device or through your
GPS of your mobile device; (ii) your search terms or interactive
behavior via BNI’s websites; (iii) your purchasing behavior;
(iv) source of the information sought by you during your search;
and (v) the age of your results data (collectively, “Shared
Information”).
We may use the information you provide in aggregate form for
internal business purposes, such as generating statistics and
developing marketing plans.
B.
Other
Information You Provide.
We may also collect and store any personal information you enter
on our Sites or provide to us in some other manner, including
personal information that may be contained in any comment you
post to our Sites. This includes identifying information, such
as your name, address, e-mail address, and telephone number (if
provided and applicable); your likeness (both still and moving);
and, if you transact business with us or our partner, limited
financial information such as your payment method (valid credit
card number, type, expiration date or other financial
information).
C.
Information
About Others. We may also collect and store personal
information about other people provided to us by members,
including their businesses, contact details including email
addresses and/or IP addresses. This data is used in the
legitimate interests of members, for the purposes of generating
their invitations to non-members to Chapter meetings and other
BNI events, and for business-to-business referrals between
members for the potential purchase of goods or services from
non‑members.
D.
Sweepstakes and Contests. When
BNI
offers sweepstakes or contests, personal information is
collected with the sole purpose of notifying you if you win the
sweepstakes or contest.
E.
Automatic Collection of Data.
Information concerning your computer hardware and
software are automatically collected and may be shared with
other
BNI
or affiliated websites. This information may include: your IP
address, browser type and language, domain names, access times,
referring website addresses and
the content of any undeleted cookies that your browser
previously accepted from us (see "Cookies"
below).
BNI
uses this information to maintain the quality of its service and
to provide general statistics about website visitors.
Cookies.
When you visit our Sites, we may use one or more "Cookies" to
make our Sites easier for you to use and to personalize your
online experience. Through the use of a cookie, we also may
automatically collect information about your online activity on
our Sites, such as the web pages you visit, the links you click,
and the amount of time you spend on the website. You can remove
or block cookies using your settings in most browsers, but if
you choose to decline cookies, you may not be able to sign in or
use some of the features offered on our Sites.
Other Technologies.
We may use the ever-evolving Internet technology, such as web
beacons and other similar technologies, to track your use of our
Sites. We also may include web beacons in company e-mail
messages, newsletters, or notifications to determine whether
messages have been opened and/or acted upon. This enables us to
customize the services we offer our Sites visitors to deliver
targeted advertisements and to measure the overall effectiveness
of our online advertising, content, programming or other
activities.
Information Collected By Third Parties.
We may allow third parties, including advertising companies, and
ad networks, to display advertisements on our Sites. These
companies may use tracking technologies, such as cookies, to
collect information about users who view or interact with their
advertisements. Unless expressly stated otherwise, our Sites do
not provide any personal information to these third parties.
This information may allow them to deliver targeted
advertisements and gauge their effectiveness. If you have
questions or concerns about this, please email our DPO at
dpo@bni.com.
Information From Other Sources.
We sometimes supplement the information that we receive
that has been outlined in this Privacy Policy with information
from other sources and companies. Such outside information
includes updated delivery and address information from carriers
or third parties, which enables us to correct our records and
deliver, for example, future communications more easily; account
information, purchase or redemption information, and page-view
information from some merchants with which we operate co-branded
businesses or for which we provide technical, fulfilment,
advertising, or other services; search term and search result
information from some searches conducted through the Web search
features; search results and links, including paid listings
(such as Sponsored Links from Google); and credit history
information from credit bureaus, which we use to help prevent
and detect fraud and to offer certain credit or financial
services to some customers.
F.
Storage and Transfer of Personally Identifiable
Information.
BNI
may store and process in the United States or any other country
in which
BNI
or its affiliates, subsidiaries, or agents maintain data
facilities.
How We Use the Information We Collect
A.
General.
We will primarily use your personally identifiable information
to fulfil our contract to provide support or service offerings
to you. Specifically, BNI
collects and uses your personal information in order to:
1.
operate the Sites and to deliver the services that you have
requested;
2.
manage your account and provide you with customer support;
3.
perform research and analysis about your use of (personal and
aggregate), or interest in, our products, services, or content,
or products, services or content offered by others; this
information may be used, by way of example only, to help us
understand the demographics of our members, identify chapters
with openings for certain professions, inform future marketing
campaigns, and judge the success of members and identify
coaching strategies.
4.
cross market your services/products with our services and our
affiliates’ services
5.
verify your eligibility and deliver online and/or offline in
connection with contests and sweepstakes;
6.
enforce our terms and conditions;
7.
manage our business;
8.
enable and leverage applications such as BNI Connect to provide
user functionality; and
9.
perform functions as otherwise described to you at the time of
collection.
When you join BNI or visit a BNI-related website, we will not
collect any personally identifiable information about you unless
you choose to provide such information to us. You agree that
when you provide your personal identifiable information to us,
BNI and its affiliated BNI franchisees may use your information
to promote you and BNI. We want
your information and preferences to be accurate and complete.
You may request access to any personal information and
preferences that you have provided to us and correct, modify or
update such information and/or preferences by sending an email
with your request to
dpo@bni.com.
The collection of your e-mail address and name if and when
requested during account registration enables
BNI and its affiliates
to send you any requested newsletter(s) or to send you any
requested mailings or offers. If applicable, you will be allowed
to indicate upon registration that you are or are not interested
in receiving offers or information from our partners and/or us
and we may occasionally send you e-mails regarding product and
event information or promotions. Only BNI and its affiliates
will send you these solicitations, and only if you have
previously not indicated that you do not wish to receive them.
If applicable and you prefer not to receive such e-mails, please
opt out or otherwise do not opt-in to receive these e-mails. You
may opt-out of receiving e-mails from BNI when you register
within your account settings at our Sites within or otherwise
provide contact information to BNI.
Information concerning your geographical location is used to
determine if
BNI
should provide regionalized information to its site users. When
you voluntarily enter a sweepstakes or contest, we request your
e-mail address and other contact information in order to be able
to contact you in the event you are a winner of the sweepstakes
or contest. Except as otherwise stated in this Privacy Policy,
the personal information you provide on our Sites will not be
shared with any third-parties, although
BNI
reserves the right to share such information with its affiliates
and subsidiaries without your permission.
BNI
provides links to send e-mail messages to our Sites for your
convenience and your e-mail address is used so that our Sites
may reply to your inquiry.
BNI
tracks the pages on our Sites that our users visit in order to
determine which areas of the website are the most popular. This
data is used to deliver customized content and advertising
within our Sites to customers whose behavior indicates that they
are interested in a particular subject area.
The vast majority of data collection from our visitors is used
to assess the type of people visiting that website and to
determine what content is most frequently accessed by those
visitors. This information helps
BNI
improve its websites by offering content that more specifically
meets the interests of our Site visitors.
B.
Financial
Information. If BNI collects your financial information, it
may use your financial information or payment method to process
payment for any purchases, subscriptions or sales made on our
Sites, to protect against or identify possible fraudulent
transactions, and otherwise as needed to manage our business.
Data Retention
Your data will only be retained for as long as necessary to
fulfil the purposes for which it was obtained. For members, at a
minimum this will be for the duration of your membership and
likely longer depending upon applicable laws, rules and
regulations.
For non-members, this will be for the duration needed to align
with your engagement with us, such as, by way of example only,
to enable us to send invitations to Chapter meetings, for
maintaining subscriptions to email newsletters, or for the
duration of your participation in one of our core groups prior
to Chapter launch. Please see our Data Retention Policy,
accessible at
http://bnitos.com/retention.html for more
information.
With Whom We Share Your Information
A.
General.
We want you to understand when and with whom we may share
personal or other information we have collected about you or
your activities on our Sites or while using our services.
B.
Personally
Identifiable Information. We do not share your personal
information with others except as indicated below or when we
inform you and give you an opportunity to opt out of having your
personal information shared.
1.
We may share your personal information with:
a.
Authorized Service Providers:
We may share your personal information with our authorized
service providers that perform certain services on our behalf.
These services may include processing credit card payments,
delivering products and services, providing customer service and
marketing assistance, performing business and sales analysis,
supporting our Sites’ functionality, and supporting other
features and promotions offered through our Sites. We will only
provide these service providers with the limited information
that they need to provide us with such services, including
limited access to personal information needed to perform their
functions. However,
they are not permitted to share or use such information for any
other purposes. When you enter into transactions with others or
make payments on our Sites, we will either (a) link you to a
third party who handles the transaction outside of our Sites, or
(b) share transaction information with only those third parties
necessary to complete the transaction. We will require those
third parties to agree to respect the privacy of your
information.
b.
Business partners:
From time to time, we may offer promotions, sweepstakes or
third-party offerings on our Sites. If and when you make
purchases, engage in these services and/or products, offered
through our Sites or our services, we may share personal
information with the businesses with which we partner to offer
you those products, services, promotions, contests and/or
sweepstakes. When you elect to engage in a particular merchant's
offer or program, you consent to us to providing your email
address and other information to that merchant. You have the
right to withdraw your consent at any time by emailing us at
legal@bni.com.
2.
Based on the contractual necessity given the nature of
our networking business, you acknowledge that in connection with
your membership we may share your personal information with:
a.
Franchisees:
If you are a BNI member or a non-member, we may share your
personal information with BNI Master Franchisees or
(Sub)franchisees of BNI, who are joint controllers of data
(“Data Controller”) with our affiliate BNI Worldwide Development
Limited. As joint
Data Controllers, Master Franchisees and (Sub)franchisees have
separate obligations for implementing appropriate technical and
organizational measures to ensure and to demonstrate that their
processing activities are compliant with the requirements of the
European Union’s General Data Protection Regulation (“GDPR” or
the “Regulation”).
b.
Members: We
and our authorized third-party agents may share your personal
information and member performance data with other members,
chapters, and the entire BNI System.
This includes (a) displaying your personal information as
a way of marketing your business on BNI Connect®, and (b)
sharing your performance data via BNI Connect®, BNI University,
and any other web platforms or techniques we may, separately or
through authorized third-party agents, choose to utilize or
develop in the future related to the core business of networking
and passing referrals.
3.
Other Situations. We also may disclose your information:
a.
In response to a subpoena, court order, or other requests
for cooperation from a law enforcement or other government
agency (including civil and criminal matters); to establish or
exercise our legal rights; to defend against legal claims; or as
otherwise required by law. In such cases, we may raise or waive
any legal objection or right available to us, in our sole
discretion. This may include respecting requests from
jurisdictions outside of the United States if we have a good
faith belief that response is required by law under the local
laws in that jurisdiction, apply to users from that
jurisdiction, and are consistent with generally accepted
international standards. We may also share information when we
have a good faith belief it is necessary to prevent illegal
activity, to prevent imminent bodily harm, or to protect
ourselves and you from people violating our Terms of Service,
accessible at
http://bnitos.com/tos_google.html.
This may include sharing information with other companies,
lawyers, courts or other government entities where applicable.
b.
In connection with a substantial corporate transaction,
such as the sale of our business, a merger, divestiture,
consolidation, or asset sale; though in any event, any acquiring
entity or other third-party assignee will be bound by the terms
of this Privacy Policy.
c.
To protect and defend the rights or property of BNI or
one of BNI’s referral networks; and, act under exigent
circumstances to protect the personal safety of members and
users of BNI, its websites, or the public.
Any third parties to whom we may disclose personal information
may have their own privacy policies, which describe how they use
and disclose personal information. Those policies will govern
use, handling and disclosure of your personal information once
we have shared it with those third parties as described in this
Privacy Policy. If you want to learn more about their privacy
practices, we encourage you to visit the websites of those third
parties. These entities or their servers may be located either
inside or outside the United States.
C.
Aggregated and non-personal information. We
may share aggregated and non-personal information we collect. We
may also share it with third parties to develop and deliver
targeted advertising on our Sites and on websites of third
parties. We may combine non-personal information we collect with
additional non-personal information collected from other
sources. We also may share aggregated information with third
parties, including advisors, advertisers and investors, for the
purpose of conducting general business analysis. This
information does not contain any personal information and may be
used to develop services that we hope you and other users will
enjoy using.
About User-Generated-Content
We do not screen, filter or monitor user submissions to our
Sites, nor do we scrape or glean personal information from any
such submissions to the extent that any comment or other user
submission contains personal information (including name,
likeness, email address, whether such information pertains to
the submitter or someone else), such personal information may be
viewed by authorized users of our Sites with whom you have
shared that information, subject to our Terms of Service. We do
not gain access to any of your personal content, and only use
"meta" information to enable the successful operation of our
service. (See "User
Submissions" below).
Third-Party Websites
There are a number of places on our Sites or through our
services where you may click on a link to access other websites
that do not operate under this Privacy Policy. For example, if
you click on an advertisement or a search result on our Sites,
you may be taken to a website that we do not control. These
third-party websites may independently solicit and collect
information, including personal information, from you and, in
some instances, provide us with information about your
activities on those websites. We recommend that you consult the
privacy statements of all third-party websites you visit by
clicking on the "privacy" link typically located at the bottom
of the webpage you are visiting.
Your Data Protection Rights and Accessing Your Information under
GDPR
Because our affiliate BNI Worldwide Development Limited is
established in Ireland, we will be governed by the GDPR. This
means that we are going to be working continuously to ensure
that we are satisfying our obligations under the Regulation.
If you have an online account with us, you have the ability to
review and update your personal information online by logging
into your account. You can also review and update your personal
information and exercise your other rights by contacting us.
More information about how to contact us is provided below.
·
You have the right to be provided on request with a copy of your
personal data.
·
You have the right to rectification of inaccurate data we may
have recorded about you.
·
You have the right to the erasure of your data (“Right to be
Forgotten”) which we no longer have justification for recording.
·
You have the right to object to processing of your data which is
being done on the basis of our legitimate interests.
·
You have the right to refuse to be contacted for direct
marketing purposes.
·
You have the right to restrict the processing of your personal
data when:
o
the basis for its processing is in dispute;
o
its accuracy is in dispute;
o
we cannot establish a lawful basis for its processing, but you
do not wish it to be erased;
o
we no longer need your data, but you need it for the
establishment, exercise, or defense of legal claims;
o
you object, where applicable, to our processing your data on the
basis of our legitimate interests, pending verification of
whether our interests override.
·
You have the right to be provided with a copy of your data in
machine readable format, or to have it transferred directly to
another data controller (“Data Portability”). In connection with
GDPR, BNI Connect provides this functionality.
If you have an online account with us, you also may choose to
close your account at any time by emailing us at
legal@bni.com.
If you close your account, we may still retain certain
information associated with your account for analytical purposes
and record keeping requirements per our Data Retention section
above as well as to prevent fraud, collect any fees owed,
enforce our Terms of Service, or take other actions otherwise
permitted by law. In addition, if certain information has
already been provided to third parties as described in this
Privacy Policy, retention of that information will be subject to
those third parties' policies.
Your Choices About
Collection and Use of Your Information
1.
You can choose not to provide us with certain information, but
that may result in you being unable to use certain features of
our Sites because such information may be required in order for
you to register as a member; purchase products or services;
participate in a contest, promotion, survey, or sweepstakes; ask
a question; or initiate other transactions on our Sites.
2.
When you register on our Sites you may be given a choice or
otherwise allowed to indicate whether you want to receive email
notifications and/or newsletters. At any time you can choose to
stop receiving notification emails by accessing your account
settings or through the link at the bottom of the notification
emails; and commercial or promotional emails or newsletters from
us by clicking on the link at the bottom of any of our emails.
You will be given the opportunity, in any commercial e-mail that
we send to you, to opt out of receiving such messages in the
future. It may take up to 10 days for us to process an opt-out
request. We may send you other types of transactional and
relationship e-mail communications, such as service
announcements, administrative notices, and surveys, without
offering you the opportunity to opt out of receiving them as
long as your account is active. Please note that, changing
information in your account, or otherwise opting out of receipt
of promotional email communications will only affect future
activities or communications from us. If we have already
provided your information to a third party (such as a credit
card processing partner or an event provider) before you have
changed your preferences or updated your information, you may
have to change your preferences directly with that third party.
Protecting Your Personal Information
We take appropriate security measures (including physical,
electronic and procedural measures) to help safeguard your
personal information from unauthorized access and disclosure.
For example, only authorized BNI employees, contractors and
certain third party service providers are permitted to access
personal information, and they may do so only for permitted
business functions. In addition, we use encryption in the
transmission of your sensitive personal information between your
system and ours.
If you choose to create a profile on our Sites or if you choose
to register for an account, you will be required to select a
password. This password can be changed at any time after you
first log into the service by using your current password. You
must keep your password confidential and you must not share this
information with anyone. If you share a computer with anyone,
you should always log out of our Sites before leaving it to
prevent access to your information from subsequent users of that
computer.
There are, however, risks inherent in sharing information, and
though we provide privacy settings for whom you share your
videos with, please be aware that no security measures are
perfect or impenetrable. We cannot control the actions of any
person with whom you share your information, and cannot
guarantee that only authorized recipients will view your videos.
We cannot control the actions of other users with whom you share
your information. We cannot guarantee that only authorized
persons will view your information. Therefore, although we take
steps to secure your information, we do not promise, and you
should not expect, that your personal information, searches, or
other communications will always remain secure. Users should
also take care with how they handle and disclose their personal
information and should avoid sending personal information
through insecure email. We are not responsible for third party
circumvention of any of our privacy settings or security
measures. Please be careful and conscientious with whom you
share your videos and choose a strong password that you do not
use for other services. For information about how to protect
yourself against identity theft, please refer to the Federal
Trade Commission's website at
www.ftc.gov/bcp/menus/consumer/data.shtml.
Communities and Forums Offered on our Sites
Any personally identifiable information or personally sensitive
data that you disclose through our Sites, or other online forums
hosted on our Sites, may be collected and used by others. We
recommend caution when giving out personal information to others
in these online forums. We encourage you to review the privacy
statements of websites you choose to visit via hyper-links
posted on our Sites so that you can understand how those
websites collect, use and share your information. BNI is not
responsible for the privacy policies or other content on
third-party websites accessed through its websites.
User Submissions
We may provide areas on our Sites where you can post information
about yourself, including your name and email address,
communicate with others; upload content; and post comments. Such
postings are governed by our Terms of Service. Also, whenever
you voluntarily disclose personal information on our site, that
information will be available and can be collected and used by
others who have authorized access to your content. We encourage
you to exercise discretion and caution with respect to your
personal information. Once you have posted information, you may
not be able to edit or delete such information.
Children's Privacy
Our Site is a general audience site, and we do not knowingly
collect personal information from children under the age of 13.
Our Sites are not intended for use by children. You may access
our Sites only if you are of legal age to lawfully form a
binding contract. If you are under the age of 18 and do not have
a parent’s or legal guardian’s permission to use our Sites, you
may not access our Sites or use any services. If you are 13
years of age or older, then you can only use our Sites and
services with the consent of your parent or legal guardian.
Transfers of Personal Data Outside of Europe
The global extent of BNI’s business necessitates the transfer of
data to its franchisees and times members on a worldwide basis.
Some countries to which we transfer your data have not been
designated by the European Commission as having at a national
level an adequate level of data protection. In these cases, we
rely on (a) Privacy Shield, and (b) Commission-approved standard
contractual clauses (“SCC”) with our franchisees to safeguard
your data.
Privacy Shield
For transfers out of the EU and Switzerland and to the United
States of America, BNI Global, LLC has self-certified that it
complies with the EU-US and Swiss-US Privacy Shield Framework as
prescribed by the US Department of Commerce regarding the
retention, use, collection, and notice principles. BNI
additionally adheres to the Privacy Shield Framework
recommendations pertaining to the transfer of information to
third parties, access, security, data integrity and purpose
limitation and enforcement. Additional information on the
Privacy Shield Program can be viewed at
https://www.privacyshield.gov.
The Federal Trade Commission (FTC) has jurisdiction over BNI’s
compliance with the Privacy Shield. BNI will annually renew its
Privacy Shield certification to help ensure the treatment of all
personal data continues to be accurate and processed in
accordance with the Privacy Shield Framework and applicable
Principles. In cases of onward transfer to third parties of EU
and Swiss Personal Data received pursuant to the EU-US and
Swiss-US Privacy Shield Framework, BNI is potentially liable.
All questions or complaints regarding the processing and use of
personal data should be directed to
legal@bni.com.
BNI has elected JAMS as its independent dispute resolution
mechanism in accordance with requirements set forth by Privacy
Shield. If questions or complaints are not resolved
satisfactorily through contacting BNI, users can file a
complaint with JAMS at
https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.
You may have the option to select binding arbitration for the
resolution of your complaint under certain circumstances,
provided you have taken the following steps: (1) raised your
complaint directly with BNI and provided us the opportunity to
resolve the issue; (2) made use of the independent dispute
resolution mechanism identified above; and (3) raised the issue
through the relevant data protection authority (DPA) and allowed
the US Department of Commerce an opportunity to resolve the
complaint at no cost to you. For more information on binding
arbitration, see US Department of Commerce’s Privacy Shield
Framework: Annex I (Binding Arbitration).
No Rights of Third Parties
This Privacy Policy does not create rights enforceable by third
parties or require disclosure of any personal information
relating to users of our Sites.
Changes to This Privacy Policy
We will occasionally update this Privacy Policy to reflect
changes in our practices and services. When we post changes to
this Privacy Policy, we will revise the "Last Updated" date at
the top of this Privacy Policy. If we make any material changes
in the way we collect, use, and/or share your personal
information, we will notify you by sending an email to the email
address you most recently provided us in your account, profile
or registration (unless we do not have such an email address),
and/or by prominently posting notice of the changes on our
Sites. We recommend that you check our Sites from time to time
to inform yourself of any changes in this Privacy Policy or any
of our other policies.
How to Contact Us
If you have any questions about this Privacy Policy or our
information-handling practices, or if you would like to request
information about our disclosure of personal information to
third parties for their direct marketing purposes, please
contact us by email, telephone, or postal mail as follows:
BNI Worldwide Development Ltd
BNI’s Data Protection Officer can be contacted at the above
address or phone number, or by email at
dpo@bni.com. |
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