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Privacy Policy


INTRODUCTION

Welcome to The Freeman Company (UK) Limited's (“Freeman”) privacy policy.

We are committed to protecting and respecting your privacy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data collected from you, or that you provide, will be processed by The Freeman Company (UK) Limited, its subsidiary or parent companies and/or affiliates (“we” or “us”). This privacy policy supplements the other notices and is not intended to override them. This policy also outlines your privacy rights and how the law protects you.

We do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

CONTROLLER

Freeman is the controller and responsible for your personal data. We, as a controller, determine why and how we collect and use your personal data.

We may share your personal information with any member of our group, which means our subsidiaries and our ultimate holding company and its subsidiary undertakings (the “Freeman Group”).

We have appointed a Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Privacy Manager using the details set out below.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

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 e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This Freeman website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

· Contact Data includes billing address, delivery address, 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 website.

· 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 website, products and services.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

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.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

(1) Information you give us: You may give us information about you by filling in forms on the site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product or service, complete any forms, surveys or statements, place an order on our site and when you report a problem with our site. The information you give us may include (without limitation): your name or company name, company number, VAT number, address, e-mail address and phone number, financial and credit card information and personal descriptions, photographs and copies of identity documents (such as passports).

(2) Information we collect about you: With regard to each of your visits to our site we may automatically collect the following information:

(a) technical information, including (without limitation) the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products or services 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.

We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

(3) Information we receive from other sources: We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, 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 information about you from them.

4. HOW WE USE YOUR PERSONAL DATA

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:

· Where we need to perform the contract we are about to enter into or have entered into with you.

· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

· Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact information provided.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We use information held about you in the following ways:

(1) Information you give to us: We will use this information:

(a) to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

(b) to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

(c) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form);

(d) to notify you about changes to our service;

(e) to ensure that content from our site is presented in the most effective manner for you and for your computer.

(2) Information we collect about you: We will use this information:

(a) to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

(b) to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

(c) to allow you to participate in interactive features of our service, when you choose to do so;

(d) as part of our efforts to keep our site safe and secure;

(e) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

(f) to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

(3) Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Note that we may process your personal data for more than one lawful ground 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.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

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).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, or filed out contact information forms and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Freeman group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time using the contact information provided.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

CHANGE OF PURPOSE

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.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal information with any member of our group, which means our subsidiaries and our ultimate parent undertaking and its subsidiary undertakings (the “Freeman Group”).

We may share your information with selected third parties including:

(a) Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

(b) Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate anonymised information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. 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; and

(c) Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:

(a) 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;

(b) If The Freeman Company (UK) Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and

(c) 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 of Use, Cookie Policy and other agreements; or to protect the rights, property, or safety of The Freeman Company (UK) Limited, the Freeman Group and our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within the Freeman Group. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

· We will only transfer your personal data to countries or recipients that have been deemed to provide an adequate level of protection for personal data by the European Commission.

· Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

All information you provide to us is stored on our secure servers. Any 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 our site, you are responsible for keeping this password confidential. You are prohibited from sharing your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

9. YOUR LEGAL RIGHTS

You have the following rights under data protection laws in relation to your personal data.

The right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at UK_support@freemanco.com.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

NO FEE USUALLY REQUIRED

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 may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

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.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

APPLICABLE LAW

This Privacy Policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

CONTACT

Questions, comments and requests regarding this Privacy Policy should be addressed to The Privacy Manager and sent by mail or to the postal address set out below.

Our full details are:

Full name of legal entity: The Freeman Company (UK) Limited

Email address: UK_support@freemanco.com

Postal address: Prologis Park,

Imperial Road,

Ryton,

CV8 3LF

Collection of Your Personal Information

At various times Freeman may collect personal information, such as your email address, name, home or work address or telephone number, VAT number, financial and credit card information or anonymous demographic information. This is information you give Freeman by filling in forms on the Site, registering on the Site or placing an order online. It also includes personal information you provide to us offline, such as when you attend an exhibition, trade show or event, place a verbal order over the phone, contact customer service or visit one of our offices.

There is also information about your computer hardware and software that may be automatically collected by Freeman. This information can include: your IP address, your login information, browser type and version, browser plugins, domain names, products or services you viewed or searched for, download errors, clickstream history through and from the Site, access times and referring website addresses. This information is used by Freeman for the operation of the service, to conduct business activities, to maintain quality of the service, and to provide general statistics regarding use of the Site. We also work with third parties (including, 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 or provide information about you from them.

Use of Your Personal Information

We only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

More specifically, Freeman collects, uses, transmits and stores the personal information you provide to deliver the services you have requested; to inform you of other products or services available from Freeman; to notify you about changes to our service; and to ensure that content from the Site is presented in the most effective manner for you and for your device. Freeman also may use your personal information to operate the Site; for internal operations, including troubleshooting, data analysis and testing; or to contact you via survey to conduct research about your opinion of current services or of potential new services that may be offered.

Freeman will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Freeman, its licensees or the Site; (b) protect and defend the rights or property of Freeman; and, (c) act under exigent circumstances to protect the personal safety of users of Freeman, the Site, or the public.

Freeman may provide your personal information to (a) Freeman affiliates that are located overseas which may not be bound by to US privacy laws; and (b) anyone authorized by you to receive your personal information. Personal information collected, however, will always remain in the sole possession of Freeman, and will not be given to any third party except in accordance with the terms hereof. Freeman may aggregate and amalgamate your personal information with other data, for internal reporting purposes, to improve the delivery of services and for benchmarking services. Freeman will only use your personal information under circumstances where you will not be, and could not reasonably be, identified as the source or origin of the information.

Retention

Freeman will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Security of Your Personal Information

Freeman secures the personal information you provide on servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. Personal information is transmitted to other websites through the use of Transport Layer Security (TLS) encrypted protection. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site; any transmission is at your own risk. Once Freeman has received your personal information, Freeman will use strict procedures and security features to try to prevent unauthorized access.

From time to time, Freeman reviews its security procedures in an effort to make the security of personal information better. However, please be aware that no security measures are perfect or impenetrable.

Changes to this Statement

If there are material changes to this Policy or in how Freeman will use your personal information, Freeman will prominently post such changes prior to implementing the change. Freeman encourages you to periodically review this Policy to be informed of how we are protecting your information. This Policy was last updated on April 19, 2018.

Contact Information

Freeman welcomes your comments regarding this Policy. Please contact Freeman by telephone, email or postal mail if you have any questions or concerns regarding this Policy, its implementation or would like to update your personal information:

Freeman P.O. Box 660613 Dallas, TX 75266-0613 Email: privacy@freeman.com

Phone: 214-445-1000

California’s “Shine the Light” Law

If you are a California resident and wish to review or change the personal information of yours which Freeman possesses, please contact us by one of the ways listed above in the Contact Information section.

US Law Applies

The Site is governed by and operated by Freeman from its offices in the United States and in accordance with the laws of the United States. If you are located outside of the US, you use the Site at your own risk. Freeman is a company that operates globally so it may be necessary to transfer your personal information internationally in accordance with this Policy. In particular, your personal information will be transferred to and processed in the United States where many of our central databases operate. By using the Site and the services related thereto, you (a) acknowledge that the data protection and other laws of other countries, such as the United States, may provide a less comprehensive standard of protection than those in your country; (b) consent to your personal information being collected, processed and transferred as set forth in this Policy and US law; and (c) submit to the jurisdiction of, and agree that venue is proper in Dallas County, Texas, USA in any legal action or proceeding.

For more information on cookies and beacons, please see our Cookie Policy.

For EU Individuals: Privacy Shield Notice for Personal Data Transfers to the United States

EU-US Privacy Shield Framework

The Freeman Company, and certain of its controlled US affiliates: Freeman Audio Visual, LLC, Freeman Digital Ventures, LLC, Freeman Expositions, LLC and FreemanXP, LLC (together, “Freeman”, or “We”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield. Freeman has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Freeman is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@freeman.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@freeman.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

As explained in our privacy policy, we sometimes provide personal information to third parties to perform services on our behalf. If we transfer personal information received under Privacy Shield to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations.

Freeman’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Freeman remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Freeman proves that it is not responsible for the event giving rise to the damage.

Freeman commits to resolve complaints about your privacy as detailed above and we further committ to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

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