Logo Telfar

Privacy Policy

Welcome to TELFAR, located at Telfar.net and Telfar.TV (collectively, the Website). We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request. Your use of the Website indicates your acknowledgment of this privacy notice and your consent to the processing herein. 

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA) or the United Kingdom (“UK”), we are subject to the EU General Data Protection Regulation (EU GDPR) or the UK General Data Protection Regulation (UK GDPR) respectively. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA. For consumers who are residents of other states, that state may have an applicable data privacy law and disclosures required by those laws are stated below.

 

Quick links


We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.

  1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:


We, us, our

Telfar Holding, Inc., and its group companies

Our representative

Telfar Holding, Inc.
privacy@telfar.net

Personal information

Any information relating to an identified or identifiable individual.


  1. Personal Information We Collect About You. We may collect and use the following personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:


Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers 

First name, Last name, Phone number, Home address, Email address, Photos, Videos, 

Other Identifiers

Payment information necessary to process your order 

Commercial information 

Purchase and order history, Browsing data, Preferred goods and services

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

IP address, Cookie data, Device IDs, Browsing data, Social media handles

Geolocation data

Inferred geolocation (e.g. IP address lookup)

Communication details (e.g. details of emails, texts, and other communications)

Message content, Message Subject, Time and date, Sender, Recipient, Calling number, Receiving number


If you do not provide personal information required to provide products or services to you, it may delay or prevent us from providing products or services to you.

PLEASE NOTE: We may also collect information that you may voluntarily provide through a chat bot function. In the event that you use our chat bot function, we use a third-party service provider to collect and respond to information you provide through this function.

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  1. How Your Personal Information is Collected. We collect personal information from the following categories of sources:

  • Information voluntarily provided by you, via the Website and related apps, by telephone, text, or email
  • Third parties, including 
    • Ecommerce partners
    • Advertising networks
    • Internet service providers
    • Data analytics providers
    • Operating systems and platforms
    • Social networks
  • And information automatically collected, including 
    • Cookies on the Website
    • Our IT and security systems

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  1. How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
  • To comply with our legal and regulatory obligations
  • For the performance of our contract with you or to take steps at your request before entering into a contract
  • For our legitimate interests or those of a third party –or–
  • Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:


What we use your personal information for

Our reasons

To provide products and services to you, including customer support, account management, billing and payment, order fulfillment, and provide service-related communications

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or TELFAR

For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you

Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies on an as requested basis. 

To comply with our legal and regulatory obligations

Operational reasons, such as improving and personalizing our goods and services, analytics, efficiency, training, and quality control

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers and visitors to the Website through marketing communications, online targeted advertisements, promotions and sweepstakes, and other marketing activities. 

For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers


For EEA and UK Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.

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  1. Cookies and Similar Tracking Technology. Like many websites, we use cookies and similar tracking technology (collectively, “Cookies“) on the Website. A cookie is a small text file that is recorded either temporarily or persistently on a hard drive by a web page server depending on use they enable us to recognize you without requiring you to repeatedly log in when using the Services. Web beacons are graphics designed to collect web log information such as pages viewed, or messages opened. 

For specific information about the Cookies that we use related to powering our Website with Shopify, see https://www.shopify.com/legal/cookies. Additionally, we partner with Google (https://policies.google.com/privacy), TikTok (https://www.tiktok.com/legal/page/us/privacy-policy/en), Meta (https://www.facebook.com/privacy/policy), Klaviyo (https://www.klaviyo.com/legal/privacy/privacy-notice), and Forter (https://www.forter.com/privacy-policy/), and others, and each partner collects information using Cookies placed on our Website. You should review the respective partner’s privacy notice for more information about how they may use your personal information. Personal information collected using Cookies can include your IP address, device IDs, browsing data, MAC address, and general location data, among other data components. We use Cookies to power and improve our Website and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on the Website to better tailor the services, products and advertising on our Website and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

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  1. EEA and UK Data Subjects: Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our products or services, including exclusive offers, promotions or new products or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us at shop@telfar.net or

  • Using the “unsubscribe” link in emails or “STOP” number in texts 

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

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  1. Who We Share Your Personal Information With. We routinely share personal information with:

  • Our affiliates, including companies within the TELFAR group

  • Service providers we use to help deliver our products and services to you, including, without limitation, payment service providers, warehouses, and delivery companies

  • Other third parties we use to help us run our business, such as marketing agencies, website hosts and others

  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

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  1. Personal Information We Sold or Shared. In the preceding 12 months, we have sold or shared the following categories of personal information:

  • Category of Personal Information

    • Identifiers such as basic contact details and certain order and account information

    • Commercial information such as records of products or services purchased and shopping information

    • Internet or other similar network activity, such as Usage Data

  • Categories of Recipients

    • Business and marketing partners, including, without limitation, Shopify

Third-party services providers and partners are obligated to comply with applicable data protection laws.

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  1. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number, bank account number, credit card number, debit card number, or other financial information.

  • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

  • Geolocation data

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  1. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To operate our business and provide you and other customers with our products and services

  • To respond to any questions, complaints or claims made by you or on your behalf

  • To show that we treated you fairly –or–

  • To keep records required by law

Different retention periods may apply for different types of personal information.

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  1. Other California Privacy Rights. California’s “Shine the Light” law (California Civil Code section 1798.83) gives customers who are California residents the right to ask, once a year, (1) what personal information was disclosed to third parties for those third parties’ direct marketing purposes in the prior calendar year; and (2) the identities of the companies with whom the information was shared. The terms “customers” and “personal information” have the meaning given by the Shine the Light (California Civil Code Sec 1798.83). We do not share personal information, as defined in California Code Civil Section 1798.83, with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with California’s Shine the Light law by sending us a written request to privacy@telfar.com or via mail to 2483 Coney Island Ave, Lower Level, Brooklyn, NY, 11223. Any such written request must include “California Shine the Light Law Request” in the first line of the description and include your name, street address, city, state, and zip code. We are only required to respond to one Shine the Light law request per customer per year, and we are not required to respond to requests made by means other than through this email address and mailing address. Further note that “Shine the Light” rights and CCPA rights are provided under different statutes and must be exercised separately.  

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  1. California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:


Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

  • The categories of personal information we have collected about you

  • The categories of sources from which the personal information is collected

  • The categories of third parties to whom we disclose personal information, if any –and–

  • The specific pieces of personal information we have collected about you

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained

  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–

  • Provide the personal information to you more than twice in a 12-month period

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

  • The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–

  • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal Information link here: https://telfar.net/pages/ccpa-opt-out


To further opt out of behavioral or targeted advertising, see http://www.thenai.org for general information about the NAI and https://thenai.org/opt-out/ for the opt-out page. You may also visit https://optout.aboutads.info/?c=2&lang=E to learn about interest-based advertising and how to opt-out from online behavioral ads served by some or all participating companies. Please note that you may need to opt out on each device and browser you use to access our Site.

Most modern web browsers give you the option to send a Do Not Track signal to the sites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a site should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records –and–

  • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort

Please note that we may not delete your personal information if it is reasonably necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us

  • Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes

  • Debug to identify and repair errors that impair existing intended functionality

  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law

  • Comply with the California Electronic Communications Privacy Act

  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us

  • Comply with an existing legal obligation –or–

  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

  • Provide a different level or quality of goods or services to you –or–

  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Please note, however, that we may charge a different price or rate or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

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  1. EEA and UK Data Subjects: Your Rights Under the EU GDPR and UK GDPR.


Right to Be Informed

The right to know or be notified about the collection and use of your personal information.

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

  • At any time to your personal information being processed for direct marketing (including profiling)

  • In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

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  1. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can contact us using the information provided here: https://telfar.net/pages/contact-us.

  • Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

  • If you choose to contact us directly, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, email address, address and customer or order reference number)

  • If requested, proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–

  • A description of what right you want to exercise and the information to which your request relates

  • We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.

  • Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

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  1. Other U.S. State-Specific Privacy Notices.

This Privacy Notice also applies to consumers who reside in states that have adopted consumer privacy laws. Because of differences in certain state laws and the effective dates of those state laws, this section may apply to residents of one or more states with consumer privacy laws requiring such information. States that have passed consumer privacy laws as of the date of this Privacy Notice are Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia (collectively “US State Privacy Laws”).  As described above, we have "sold" and "shared" (as those terms are defined in applicable law) personal information over the preceding 12 months for the purpose of engaging in advertising and marketing activities.

Your Rights Under Applicable US State Privacy Laws. To the extent applicable under US State Privacy Laws, you may have the following rights in connection with your personal information:

  • You have a right to confirm whether or not we process your personal information as well as to access and receive a copy of the specific personal information we have collected about you.

  • You have a right to receive the personal information you previously provided to us in a structured and commonly used format so that it can be transferred to another entity (“data portability”).

  • You have a right to deletion of your personal information, subject to exceptions under applicable US State Privacy Laws.

  • You have a right to request correction of any inaccurate personal information we hold about you.

  • You have a right to opt-out of our sale or our use of personal information for targeted advertising purposes.

  • Finally, you have a right to receive notice of our practices at or before collection of personal information and you have a right not to receive discriminatory treatment for exercising any of your rights described under this section. We will not discriminate against you based on your exercise of any of your rights.

You can assert these rights only where we receive a verified request from you. For information on how to exercise your rights, please see the “Exercising Your Rights” section above.  

Use of Agents. If you are a consumer in a jurisdiction that recognizes the ability to use an authorized agent and wish to contact us through an authorized agent, the authorized agent can submit a request on your behalf along with a statement, certified as may be required, that the agent is authorized to act on your behalf. In order to verify the request, we may ask you to verify your identity.  

Appeals. If you are in a jurisdiction that recognizes your ability to appeal a decision we have made in connection with your attempt to assert a right under applicable US State Privacy Laws (such as Texas, Oregon, Montana, Colorado, Connecticut or Virginia), you may file an appeal of our decision refusing your request to exercise your rights under this Privacy Notice. Requests to change our policies or practices are not grounds for appeal.  If your jurisdiction allows you to file a complaint with the state’s Attorney General’s Office regarding any concerns with the result of your appeal request, you may do so by using the following links as may be applicable to you: Virginia (www.oag.state.va.us/consumer-protection/index.php/file-a-complaint), Colorado (coag.gov/file-complaint), Connecticut (portal.ct.gov/AG/Common/Complaint-Form-Landing-page), and Texas (https://oag.my.salesforce-sites.com/CPDOnlineForm).

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  1. EEA and UK Data Subjects: Where Your Personal Information is Held. Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”). Some of these third parties may be based outside the UK and European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

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  1. EEA and UK Data Subjects: Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • With your and our service providers located outside the EEA

  • If you are based outside the EEA –or–

  • Where there is an international dimension to the services we are providing to you

These transfers are subject to special rules under European and UK data protection law.

Non-EEA countries may not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. 

If you would like further information, please contact us. (see “How To Contact Us” below).

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  1. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

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  1. EEA and UK Data Subjects: How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the UK or European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. 

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  1. Annual California Privacy Rights Disclosure.

Reporting is updated annually. Data identified below is for all requests received from US users between January 1 and December 31, 2023.



Requests Received*‡

Requests Complied With in Full or Part*‡

Requests Denied in Whole or Part*‡

Median & Mean Number of Days to Respond

Requests to Know

0

0

0

0

Requests to Delete

0

0

0

0

Requests to Opt-Out

0

0

0

0

*Requests complied with in whole or in part are verified requests that TELFAR timely processed and responded to, including where TELFAR confirmed it had no corresponding data for the consumer. Requests denied in whole or part include occasions when the consumer requestor failed to verify their identity.

‡Not limited to residents of California.

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  1. Children’s Online Privacy Protection Rule (“COPPA”). We do not knowingly or specifically collect personal information from users under 16 years of age. We do not authorize users under 16 years of age to use the Website or Services. Please notify us if you believe our Website or Services are being used by a child under the age of 13.

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  1. Changes to This Privacy Notice. This privacy notice was published on Sept 16, 2024 and last updated at that time

We may change this privacy notice from time to time–when we do, we will inform you via the Website or other means of contact such as email.

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  1. How to Contact Us. Please contact us by post or email if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:


Our contact details

2483 Coney Island Ave

Lower Level

Brooklyn, NY 11223

Privacy Compliance Officer at privacy@telfar.net

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  1. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

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