PRIVACY POLICY

REFINED LEADERSHIP, Inc.
Privacy Notice
At Refined Leadership, Inc., (“Refined Leadership”, “Company”, “we”, “our” or “us”), we value your trust. We are committed to acting responsibly when we collect, use and protect your non-personal and personal information.

We believe in being clear and open about how we collect data related to you when you visit our website at www.refinedleadership.com (the “Website”), subscribe to/ purchase our services for customized one-on-one and in-person leadership coaching, focusing on peak performance habits, effective communication techniques, and refined leadership skills (“Courses”), subscribe to our newsletter, interact with us, participate in online advertisements or marketing emails, opt-in to receive SMS mobile messages, or engage with any other websites, pages, features, or content we own, operate and/or provide (collectively with the Website and Courses, the “Services”)that direct you to this Privacy Notice (“Privacy Notice”).

This Privacy Notice does not apply to information collected by:
· Us offline or through any other means, including on any other website operated by Company that does not direct you to this Privacy Notice or any third party (including our affiliates and subsidiaries); or
· Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

This Privacy Notice is designed to help you understand how we collect, use, share and safeguard the information you provide to us and to assist you in making informed decisions when using our Services. Please read this Privacy Notice very carefully.

By accessing and using the Services, you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Notice the Cookie Policy located at (“Cookie Policy”). The use of the Services is subject to the Terms of Service located at ("Terms of Service").

1. Types of Data We Collect

We collect “Non-Personal Information” and “Personal Information” and the information we collect from you depends on how you use the Services. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, support@refinedleadership.com, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. This includes: 

Context
Types of Data We Collect
Primary Purpose for Collection and Use Data
Website User Information
We collect the name, if stated, and email address if a user contacts us
We have a legitimate interest in contacting our customers and communicating with them in relation to the Services.
Discovery Call
If you choose to set up a discovery call using the online form, we will collect information that you provide or select as applicable.
We collect this information based on your consent and we also have a legitimate interest in contacting our customers and communicating with them in relation to the Services.
Account Information

If you set up an account through the Website, we collect your:

  1. full name
  2. role / title
  3. mailing address
  4. phone number
  5. email address
  6. billing information and purchase history
  7. IP address.
We have a legitimate interest in contacting our customers and communicating with them in relation to the Services.
Cookies and first party tracking
We use Cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our Cookie Policy for more information on how we use Cookies. ("Cookie Policy")
For individuals that consent, we may use first party Cookies, other than essential or strictly necessary Cookies to make the Services operate efficiently. We also have a legitimate interest in making the Services operate efficiently.
Cookies and Third-Party Tracking
We participate in interest-based (aka targeted advertising) and behavior-based advertising, this means that a third party uses technology (i.e.: a cookie, social media pixel, etc.) to collect information about your use of the Service so that they can provide advertising about products and services tailored to your interests. We use Google Analytics, which is an analytics service provided by Google Inc. (US).:  https://policies.google.com/privacy

You may opt-out of Google Analytics for display advertising or customize Google display network ads by managing your privacy controls on Google's website. See our Cookie Policy for more information on how we use Cookies. ("Cookie Policy")
For individuals that consent, we may engage in interest-based and behavior-based advertising, capturing Website analytics and engaging third parties to assist with providing Services to you that are tailored to your interests.
Virtual Meetings
When you sign up for our virtual consultation or Course hosted via Zoom or a similar platform, we will collect your username and email address.
The information is needed to provide you access to the Zoom consultation or course and any recordings thereof.For all recorded Zoom meetings, you will be asked to provide consent to being recorded. If you do not provide consent, your microphone will be muted, and your video will be off if you join a meeting with recording or live streaming already in progress. Your microphone and video settings will revert to default if you provide consent.We also have a legitimate interest in contacting our clients and communicating with them in relation to the Services and we have a legitimate interest in using this information to provide the Services.
Client Testimonials

If you voluntarily choose to provide us with a testimonial for our Website, we will collect your:

We collect this information based on your consent. Your testimonial and photo will be posted on our Website.
Personal Information Received from Strategic Partners
Our strategic partners are authorized resellers of our Courses and may share your full name and email address with us
Your full name and email address are needed to send you log in credentials for the online Course(s).For individuals that consent, we may send you email communications with marketing and other promotional materials that may be of interest to you.
Email Interconnectivity
If you receive email from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.
We have a legitimate interest in understanding how you interact with our communications to you.
Feedback/Support
We collect Personal Information from you contained in any inquiry you submit to us regarding the Services, such as completing our online forms, calling or emailing for the purposes of generalinquiries, support requests, or to report an issue.When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control and for sales and marketing purposes. During such calls we will notify you of the recording via either voice prompt or script.
We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries.
Email and Mailing Lists
When you sign up for one of our email lists, we will collect your name and email address. When you sign up for our mailing lists, we collect your name and postal address.
We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products and services.
Mobile Devices
We collect information from your mobile device such as unique identifying information broadcast from your device when using the Services.
We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Website Interactions
We use technology to monitor how you interact with the Services. This may include: IP addresses, preferences, web pages you visited prior to using the Services, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors)
We have a legitimate interest in understanding how you interact with the Services to better improve the Services, and to understand your preferences and interests and to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Logs
We collect information, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.
We have a legitimate interest in monitoring networks and the visitors to our Website and access and use of the Services to provide the Services and enhance the Services
Employment
If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your social security number. Providing this information is required for employment
We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations, and provide the Website to our customers.
Demographic Information
We collect Personal Information, such as your age or location.
We have a legitimate interest in understanding our users and providing tailored Services.
Geolocation Information
When you use our Website and Services we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location to better serve you.
We have a legitimate interest in understanding our users and providing tailored Services. In some contexts, our use is also based upon your consent to provide us with geo- location information.
Surveys

When you participate in a survey, we collect information that you provide through the survey. This information may include but is not limited to:

We have a legitimate interest in understanding your opinions and collecting information relevant to our organization and the Services.
Signing up for a Consultation and/or Enrolling in a Course
We collect your full name, billing address, e-mail address, phone number, and credit card number when you sign up for a consultation and/or enroll in a Course.
We have a legitimate interest in using this information to provide the Services.

2. Children’s Online Privacy Protection Act (“COPPA”)

Our Services are not designed for children under 13, and we do not intentionally or knowingly collect Personal Information from users who are under the age of 13 or from other websites or services directed at children. If we discover that a child under 13 has provided us with Personal Information, we will delete such information.

3. Information You Provide To Us

4. Collected via Technology

5. Information We Obtain From Other Sources

Our business and strategic partners, affiliates, data analytics providers, advertising networks, internet service providers, operating systems and platforms and social networks may also provide us information about you. We may also collect information from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

6. Use of Your Personal Information

In general, Personal Information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Information in the following ways :

7. Use of Non-Personal Information

In general, we use Non-Personal Information to help us improve the Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Services. This Privacy Notice does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

8. How We Share Your Personal Information

We may disclose your Personal Information as described below and as described elsewhere in this Privacy Notice :

9. Links to Third Party Websites and Third-Party Providers

As part of the Services, we may provide links to or compatibility with other websites or applications; however, we are not responsible for the privacy practices employed by those websites or the information or content they contain nor are we liable for third party products, services, acts and/or omissions. This Privacy Notice applies solely to information collected by us in relation to the Services and your use of the Services. Therefore, this Privacy Notice does not apply to your use of a third-party website accessed by selecting a link on our Website or via the Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to such access and/or use. We encourage our users to read the privacy statements of other websites before proceeding to use them.

10. Your Rights Regarding the Use of Your Personal Information

We may send periodic promotional emails to you. You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. If applicable, you can also indicate that you do not wish to receive marketing communications from us in the “Notifications” section of your Account. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the Notification section of your Account, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Notice. You may unsubscribe to promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process unsubscribe requests. If you unsubscribe from receiving promotional emails, we may still send you emails about the Services.

Your Rights and Choices

If applicable privacy laws allow, you may have rights over your Personal Information.  This includes, but is not limited to:

  1. 11. How to Exercise your Right(s)

You may enquire about your Personal Information by contacting us as described below in Section 20.  Refined Leadership will generally respond to all access requests within 30 days of the receipt of all necessary information. We will need to verify your identity before providing you with the Personal Information we hold about you. In circumstances where we are not able to provide access, or if additional time is required to fulfill a request, we will advise you in writing. Refined Leadership may not release certain types of information based upon exemptions specified in applicable laws. Where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Information to you, we will provide you with an explanation, subject to restrictions. In certain circumstances, such as where the request is excessive or unfounded, we may charge you an administration fee for access to your Personal Information. We may also charge for additional copies. We will advise you of any fees before proceeding with a request. You may learn more about the process or obtain assistance in completing an access request by contacting us as described below. Note that, as required by law, we will require you to prove your identity.  We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete Personal Information about you in our files. In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.  If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:


If we do not receive this information, the request will be denied.

  1. 12. How We Protect Your Personal Information and Personal Data

We implement security measures designed to protect your information from unauthorized access, alteration, disclosure and/or destruction. Because the internet is not a completely secure environment, we cannot warrant the security of any information a user transmits to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards.  Any account you have on our Website is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures; however, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. While we use reasonable efforts to protect your Personal Information, we cannot guarantee the Services are absolutely secure. 

  1. 13. How we Retain Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise periods for which we keep your Personal Information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use and/or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.  In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice.  We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide us with requested information, you may not be able to use the Services. You can request further details of retention periods for different aspects of your Personal Information by contacting us. Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.

  1. 14. Accessibility

If you are visually impaired, you may access this Privacy Notice through your browser’s audio reader.

  1. 15. Changes to This Privacy Notice

We reserve the right to change this Privacy Notice or any agreement you entered into with Refined Leadership time to time. We may notify you of significant changes to this Privacy Notice by sending a notice to the primary support@refinedleadership.com specified by you or by placing a prominent notice on the Site.  Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. Our Privacy Notice includes an “effective” and “created” or “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current Privacy Notice was last substantively modified. You should periodically check the Site and this Privacy Notice for updates.

  1. 16. Other Jurisdictions

Personal Information that you submit through the Services may be transferred outside of the jurisdiction in which you live.  We also store Personal Information locally on the devices you use to access the Services. Your Personal Information may be transferred to other jurisdictions that do not have the same data protection laws as the jurisdiction in which you initially provided the information. The following provisions may apply to you depending on where you are located.

Nevada.  This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing users, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at support@refinedleadership.com or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: AGCinfo@ag.nv.gov.

Vermont. In accordance with Vermont law, we will not share information we collect about you with companies outside of Refined Leadership except as described herein, or otherwise required or permitted by law. Virginia. This Section is only applicable to you if you are a resident of the state of Virginia (“Virginia Residents”).  If you have a complaint, first contact us at support@refinedleadership.com.  We will respond within 45 days after receipt of your request, and such time may be extended for an additional 45 days if it is reasonably necessary.  We will notify you of any extension within the initial 45-day period. If you are not satisfied with our responses, you have the right to appeal.  We will respond within 60 days of receipt of your appeal.  If you still have an unresolved complaint, please direct your complaint to the Virginia Attorney General at service@oag.state.va.us or call (804)786-2071.

California. At this time, California Privacy laws (California Consumer Privacy Act, California Privacy Rights Act) do not apply to us, but we will still protect your Personal Information as outlined in this Privacy Notice. If you feel this is incorrect, please contact us at support@refinedleadership.com 

  1. 17. Notice to Residents of the European Union, the European Economic Area and the United Kingdom

This Notice is meant to supplement our Privacy Notice. If you reside in the European Union (“EU”) or the European Economic Area (“EEA”), the European Union General Data Protection Regulation (“GDPR”) will apply to how we collect and process your “Personal Data”, which is defined as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.” If you reside in the United Kingdom, the United Kingdom Data Protection Act 2018 (“UK GDPR”) will apply to how we collect and process your Personal Data.
The Personal Data we collect and process, as described in this Privacy Notice, may be transmitted or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country. The data centers for Refined Leadership’s Services are located in the United States, and third-party processors operate in many countries around the world. When we collect your Personal Data, we may process it in any of those countries. We have taken appropriate steps and put safeguards in place to help ensure that your Personal Data remains protected in accordance with this Privacy Notice. We also require that third-party processor to whom a data transfer is made has appropriate safeguards in place to protect your Personal Data, in compliance with applicable data protection laws. The particular measures used will depend on the processor, and our agreements with them may include but are not limited to the European Commission approved Standard Contractual Clauses and/or UK International Data Transfer Agreements.

Legal Basis For Processing: We primarily utilize your consent for lawfully using your Personal Data.  We may also use your Personal Data lawfully and fairly based on any of the following situations:


First and Third-Party Cookies and Other Similar Technologies
Please see our <"Cookie Policy"> here. In addition to your rights described in our Privacy Notice, you have the following rights

How to Exercise your Right(s)

We will not discriminate against you for exercising your rights. You may exercise your rights about your Personal Data by contacting us as described below in Section 20. 

Once we receive your request, we will need to verify your identity before providing you with the Personal Data we hold about you. Typically, we will respond to your request within thirty (30) days. If we are unable to verify your identity, complete your request or if additional time is required to fulfill a request, we will notify you in writing.

Refined Leadership may not release certain types of information based upon exemptions specified in applicable laws. Where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Data to you, we will provide you with an explanation, subject to restrictions. In certain circumstances, such as where the request is manifestly unfounded, excessive or repetitive, we may charge you a reasonable fee. We will advise you of any fees before proceeding with a request.

Withdrawal of Your Consent

If we used consent to lawfully and fairly use your Personal Data, you may withdraw your consent at any time by contacting us as described below.  Doing so may prevent you from accessing the Website. In some cases, we may limit or deny your request to withdraw consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. If you unsubscribe from the promotional emails you will still receive emails regarding your account.

To withdraw your consent, contact us at: support@refinedleadership.com

Retention of Personal Data

As we are committed to the privacy of your Personal Data, we only hold on to Personal Data for as long as we need it to provide Services to you.  We may retain limited Personal Data to meet legal or compliance obligations our Company must meet.  You can request further details of retention periods for different aspects of your Personal Data by contacting us.

How to Lodge a Complaint

If you are in the EU or the EEA and have a complaint about how we use your Personal Information, you have the right to lodge a complaint with a supervisory authority. A list of the Data Protection Authorities and their contact information can be found here:  Our Members | European Data Protection Board (europa.eu)

If you reside in the UK and have a complaint about how we use your Personal Information, you have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”). You can find additional information on how to do so here: Make a complaint | ICO

  1. 18. Notice to Canadian Residents

If you reside in Canada, the Personal Information Protection and Electronic Documents Act (“PIPEDA”) will apply to how we collect and process your Personal Information. In addition to the safeguards and rights listed in this Privacy Notice, the following will also apply to you: 

Accuracy and Use of your Personal Information: We rely on you to update and correct your Personal Information. Please update your Personal Information by logging into your account or contact us at the address or via email below, immediately if there are any changes to your Personal Information. We may keep historical information in our backup files as permitted by law. Your Personal Information will not be used without your consent for purposes other than the ones for which it was collected, as described in this Privacy Notice and in compliance with applicable laws. We will request your consent for any new or additional purposes for the collection and processing of your Personal Information.  

First and Third-Party Cookies and Other Similar Technologies: Please see our Cookie Policy : <"Cookie Policy">

Online Tracking.  We do not currently recognize automated browser signals regarding tracking mechanisms, which may include ‘Do Not Track’ instructions. 

Security of Your Personal Information and Personal Data: We implement security measures designed to protect your information from unauthorized access, alteration, disclosure and/or destruction. Because the internet is not a completely secure environment, we cannot warrant the security of any information a user transmits to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards.  Any account you have on our Website is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures; however, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. While we use reasonable efforts to protect your Personal Information, we cannot guarantee the Services are absolutely secure. In the event that your Personal Information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, we will notify you of the breach by email, fax, or U.S. mail. We will give you notice promptly, consistent with the reasonable needs of law enforcement and/or Refined Leadership to determine the scope of the breach and to investigate and restore the integrity of the data system.Your Rights In addition to your rights described in this Privacy Notice, you will have the following rights: 

How to Exercise your Rights: We will not discriminate against you for exercising your rights. You may exercise any of the above rights, by contacting us as indicated below or by emailing us at: support@refinedleadership.com. Once we receive your request, we will need to verify your identity before providing you with the Personal Information we hold about you. Typically, we will respond to your request within thirty (30) days. If we are unable to verify your identity, complete your request or if additional time is required to fulfill a request, we will notify you in writing.

E-mail and SMS Mobile Messaging Communications: In compliance with the Canada’s anti-spam legislation (CASL), our Websites allow you to sign up and expressly consent to receiving electronic communications. All emails sent from Refined Leadership will clearly state who the email is from and provide information on how to contact us.  You can unsubscribe from promotional e-mails via the unsubscribe link included in each promotional e-mail. You can opt-out of receiving future text messages by replying "STOP". If you opt-out and un-subscribe, you will still receive transactional/ booking confirmation emails from us. You may also contact us at support@refinedleadership.com to stop receiving them or can unsubscribe using the link included in the e-mail or by calling us at +1 (312) 854-9715.

 Privacy of Minors: Our Services are not designed for minors and we do not intentionally or knowingly collect Personal Information from users who are considered minors in their province. If we discover that a minor has provided us with Personal Information, we will delete such information. 

Questions or Complaints Regarding Our Privacy Practices: We hope that you will contact us if you have any questions or complaints regarding how we handle or use your Personal Information.  We will work to answer your question or address your complaint. You also have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy though the courts. You can learn more here Reporting concerns and filing complaints - Office of the Privacy Commissioner of Canada.

  1. 19. Notice to Residents Outside of the United States, EU, EEA, UK and Canada

Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. If you are located outside of the United States, the EU, the EEA, the UK or Canada, please be advised that any information you provide to us will be transferred to and stored in the United States and that, by submitting information to us, you explicitly authorize its transfer and storage in the United States. We will protect the privacy and security of Personal Information according to this Privacy Notice regardless of where it is processed or stored.

  1. 20. Contact Information

If you have any questions comments, or complaints concerning our privacy practices, please contact us by sending an email to support@refinedleadership.com or send correspondence via mail to:Refined Leadership Inc.2501 Chatham Road, Ste. NSpringfield, IL 62704We will attempt to respond to your request and to provide you with additional privacy-related information.

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