Data Protection

Date: 31.08.2020
The protection of personal data is matter of trust and having your trust is of great importance for us. Therefore, it is naturally in our interest to respect your private sphere and your right to autonomously determine how we should handle your personal information. To make sure that you feel safe when using our online Services please allow us to inform you below of our data protection policy and the use of cookies. We strictly abide by existing legal provisions regarding the use of personal data.  

The following data protection provisions shall apply to the online Services as they appear under stylight.de ("Online offer" or „Service(s)“) as well as to the use of the Stylight mobile application (“App or “Online Offer”).

Contents

1. Responsible Entity
2. Right to Withdrawal of Consent
3. Collection, Processing and Use of Personal Data
4. Log Files
5. Cookies and Tracking Technology
6. Web and App Analysis
7. Social Plugins
8. Social Sign in (Registration via Social Networks)
9. Push Messages App
10. Newsletter
11. Share Functions (App)
12. Rights of the User
13. Contact

Responsible Entity

Stylight is a part of Inspiration Commerce Group GmbH. The responsible data protection entity is Inspiration Commerce Group GmbH, with address at Mühldorfstraße 8, 81671 München, Deutschland, hereinafter “Stylight” or „we“ or „us“. Any exceptions hereto are specifically addressed in the current data protection provisions.

Right to Withdrawal of Consent

You may at any time withdraw your consent to the use of cookies with effect for the future. To this end simply alter your selection under Data Protection Settings.

Collection, Processing and Use of Personal Data

General Observations

Personal Data means any information relating to an identified or identifiable natural person (for example, name, address, telephone number, date of birth or e-mail address). When we refer to processing of personal data, what we are doing, for example, is collecting, storing, using, transmitting or erasing the data.

In general, you may make use of our Online Services without needing to provide any personal data. However, the use of some specific Services may require the provision of personal data, such as when registering or when taking part in a prize competition. Any data which is compulsory is marked with an asterisk (*). The non-provision of the required data unfortunately disqualifies you from using the corresponding Services.

Purpose of Data Processing

We process your personal data for the purposes as described below and based on the afore-mentioned legal provisions. For those cases where the data processing rests upon the legal provisions of a legitimate interest, please allow us to detail where our legitimate interest lies and which we pursue when processing your data:

Balancing of interests; we have a legitimate interest in analysing the use of the Online Offers made by users in order to continuously improve and/or to adapt our Offers to our users´ preferences.

Balancing of interests; both we and other advertisers have a legitimate interest in carrying advertising via interest-based advertising and offer our users advertising which is customized to their personal preferences.

Contract fulfilment

Balancing of interests; we have a legitimate interest in performing direct marketing, only insofar as such direct advertising does not require previous consent as set out in German competition provisions.

Balancing of interests; upon request by users who have an active social plugin, we  have a legitimate interest in sharing the information of said plugin with the social networks. 

Contract fulfilment

Fulfilment of our legal obligation to ensure data safety as well as a balancing of our legitimate interests: we have a legitimate interest in removing disruptions, safeguarding system security and in identifying and following up on unauthorised access or access attempts.

Due observance of statutorily defined obligations, especially about the need to store specific information and in connection with company audits.

Balancing of interests; we have a legitimate interest in exercising and protecting our rights.

Upon request you will receive from us additional information regarding our balancing of interests to supplement the information on the “Legitimate Interests” as enumerated above based on the existing legal framework. To this end please refer to data provided under Contact.

Please keep in mind that you are entitled to object to the processing of your data for reasons of direct marketing or for personal reasons (see section User Rights).

Registration

If you wish to make use of services that require the conclusion of a contract, we will request that you please register. As part of the registration procedure we shall collect the personal data necessary to establish and apply the contract (for example, given name, surname, date of birth, e-mail address, where necessary data regarding the preferred method of payment or bank account holder) as well as, where appropriate, data to be provided on a voluntary basis. Compulsory data is marked with an Asterisk (*).

Transfer of Data to Third Parties

As a general rule we shall transfer your personal data to third parties only insofar as such transfer is necessary for the application of the contract; if either Stylight or third parties have a legitimate interest in the transfer; if you have given your explicit consent to the transfer or if said transfer is necessary to meet a legal obligation.

We can share personal data with a third party especially in the following cases:

• When we are bound in individual cases to do so by statutory requirements or by an enforceable administrative or court order;
• In connection with legal disputes (before the courts or with our lawyers) or with a company audit (conducted by an auditing body);
• When we are bound to share information with the investigating authorities in connection with potentially criminal offences;
• In case of sale of the business operations (sharing data with the buyer) .

Furthermore, we share personal data with providers of tools which carry advertising based on “interest-based advertising” as well as in special cases, where we share data with providers of analysis tools. Further detailed information regarding said providers can be found on our Consent Management Platform („CMP“), accessible under Data Protection Settings.

Any data submission to other third parties which occurs on a regular basis shall be clarified in the data protections stipulations. However, data submissions which occur based on a given consent, the corresponding clarification can be supplied when the request for consent is made.

Transfer of Data to Service Providers

We reserve the right to commission data service providers to collect and/or process data. The commissioned service providers will receive only the personal data which is necessary to carry out your task. In this way, for example, a service provider may be given your e-mail address to allow him/her to deliver a newsletter which has been ordered. Service providers may likewise be commissioned to provide server capacity. Service providers are generally brought on board as so-called processors who can process the personal data of the Online Offer´s user following  specific instructions imparted by us.

Further detailed information regarding said providers can be found on our Consent Management Platform („CMP“), accessible under Data Protection Settings.

Transfer of Data to non-EEA Countries

We also share personal data with third parties or processing agents whose registered offices are not in EEA countries. In this case, before we transfer any data we make sure that the processing agents which receive the data either offer the necessary standards of data protection or that our user has given explicit consent to the transfer (for example on the basis of an adequacy decision by the European Commission regarding the corresponding country in line with article 45 of the  [German] General Data Protection Regulation (DSGVO), via a self-certification by the recipient of the data for the EU-US-Privacy Shield in conjunction with the corresponding adequacy decision of the Commission in line with  article 45 DSGVO or the agreement of the so-called EU standard contractual clauses  of the European Commission with the data receptor in line with article 46 DSGVO) .

This is the case for third parties, or data processors in the following countries: USA.

An overview of data recipients in third countries and a copy of the specific agreements with their corresponding regulations to guarantee the appropriate level of data protection is available for perusal. To this end please use the data in the section Contact.

Duration of Data Storage and Retention Periods

We store data for as long as such data is necessary for the fulfilment of our Online Offers and their related Services or for as long as we have a legitimate interest  that justifies its continued storage. In all other cases personal data shall be erased, with the exception of data which we need to keep in storage for compliance with legal (for example, due to fiscal or commercial regulations) storage obligations (for example, invoices).

Data which is subject to retention periods shall be blocked until the expiry of the deadline period.  

The following time periods apply specifically to the personal data processed within the framework of this Online Offer:

• Log files: 7 to 10 days

Data Processing by App Stores

Before you can install this App, you should conclude an agreement on the terms of use with an App Store operator (for example,  Google, Apple) to permit access to said operator´s portal  (for example, Google Play, App Store). Within the framework of the use of the App Store, the App Store operator, as the responsible entity, collects and processes data such as username, e-mail address and the individual identity code of the user´s equipment. We are not a contractual party to the Agreement on the Terms of Use with the App Store operator and have no influence as to how the operator handles the data. The corresponding App Store operator´s data protection policy applies accordingly.

Data Erasure (App)

You may also erase all data collected by us within the framework of the App by removing said App from your mobile end user device. Please note that initially your data will only be blocked if binding statutory retention periods apply to this data.

Log Files

Each time the Internet is used, your internet browser automatically transmits specific information which we store for a duration of 7 to 10 days before it is then erased. This data is kept for the purpose of helping us trace disruptions and for reasons of security (for example, to investigate attempted attacks). Log files which might need to be stored as sources of evidence will be exempted from erasure until the corresponding case for which it is being saved has been solved. In specific cases, this data may be shared with the competent investigating authorities.

The following information is collected in the Log files:

• IP-address (Internet Protocol address) of the end user and from which the Online Offer is accessed;
• Internet address of the website from which the Online Offer was called up (the so-called Origin or Referrer-URL);
• Name of the service provider through which the Online Offer was accessed; name of the accessed files or information;
• Date, time and duration of the access;
• Transferred data volume;
• Operating system and information regarding the browser type and version used, including all installed Add-ons (for example, for the Flash Player); and
• http-Status-Code (for example, z. B. „Request was successful“ or „requested file not found“).

Log files are also used for the Web Analysis Web-Analyse.

Cookies and Tracking Technologies

This Online Offer uses Cookies and similar Tracking Technologies (hereinafter collectively referred to as „Cookies“).

What are Cookies?
Cookies are small text files which are sent out when a user visits a website, and which are saved in said user´s devices. If the same website is accessed, the user´s browser then sends the cookie´s content back, allowing the system to automatically recognise the user that has previously visited the website. Whereas some cookies are automatically deleted when the user closes the browser (the so-called session cookies), others are saved in the user´s browser permanently or for a specific amount of time, after which they are automatically deleted.

What information do Cookies save?
Cookies basically save no information which could allow the identification of the user (that is, no names, e-mail addresses or IP-addresses). Instead, Cookies typically contain a code (the so-called Identifier), as well as details regarding the storage duration and  sometimes specific technical attributes (for example, security features). Cookies may nevertheless be used to set up user profiles.

How to Configure or  Delete Cookies
Except for substantial cookies, (cookies which are essential and unavoidable), we only use cookies if we have received your consent to do so. You may give your consent via our Consent Management Platform („CMP“). You may withdraw your consent hereto at any time with effect for the future by configuring your private sphere settings in this sense. To this end please access: Data Protection Settings

You likewise always have the possibility of deleting cookies which have already been saved in your browser. Please note however that an exclusion of cookies may result in having only partial access or in having no access whatsoever to Online Offers

• Internet Explorer: Instructions under http://windows.microsoft.com/de-de/internet-explorer/delete-manage-cookies#ie=ie-11-win-7
• Mozilla Firefox: Instructions under https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
• Google Chrome: Instructions under https://support.google.com/chrome/answer/95647
• Safari: Instructions under http://help.apple.com/safari/mac/8.0/#/sfri11471

What Cookies do we Use?

Essential Cookies:
Together with other information, these cookies are strictly necessary for the correct functioning of our services. They guarantee that our service is safe and can be offered in accordance with your preferences. Hence, these cookies cannot be deactivated.

Functional Cookies:
We wish to provide you with the best service possible. To this end we constantly strive to  improve our services and your use experience, analysing likewise for this purpose the use made of services and evaluating the results obtained in a statistical format. 

Marketing Cookies:
To make our services even more personally suited to our users, we make use of these cookies and other information to provide personalized recommendations and targeted advertisement, making interaction with social networks possible.

Both Stylight and our business partners make use of cookies. This allows us and our partners to provide the user with targeted, customised advertisement, based on webpage and cross-device analysis of the user´s usage patterns. The data we and our partners collect  with the aid of cookies can be bundled with data from other websites.

Some of our partners have registered offices in countries outside the European Economic Area (EEA).

Should you deny consent to the use of these cookies or should you deactivate them at some later moment, you will only be shown advertisements which could be less relevant to you.

Web and App Analysis

Web-Analysis

We require statistic information regarding the use of Online Offers to ensure as user-friendly a design as possible as well as to undertake measurements of our reach and to carry out market analyses.

To this end we make use of Analysis Tools. The user profiles created by Tools with the help of functional cookies and via the examination and evaluation of the Log file are not merged with personal data. Moreover, the tools either wholly refrain from using the IP-addresses of users or the addresses are abbreviated after having been collected.   

As a rule, Tools providers process data only in their capacity as commissioned processors; they do so always in line with our instructions and never for their own account.   

Users have the option to prevent the creation of a user profile for analysis purposes by denying or withdrawing their consent to the use of functional cookies via the Consent Management Platform („CMP). The CMP likewise provides further information regarding the providers of the Tools used. To this end please access: Data Protection Settings.

Collection and Evaluation of User Patterns for Interest Based Advertisement (also by Third Parties)

We wish to present the users of this Online Offer with advertisements and special offers which are customised to their preferences (interested based advertisement), likewise limiting the frequency of specific ads.

The user profiles created by Tools with the help of marketing cookies are not merged with personal data. Moreover, the Tools either wholly refrain from processing the IP-addresses of users or the addresses are abbreviated immediately after having been collected.   

Where applicable, Tools suppliers pass on information also to third parties in pursuit of the afore-mentioned objectives.

Users have the option to prevent the creation of a user profile for interest-based advertisement purposes by denying or withdrawing their consent to the use of marketing cookies via the Consent Management Platform („CMP”). Please note that this procedure does not switch off advertising. Opting out of marketing cookies means that users can no longer be shown interest-based advertising based on their usage patterns. The CMP also provides further information regarding the providers of the Tools used. To this end please access: Data Protection Settings

We freely subscribe to the self-regulation of the German Data Protection Council for Online Behavioural Advertising (Deutscher Datenschutzrat Online-Werbung, DDOW). We abide by a the self-regulation codex (codex relating to providers of telemedia services – first parties ) which can be consulted by following the link: http://meine-cookies.org/DDOW/dokumente/DDOW_%20OBA-SR_Kodex_1st.pdf.

For more information regarding interest-based advertisement please consult the User Portal at www.meine-cookies.org. The link supplied below  also gives access to the most updated information regarding activation possibilities with relation to various Tools suppliers and on how to opt out from your data being collected and/or evaluated by these Tools: www.youronlinechoices.com/de/praferenzmanagement. 

A central opt-out system from different Tools, especially with regard to those of US-based suppliers, can also be accessed via the link: optout.networkadvertising.org

Both Stylight and our partners use browser cookies (small text files) to understand the preferences of the users that visit our sites and, in this way,  be able to provide relevant content and advertising.

App Analysis

We require statistic information regarding the use of Online Offers to ensure as user-friendly a design as possible as well as to undertake measurements of our reach and to carry out market analyses. To this end we make use of various Analysis Tools. The user profiles created by Tools through the evaluation of Log Files are not merged with personal data. Tools providers process data only in their capacity as commissioned processors; they do so always in line with our instructions and never for their own account. Moreover, the Tools either wholly refrain from using the IP-addresses of users or the addresses are abbreviated immediately after having been collected.  Related to each Tool you will find information from the corresponding provider as well as information on the available opt-out options to stop  your data from being collected and processed by the Tool. 

Advertising ID (App)

We use so-called Advertising ID, as made available by the operating system of the user´s mobile end device, for advertising purposes. For devices using Android operating systems this is the so-called Advertising ID, whereas for devices running on the iOS operating system this is the so-called Advertising Identifier (IDFA). The Advertising ID, as is typically the case with the online identification codes saved in cookies, are unique reference numbers which are not saved permanently. We make use of the user profiles of online usage patterns (for example, selected ad banners, visited sections of the offer, searches) created with the help of Advertising IDs to present the user with customised advertising and offers (interest based advertising). The data so gathered is not linked with other device information.

How to Avoid and/or Limit the Use of Advertising ID

The use of advertising ID for advertising purposes can be limited or even deleted by adjusting the settings of  your end device to this end (after deletion, a new advertising ID will be created, which will not be merged with the data collected for the previous ID).  

Technical instructions to deactivate personalised advertising:

Android Operating Systems:
-> Settings -> Google -> Display and then select „Reset Advertising ID“ and/or „deactivate customised advertising“

IOS Operating System (Apple):
-> Settings -> Data Protection-> Advertising and then select „Reset Ad-ID“ and/or „no Ad-Tracking“

Social Plugins

This Online Offer uses Social Plugins („Plugins“). Information on providers and on data protection can be found under Cookies & Tracking Technologies as well as under your Data Protection Settings.

All providers of Plugins are hereinafter collectively referred to as „Plugin Suppliers“.

To guarantee a high-level protection of your data when visiting our Online Offers, the website embeds Plugins using the so-called „Shariff-Solution“. This ensures that no connection is made to the server of the corresponding Plugin Supplier now of calling up the page with this Online Offer.

The internet browser will only establish a direct connection to  the corresponding Plugin Supplier´s server once the user him/herself has activated the Plugins. Only then does the Plugin Supplier receive the information that the user´s browser has called up the corresponding page with our Online Offer, even if the user lacks a user account with the supplier or if the user is not logged in at that moment in time. The Login data (Log files), including the IP address, is passed on by the user´s browser directly to one of the corresponding Plugin Supplier´s servers and, where applicable, will be stored there. These servers could be located outside the EU or the EEA (for example, in the USA).

The Plugins represent an enhanced functionality of the Plugin Supplier. The scope of the data collected and stored by the Plugin Suppliers´ is therefore beyond our control.

If you do not wish the Plugin Supplier to be entitled to collect and, where applicable, store and/or reuse the data it obtains via this Online Offer you should refrain from using the corresponding Plugins.  

Generally, it is possible to fully block the download of Plugins. The Add-ons for your browser help do this. These are the so-called Script Blockers.

For further information regarding the purpose and extent of the capture,  further processing and use of your data by Plugin Suppliers and relating to your rights and settings available for the protection of your privacy please refer to the privacy policies of the respective supplier. 

Social Sign-in

Registration/Login via Facebook (Facebook-Login)

We offer you the possibility to register or login to Stylight via your Facebook account. Should you wish to make use of this possibility, Facebook will provide us with the data that was necessary to carry out said registration or login (for example, e-mail address, name). Facebook Inc. is certified in line with the EU-US Privacy Shield and therefore offers valid guarantees for the transmission of information as foreseen by the provisions of the [German] General Data Protection Regulation (DSGVO).

We have no influence on the scope of the data collected by Facebook during the Facebook Login. If you do not wish for Facebook to collect and reuse the data regarding your person which it obtains via your use of this Online Offer for its own purposes you should refrain from using the Facebook Login. 

For further information regarding the purpose and extent of the capture, further processing and use of your data by Facebook and relating to your rights and settings available for the protection of your privacy please refer to Facebook´s privacy policies.

Registration/Login via Google

We offer you the possibility to register or login to Stylight via your Google account. Should you wish to make use of this possibility, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA („Google“) will provide us with the data that was necessary to carry out said registration or login (for example, e-mail address, name). Google is certified in line with the EU-US Privacy Shield and therefore offers valid guarantees for the transmission of information as foreseen by the provisions of the [German] General Data Protection Regulation (DSGVO).

We have no influence on the scope of the data collected by Google during the Google Login. If you do not wish for Google to collect and reuse the data regarding your person which it obtains via your use of this Online Offer for its own purposes you should refrain from using the Google Login. 

For further information regarding the purpose and extent of the capture, further processing and use of your data by Google and relating to your rights and settings available for the protection of your privacy please refer to Google´s privacy policies.

Push Messages App

You may on occasion receive so-called push messages from Stylight, even if you are not using the App at that given point in time. The messages may deal with information sent to you in relation to contractual issues (for example, indications as to the interruption of services due to maintenance works). You will only receive advertisement-related push messages if you have previously given your explicit consent in this sense.

You have the possibility to sign up for the reception of Push Messages with promotional content. The „CleverPush“service offered for this purpose is operated by CleverPush GmbH, Nagelsweg 22, 20097 Hamburg („CleverPush“). These Push Messages provide information on a regular basis regarding any updates in the contents of our Online Offers.

The reception of these messages can likewise be deactivated at any time in the settings of the App. Alternatively, you can also stop the reception of customized advertisement by modifying the settings on your mobile device.

Technical instructions to deactivate personalised advertising:

Android Operating System:
-> Settings -> Google -> Display and select „Reset advertising ID“and/or „deactivate personalised ads“

IOS Operating System (Apple):
-> Settings -> Privacy -> Advertisement and select „Reset Ad-ID“ and/or „no Ad-Tracking“

Newsletter

We offer you the possibility to order a newsletter to receive news and latest information.
We will save your email address, the time of registration and the IP address used for registration until you unsubscribe from the newsletter. The sole purpose of the storage is to send you the newsletter and to be able to prove your registration.

You can revoke your newsletter subscription at any time. Either conveniently using the link at the bottom of each of our newsletter mailings or by email to newsletter@stylight.com.

Share Functions (App)

Your end device offers the possibility of sharing the App´s contents with third parties (for example via e-mail, SMS or with share features in social networks). We have no influence over how the data is processed by, for example, social network operators. Solely accountable in this respect are the corresponding third-party providers.

Rights of the User

How can You Assert Your Rights?

Please refer to the indications offered under the Contact section to assert your rights. You are kindly requested to ensure that you can be unequivocally identified. Alternately, you can correct any data provided at registration or withdraw any consents previously given regarding the reception of advertising by altering the settings in the user account.

You can also delete your own user account as follows:

-> Registration/ Stylight Club -> My Profile -> Delete account -> Confirm (account erasure) with your password.

Please note that initially your data will only be blocked for the use it was originally intended to serve if binding statutory retention periods apply to this data.

Right to Information and Rectification

You have the right to obtain confirmation by Stylight as to whether your personal data is being processed. You likewise have the right to gain access to the personal data as processed by Stylight. Should the affected personal data be inaccurate or incomplete, then you are entitled to demand that such data be rectified or completed. Should this personal data have been passed on to third parties, these shall likewise be informed of the rectification undergone by said personal data should this be prescribed by law.

Right to Erasure (Right to be “Forgotten”)

You can request the immediate erasure of your personal data insofar as the legal requirements in this sense are met. This is especially the case when

• The personal data is no longer necessary for the objective(s) for which it was originally collected;

• The legal justification for processing your data rested only upon having received your consent hereto and your consent was subsequently withdrawn;

• You have objected to data processing for advertising purposes („Objection to Advertising”);

• You have objected to your data being processed on the legal basis of the existence of a legitimate interest for personal reasons and we cannot bring forth any justification that gives an overriding justification to enable us to process your data;

• Your personal data was processed unlawfully; or

• Your personal data must be deleted in order to comply with legal obligations.

Should we have passed this personal data on to third parties, these shall likewise be informed of the erasure of your personal data should this be prescribed by law.

Please keep in mind that your right to erasure must comply with certain limitations. For example, we are not entitled to delete any data that needs to be preserved for a longer period due to applicable legal retention periods. The right to data erasure is likewise excluded in cases where the data is needed to establish, exercise or defend legal rights.

Right to Restriction of Processing

You can request that we restrict the processing of your personal data insofar as the legal requirements in this sense are met. This is particularly the case when:

• You contest the accuracy of the personal data, and for a period enabling us to verify the accuracy of said personal data;

• Processing is unlawful and you oppose the erasure (see point above) of the personal data and request the restriction of its use instead;

• We no longer need the personal data for the purposes of the processing, but you nevertheless require said data for the establishment, exercise or defence of your legal claims;

• You have filed an objection based on personal grounds and until it has been determined whether your interests prevail.

Provided that the right to restriction exists, we shall proceed to flag the corresponding data to ensure in this way that it is processed only within the limits foreseen for such restricted data (especially for instances of defence of legal claims or with your consent).

Right to Data Portability

You have the right to receive your personal data, as collected for purposes of contract fulfilment or on the basis of your consent in a machine-readable format; you also have the right to request the transmission of said data to a third party, insofar as this is technically feasible.

Right to Withdrawal of Consent

You have the right to withdraw your consent to the processing of your personal data at any time and with effect for the future. The withdrawal of consent shall not affect the lawfulness of data processing based on consent before its withdrawal.

Objection to Direct Marketing

You are likewise entitled to object to the processing of your personal data for advertising purposes („Objection to Advertising“) at any time. Please note that for organisational reasons there could be an overlap period between the filing of your objection and the use of your data within the framework of a running campaign.

Your Right to Object on Personal Grounds

Based on a special personal situation you are entitled to file an objection to any processing of your data by us insofar as this request can be justified with the existence of a legitimate interest. In such a case, we shall abstain from any further processing of your data unless we can – as expressed in binding legal provisions – demonstrate that compelling reasons for the continued processing exist that outweigh your interests or if the processing serves the purpose of asserting, exercising or defending legal claims.

Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with the Data Protection Authorities. You can address your complaint to the Data Protection Authority which is responsible for the area or the region in which you live or which is responsible for the place in which the data protection regulation was breached. Alternately, you can address the complaint to our corresponding Data Protection Authority.

Contact

Our Data Protection Coordinator and Stylight are at your disposal for any information requests or comments you might have regarding data protection issues under the e-mail datenschutz@stylight.de or under our Data Protection Officer´s e-mail  epost@datenschutz-agentur.de.

If you wish to contact us, you may reach us as follows:

Stylight - part of Inspiration Commerce Group GmbH
Mühldorfstraße 8
DE-81671 Munich, Germany

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