This Privacy Policy describes how your personal information is collected, used, and  shared when you visit or make a purchase from BoxedReturns.com. 

Boxed Returns (hereinafter “Boxed Returns,” “us,” “we,” and “our”) owns and operates the Website www.boxedreturns.com, and any and all computer applications or mobile  applications in connection with the same (each a “Website” and collectively the “Website”)  through our various subsidiaries (collectively, “Services”). 

Our Privacy Policy (“Policy”) states what information we collect, how that information is  collected, for what purposes we collect information (including specifically the legal basis  on which Personal Information we collect from you will be processed), how that  information is used, who we share it with and under what circumstances that information  would be released. Our Policy will also explain what rights you have in relation to your  Personal Information, what steps we take to secure your private information and what  steps you should take to safeguard that information. Finally, our Policy will tell you who  you can contact regarding questions about our Policy. Should you require assistance or  are having any trouble accessing this Policy or our Website, please contact us through  our website at www.boxedreturns.com. Material changes will be communicated by posting  an updated version of the Policy on this Website. 

The following are commonly asked questions about our Privacy Policy, as follows: 

1. What Type of Personal Information Do You Collect? The types of  information that we may collect from you are as follows: 
    1. Identifiers. Identifiers, such as your name, address (including, city,  state, postal code, and country), email address, telephone phone  number, secondary number, account name, IP address, and other  information you provide to us. 
    2. Commercial Information. Commercial information, including records  of personal property, product or services purchased, obtained or  considered, or other purchasing or consumer history. 
    3. Financial Information. Financial information, such as your VAT or  government-issued Tax ID, or any other financial information you  provide to us. 
    4. Network Activity. Internet or other electronic network activity  information, such as your usage statistics, information about your device  (including browser and operating system), your browsing history, access  times, and referring site.
    5. General Information. Audio, electronic, visual, thermal, olfactory or  similar information. 
    6. Background Information. Professional, employment, or education  information, such as your job title, company name (including company  website URL and number of employees). 
    7. Profile. Inferences drawn from any of the information we collect to  create a profile about you reflecting your preferences, characteristics,  psychological trends, predispositions, behavior, attitudes, intelligence,  abilities, and aptitudes. 
    8. Additional Information. We may request additional information from  you depending on certain transactions, contractual or regulatory  requirements. In such event, we will notify you of what information we  need, and how it will be used. 
2. What is the Source of the Personal Information? We collect information  about you and how you interact with us in several ways, including but not limited  to the following ways: 
  1. Information You Provide. We collect the information you provide to us  directly, such as when you register for an account with us through any  of our Websites or submit information to us (such as in connection with  a bid or purchase, when you submit an inquiry, etc.). 
  2. Information Automatically Collected. Information automatically  collected or inferred from your interaction with us. We automatically  collect technical information about your interactions with us (such as IP  address and browsing history). 
  3. Public Sources. Information from public sources. 
  4. Information From Third Parties. We receive information about you  and your interactions with us from third parties, such as from your  employer or co-workers, third party service and content providers, credit  reporting agencies, companies that provide or sell lists of potential  purchasers, and others interacting with us. 
  5. Cumulative Information. We may combine information that we receive  from the various sources described in this Policy, including third party  sources and public sources, and use or disclose it for the purposes  identified herein. 
  6. Applicable Policy. If you provide your Personal Information to us  offline, this Policy applies to our collection and use of your information.

 

3. How Do You Use My Personal Information? We may use your information  in the following ways: 

a. General Services. To provide services to you, such as to consummate  transactions with you; register and administer your account; to establish  and facilitate our business relationship with you; to respond to an inquiry,  complaint, or request from you; and to understand your preferences and  needs. 

b. Business Purposes. For our own internal business purposes, such as  to administer and improve our Website; to track and report Website  traffic; to analyze our customers’ demographics and interests; to help  diagnose potential problems with our server; to enhance or develop  features, products, and services; to monitor and analyze information  regarding your browsing and viewing preferences; and to otherwise  protect or further our legitimate interests. 

c. Compliance Purposes. For legal, safety or security reasons, such as  to comply with legal requirements; protect our safety, our property or  rights of those who interact with us, or others; and detect, prevent, and  respond to security incidents or other malicious, deceptive, fraudulent,  or illegal activity. 

d. Anonymity. In a de-identified, anonymized or aggregated format.  When converted to a de-identified, anonymized, or aggregated format,  data no longer constitutes Personal Information, and we may use this information for any purpose. We may use and share anonymized or  aggregated information with third parties. 

e. Marketing. We may use your Personal Information to send you e-mail  alerts and newsletters regarding upcoming auctions, sales events and  information about our products and services which we anticipate may be  of interest to you. 

f. Consent and Lawful Purpose. For any other lawful purposes for which  you provide consent. 

4. Who Do You Share My Personal Information With? We do not sell or release  your Personal Information to any third party (except as set out in this Policy)  without your consent, unless we are required to by law, or in the good-faith  belief that such action is necessary to conform to the edicts of the law or comply  with an official investigation by a law enforcement organization. With the above  said, we may share your Personal Information with the categories of recipients  described below:

a. Services Affiliates. We may share your Personal Information within the  Services group of business entities. 

b. Service Providers. We may share your Personal Information with  external service providers such as Salesforce, Oracle Eloqua, Amazon  Web Services and Microsoft Azure whose services we may utilize from  time to time to assist us in our provision of services to you and to assist  us in carrying out our business activities. We will only share your  information where it is lawful and required for the provision of services  to you or where you have consented to this. 

c. Third Parties That Provide Services or Communications. We may  also provide other Website users, vendors, third party partners,  subcontractors, or service providers with information as required in order  to provide services you request or to complete a transaction. 

d. Business Partners, Other Website Users or Other Third Parties. We  may also provide your Personal Information to our business partners for  their own purposes, including for third party marketing. If legally  required, we will seek your consent before engaging in such sharing. 

e. Legal, Security and Safety Purposes. In case of a subpoena, court  order or official request, we may share your Personal Information to  investigate, prevent or take action regarding suspected illegal activities,  fraud or potential threats, or exercise legal rights or defend against  claims, when we believe that doing so may protect your safety or the  safety of us or others, or as otherwise permitted or required by law. 

f. Corporate Reasons and Transactions. As we continue to develop our  business, we may sell or purchase assets. If another entity acquires us  or merges with us your Personal Information will be disclosed to such  entity. Also, where we carry out an asset sale of a particular business  division, your Personal Information (if held by such business division)  may be considered an asset of ours and as such it is possible it will be  sold or transferred to the purchasing third party. 

g. Auditing Purposes. We may provide transaction-related information to  government or private auditors to inspect or validate our business  practices, accounting records, or financial reports. Any release of  information for such a purpose will be done under standard  confidentiality restrictions. 

5. Why Do You Process My Data? Data protection laws require a specific lawful  basis for processing data, as follows:

 

  1. Data Protection Rights. We process your Personal Information when  our interests are not overridden by your data protection rights. 
  2. Inquiries. Where you provide Personal Information to us for the  purposes of an inquiry, the basis for processing is that it is required as  a legitimate interest of ours as a business to respond to your inquiry. 
  3. Business Relationship. Where we enter into a business relationship  with you, we rely on the legal basis of performance of a contract with  you for processing your Personal Information on the basis of that  contractual relationship and to complete a transaction with you. 
  4. Marketing Communications. Where we process your Personal  Information for the purposes of sending you marketing communications  (such as buy alert emails, information on upcoming sales events, special  announcements, etc.), we will rely upon the legal basis of legitimate  interests and/or consent (if required and obtained) for processing your  Personal Information for those purposes. You have the right to withdraw  consent at any time. Where consent is the only legal basis for  processing, we will cease to process data after consent is withdrawn 
  5. Feature Enhancement. Where we use your Personal Information to  enhance or develop features, products and services we rely on the legal  basis of legitimate interest as it is necessary for our legitimate interest  to provide a responsive service to our customers to keep them satisfied. 
  6. Legal and Regulatory Obligations. Where we process your Personal  Information to comply with our legal and regulatory obligations we rely  on the legal basis that such processing is required in order to fulfil a legal  obligation. 
  7. Notification. Before we alter the reason for using any Personal  Information you have provided to us, we will notify you of our intended  change in use of that information, ensuring such use complies with  applicable data protection law and where necessary obtain your consent  prior to using your Personal Information in a new way. 
6. Do You Send My Information Outside My County? Your Personal  Information shall generally be stored and processed in the United States.  However, your personal data may be stored and processed in any country  where we or our affiliates or approved partners have facilities or operations throughout the world, but rest assured that appropriate security measures and legal safeguards are in place whenever any cross-border transfers of Personal Information are conducted.

 

  1. For EU Residents. Where your Personal Information is transferred from  within the EEA to a country outside the EEA (including the United States)  we ensure that security measures and adequate safeguards are in place  for the transfer of Personal Information in compliance with applicable data protection laws on the transfer of Personal Information outside the EEA. To find out more about how we safeguard your Personal Information (including obtaining a copy of such safeguards) in relation to transfers outside the EEA, please contact us via the details provided in the contact us section below. 
7. How Long Do You Retain My Personal Information? We retain your  Personal Information for no longer than is necessary for the purposes for which  the information is collected and in line with this Policy. When determining the  relevant retention periods, we will take into account factors including the  following: 
  1. Our Contractual obligations. 
  2. Legal obligation(s) under applicable law to retain data for a certain  period of time. 
  3. Statute of limitations under applicable law. 
  4. [Potential] Disputes. 
  5. Compliance, regulatory and auditing purposes. 
  6. Guidelines issued by relevant national data protection regulators. 

Please be advised that we securely anonymize and/or erase your Personal  Information once it is no longer required. For further information about how long  we will keep your Personal Information, please contact us using the contact  details provided in the contact us section below. 

8. What are my rights?  

a. California Rights. Under California Civil Code §§ 1798.80-1798.85 and  California Business and Professions Code §§ 22575 – 22579, California  residents are entitled to the following rights pertaining to protecting their  Personal Information. Residents have the right to reasonable security of  their Personal Information by us, and to destruction of any Personal  Information that is no longer to be retained by the company via  shredding, erasing or otherwise modifying the Personal Information in  the records to make them indecipherable. Residents may expect that a  business that discloses Personal Information about a California resident  under a contract with a non-affiliated third party shall require by contract that the third party implement and maintain reasonable security  procedures and practices appropriate to the nature of the information, to  protect the Personal Information from unauthorized access, destruction,  use, modification, or disclosure. Residents have a right to timely  notification by us if we learn of an unauthorized disclosure or acquisition  of your Personal Information. Residents have the right to be informed by  our customer relations staff of how they can inquire about our privacy  practices or compliance with the above-referenced California laws.  Residents have the right to be provided contact information for inquiring  about the company’s privacy practices at every location in California  where we do business. Residents have a right to a response to any  inquiry regarding our privacy practices or compliance with California law  within 30 days of receipt of the inquiry by us. We may not request you  waive any of your rights under the above-referenced California laws. California residents also have certain rights under the California  Consumer Privacy Act (“CCPA”), subject to legal limitations and  applicable exceptions, regarding the collection, use, and sharing of your  Personal Information. California residents may exercise the following  rights by using the “contact us” section of our Website. 

b. UK and EEA Rights. You have a number of rights when it comes to  your Personal Information. Further information and advice about your  rights can be obtained from the data protection regulator in your country  of residence. You can exercise any of these rights by writing to us on  the email address below in the “contact us” section of our Website. 

c. The Right to be Informed. You have the right to be provided with clear,  transparent and easily understandable information about how we use  your information and your rights, which is the reason we created the  Privacy Policy articulated herein. 

d. The Right of Access. You have the right to obtain access to your  information (if we are processing it), and certain other information  (similar to that provided in this Website Privacy Policy). This is so you  are aware and can check that we are using your information in  accordance with data protection law. You can do this by writing us using  the “contact us” section of our Website. 

e. Correction Rights. You are entitled to have your information corrected  if it is inaccurate or incomplete. You can request that we rectify any  errors in personal information that we hold by writing us on the email  address below. 

f. Erasure Rights. This is also known as ‘the right to be forgotten’ and, in  simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it.  This is not a general right to erasure; there are exceptions. 

g. Rights to Restrict Processing. You have rights to ‘block’ or suppress  further use of your information. When processing is restricted, we can  still store your information, but may not use it further. 

h. The Right to Data Portability. You have rights to obtain and reuse your  personal data for your own purposes across different services. For  example, if you decide to switch to a new provider, this enables you to  move, copy or transfer your information easily between our IT systems  and theirs safely and securely, without affecting its usability. This is not  a general right however and there are exceptions. 

i. The Right to Object to Processing. You have the right to object to  certain types of processing, including processing for direct marketing  (i.e., receiving emails from us notifying you about other services we  provide which we think may be of interest to you or being contacted with  varying potential opportunities). You may change your preferences  regarding email communications by contacting us using the “contact us” section of our Website. 

j. The Right to Lodge a Complaint. You have the right to lodge a  complaint about the way we handle or process your personal data with  your national data protection regulator. 

k. The Right to Withdraw Consent. If you have given your consent to  anything we do with your personal data (i.e., we rely on consent as a  legal basis for processing your Personal Information), you have the right  to withdraw your consent at any time (although if you do so, it does not  mean that anything we have done with your personal data with your  consent up to that point is unlawful). You can withdraw your consent to  the processing of your Personal Information at any time. We usually act  on requests and provide information free of charge but may charge a reasonable fee to cover our administrative costs of providing the  information for baseless or excessive/repeated requests, or further  copies of the same information. Alternatively, we may be entitled to  refuse to act on the request. Please consider your request responsibly  before submitting it. We will respond as soon as we can. Generally, this  will be within one month from when we receive your request but, if the  request is going to take longer to resolve, we will let you know. 

l. Right to Know. You have the right to request information about the  categories of Personal Information we have collected about you, the  categories of sources from which we collected the Personal Information,  the purposes for collecting the Personal Information, the categories of third parties with whom we have shared your Personal Information, and  the purpose for which we shared your Personal Information (“Categories  Report”). You may also request information about the specific pieces of  Personal Information we have collected about you (“Specific Pieces  Report”). 

m. Right to Delete. You have the right to request that we delete Personal  Information that we have collected from you. 

n. Anti-Discrimination. We will not discriminate against you, in any  manner prohibited by applicable law, for exercising these rights. 

o. Verification. In order to exercise your rights, we will need to obtain  information to locate you in our records or verify your identity depending  on the nature of the request. If you are submitting a request on behalf of a household, we will need to verify each member of the household in  the manner set forth above. More information about our verification  process is available at our Website. 

p. Authorized Agents. You may use an authorized agent to exercise your  rights on your behalf. If you are making any of the requests above  through an authorized agent, we will request written authorization from  you and will seek to verify as described in our Website, or we will accept  a legal Power of Attorney under the California Probate Code to the  authorized agent. To make a request using an authorized agent, please use the “contact us” section of our Website and upload documentation  demonstrating you have authorized the agent to exercise rights on your  behalf. 

q. Timing. We will make every effort to respond to Requests to Delete and  Requests to Know as soon as possible, and usually no later than 90  days after a request is made. 

r. CCPA. Pursuant to the CCPA, below is a chart which contains a  summary of the personal information we collect from consumers, the  sources from which we collect the Personal Information, the business or  commercial purpose for which the Personal Information is collected, and  the categories of third parties with whom we share consumer Personal  Information.

 

Personal  

Data

Sources  

of  

Personal  Data

Business or  Commercial  Purpose for  Collection

With Whom We Share  Personal Data

Identifiers such  as name,  

address, IP  

address, email  address,  

account name,  and telephone  number

You,  

Affiliates,  

Third  

Parties, and  Service  

Providers

Auditing,  

Security,  

Performing  

Services,  

Internal  

Research,  

Quality  

Assurance,  

Legal, and  

Marketing

With Boxed Returns Affiliates;  with service providers that  assist us with providing our  products and services,  

including IT, storage,  

business operations, and  marketing service  

providers; in the event of a  merger, transfer of business  assets, or bankruptcy may  share your Data with  

buyers, lawyers, or  

professional advisors; and  to third parties when  

required to do so by law or  otherwise to protect our  legal rights, property, and  safety

Commercial  

information,  

including  

records of  

personal  

property,  

product or  

services  

purchased,  

obtained or  

considered, or  other  

purchasing or  consumer  

history

You or  

Service  

Providers

Performing  

Services,  

Internal  

Research,  

Legal, and  

Marketing

With our Affiliates; with  service providers that assist  us with providing our  

products and services,  

including IT, storage,  

business operations, and  marketing service  

providers; in the event of a  merger, transfer of business  assets, or bankruptcy may  share your Data with  

buyers, lawyers, or  

professional advisors; and  to third parties when  

required to do so by law or  otherwise to protect our  legal rights, property, and  safety

Financial  

information

You 

Performing  

Services

With our Affiliates; with  service providers that assist  us with providing our  

products and services,  

including IT, storage, 



 

business operations, and  marketing service  

providers; in the event of a  merger, transfer of business  assets, or bankruptcy may  share your Data with  

buyers, lawyers, or  

professional advisors; and  to third parties when  

required to do so by law or  otherwise to protect our  legal rights, property, and  safety

Internet or  

other electronic  network  

activity  

information,  

including, but  not limited to,  browsing  

history, usage  statistics, and  device  

information

You or  

Service  

Providers

Auditing,  

Security,  

Performing  

Services,  

Internal  

Research,  

Legal, and  

Marketing

With our Affiliates; with  service providers that assist  us with providing our  

products and services,  

including IT, storage,  

business operations, and marketing service  

providers; in the event of a  merger, transfer of business  assets, or bankruptcy may  share your Data with  

buyers, lawyers, or  

professional advisors; and  to third parties when  

required to do so by law or  otherwise to protect our  legal rights, property, and  safety

Audio,  

electronic,  

visual, thermal,  olfactory or  

similar  

information

You or  

Service  

Providers

Performing  

Services,  

Internal  

Research,  

Legal, and  

Marketing

With our Affiliates; and  with service providers that  assist us with providing our  products and services,  

including IT, storage,  

business operations, and  marketing service providers

Professional or  employment 

related  

information

You 

Auditing,  

Performing  

Services,  

Legal, and  

Marketing

With service providers that  assist us with providing our  products and services,  

including IT, storage,  

business operations, and  marketing service providers



 

Inferences  

drawn from  

any of the  

information  

identified  

above to create  a profile about  a consumer  

reflecting the  consumer’s  

preferences,  

characteristics,  psychological  trends,  

predispositions,  behavior,  

attitudes,  

intelligence,  

abilities, and  

aptitudes

You or  

Service  

Providers

Auditing,  

Security,  

Performing  

Services,  

Internal  

Research, and  Marketing

With our Affiliates, with  service providers that assist  us with providing our  

products and services,  

including IT, storage,  

business operations, and marketing service providers


s. We Do Not Sell Personal Information. We disclosed all of the  categories of personal information listed above for a business purpose  in the past 12 months. 

t. Other Rights. A user may request we discontinue the use of that  person’s Personal Information. If you would like to know what  information we have collected, would like any information purged, or  would like for us to discontinue using Personal Information, please  contact us using the “contact us” section of our Website. The return of  certain Personal Information by us may prevent you from accessing all  or certain portions of our Website, and we will endeavor to communicate  to you the extent to which your request will affect your use of our Website  prior to complying with your request. 

9. How Do You Communicate With Me? Upon registration, our site provides  users the opportunity to elect to receive email communications. To opt-out of  receiving marketing email communications from us please contact us at the  details provided in the “contact us” section in our Website, or follow the opt-out/  unsubscribe instructions included in marketing emails. Please be advised that  we may utilize third-party providers to assist us with the sending of marketing  emails to you. 

10. What Steps Do You Take To Secure My Personal Information? We are  committed to keeping your Personal Information safe and secure. We use  appropriate technical and organizational measures to protect against the loss, misuse and alteration of Personal Information. Employees having access to  Personal Information must undergo data privacy training and are monitored by  management to ensure that adequate safeguards are used to protect the  private information of our customers. Our Website has security measures in  place to protect the loss, misuse, and alteration of the information under our  control. Our Website uses SSL (secure sockets layer) encryption for all  sensitive data transmitted over the Internet. This includes customers adding  data to our Website, and employees transmitting data off our Website. No  information, including the passwords that would give access to sensitive  information, ever flows over the Internet un-encrypted. 

11. How Can I Protect My Personal Information? Please be advised that any  transmission of data over the internet is never completely secure. It may be  possible for third parties not under our control to intercept or access  transmissions or private communications unlawfully. Any such transmission of  your information is at your own risk. For any transmission of data over the 

internet, we recommend that you utilize all resources at your disposal to  minimize the risk of exposing your personal information, including the use of  firewalls, data protection software, antivirus software and similar technologies.  Additional precautions that you can take are as follows: 

  1. Email Not Secure. Never send credit card information via email.  
  2. Protect Your Account. Do not release information about your account  to anyone who is not authorized by you to transact business with us on  your behalf.  
  3. Protect Your Password. Do not tell your password to anyone. We will  never ask you for your password to verify your identity. 

12. Do You Use Cookies? Cookies are small text files that are placed onto your  device (e.g., computer, smartphone, tablet or other electronic device) when you  use a Website (including ours) and contain information such as your username,  user preferences, the web pages you have visited and the activities you’ve  performed while using our Website. We use cookies to deliver content specific  to your interests and customize your experience with our Website, and to store  your information so you do not have to re-enter it each time you visit our  Website, and for other lawful purposes. For our Website to function as  effectively as possible and provide you with the best user experience, it is  preferable for you to have cookies enabled. Some of our business partners  also use cookies to provide us with anonymous, aggregate data and  information regarding our users. We do not have access or control over these  cookies, and our Policy does not cover the use of third-party cookies. We also  use cookies for the following purposes:

 

  1. Functional Cookies. These cookies enable our Website to provide  enhanced functionality and personalization. They may be set by us or  by third party providers whose services we have added to our pages. If  you do not allow these cookies, then some or all of these services may  not function properly. 
  2. Targeting Cookies. These cookies may be set through our site by our  advertising partners. They may be used by those companies to build a  profile of your interests and show you relevant adverts on other sites.  They do not store directly personal information but are based on  uniquely identifying your browser and internet device. If you do not allow  these cookies, you will experience less targeted advertising. 
  3. Strictly Necessary Cookies. These cookies are necessary for our  Website to function and cannot be switched off in our systems. They are  usually utilized in response to actions made by you which amount to a  request for services, such as setting your privacy preferences, logging  in or filling in forms. You can set your browser to block or alert you about  these cookies, but some parts of our Website will not then work. These  cookies do not store any personally identifiable information. 
  4. Performance Cookies. These cookies allow us to count visits and traffic  sources so we can measure and improve the performance of our  Website. They help us to know which pages are the most and least  popular and see how visitors move around our Website. All information  these cookies collect is aggregated and therefore anonymous. If you do  not allow these cookies we will not know when you have visited our  Website and will not be able to monitor its performance. 

You can manage your Cookie preference settings when accessing each  Website. 

13. Do You Use Web Beacons? We or a third-party analytics provider engaged by us may also use “web beacons” to collect information about your use of our  Website, and Websites of selected sponsors and advertisers. Web beacons  are tiny graphic image files embedded in a web page or email that provide a  presence on the web page or email and send back to its home server  information from the user’s browser. The information collected by web beacons  allows us to statistically monitor how many people are using our Website,  selected sponsors’ and advertisers’ websites and using our services and for  what purposes. 

14. Are Children Allowed On Your Website? Our Website is not directed at,  marketed to, not intended for individuals under 18 years of age nor do we  knowingly collect information, including Personal Information, from children  under age 18 on our Website or offline. If you are under 18, you are not permitted to register for emails or newsletters or to otherwise submit any  Personal Information to us. If a child under the age of 18 submits Personal  Information to our Website, we delete the information as soon as we discover it was provided by a child under 18 years of age and we do not use it for any  purpose. 

15. How Do I Contact You About My Personal Information? If you believe that  your Personal Information has been improperly released by us to a third party, or if you have questions about how we collect, store, use, or destroy your  Personal Information, or how to exercise your rights in relation to your Personal  Information, you may contact us at the email address, telephone number, or  mailing address listed in the “contact us” section of our Website. When  contacting us about your Personal Information, please do not include your  account password, credit card number, date of birth, driver license number, or  social security number in any email to us. If you experience difficulty in  correcting Personal Information or have questions regarding our Policy, please  contact us using the “contact us” section of our Website. Additionally, if you  wish to file a complaint about our collection, use, disclosure, or protection of  your Personal Information, or if you have specific questions about our policies  or practices regarding collection, retention, use, or disclosure of Personal  Information, please contact us using the “contact us” section of our Website. You also have the right to complain to a data protection authority about the  collection and use of your personal data. For more information, please contact  your local data protection authority. 

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