Privacy Policy

Last Updated: 11/06/2024

To print this Privacy Statement, please click here.

Keystone Partners (“we”, “our”, “us”) and its family of businesses and services, is committed to protecting the privacy rights of all persons with whom it deals on the websites controlled by Keystone Partners, where this Privacy Statement is provided (“Sites”), as well as when Keystone Partners interacts with you via its services (“Services”). To demonstrate its commitment to your privacy, Keystone Partners has made its information and privacy practices available in this Privacy Statement.

This Privacy Statement applies when you interact with our Sites and Services located at:

 

This Privacy Statement does not apply to:

  • Any specific contracts agreed to by the parties and relationships that may be governed by further privacy agreements. If you are engaging with us on behalf of your employer, others in your company, or are otherwise providing the personal information of others, by engaging with us, you acknowledge and agree that you have the consent of the other individual.
  • There may be links to other sites from the Sites that take you outside our Services. These other sites may send their own cookies to users, collect data, or solicit personal information. Personal information which you choose to provide to another party or website will be subject to their privacy policy. Keystone Partners is not responsible for the privacy practices or the content of other websites that may be linked to our Sites.

 

By using this Site or our Services, you agree that you have read and understand this Privacy Statement.

Notice at Collection

Within the past twelve months, we may have processed the following categories of personal information either directly from you, indirectly through your use of the Sites or Services, or from service providers or third parties: identifiers; financial information; commercial information; internet or other electronic network activity information; audio, electronic, visual, or similar information; employment or professional information; education information; geolocation information; demographic information; content of communications; or any other information that you provide to us. We use your personal information to: complete your registration; for internal business purposes; to improve our Sites and Services; for advertising and marketing; to maintain security; and for legal compliance. We may disclose, sell, or share your personal information as outlined in the section, “How We Disclose, Sell, or Share Your Personal Information.” The personal information we might “sell” or “share” includes: your identifiers; commercial information; professional or employment information; education information; internet and online activity information; geolocation information; financial information; and any other personal information you provide on our Sites where cookies are present. Please click this “Do Not Sell or Share My Personal Information” link to opt-out. We will retain your information for as long as needed to fulfill the purpose for which it was collected and to comply with our legal obligations, resolve disputes, and enforce our agreements.  To understand what rights may be available to you, please see the section, “Personal Information Options and Rights.” If you have questions or concerns regarding the privacy of your personal information, please write to Keystone Partners’ Privacy Officer at dataprivacy@keystonepartners.com or call 1-800-822-9492.

By using the Keystone Partners’ Sites and Services, you agree to the policies and practices described in this Privacy Statement. If you provide personal information in your capacity as an employee, you represent that you agree to this Privacy Statement on behalf of your employer.

What is Personal Information?

Personal information is information relating to an identified or identifiable individual, (e.g., name, email address, mailing address, phone number, credit card number).  Personal information is considered information that is linked to, or can be linked to, a specific individual. Personal information does not include publicly available information or information that has been changed so that it can no longer be linked to you.

Personal Information We Collect and Sources of that Information  

We may, and in the past 12 months we may have, collected certain personal information, including:

  1. Identifiers, such as your name, street address, email address, job title, employment information, employer, and phone number, and other information that would be related to the delivery of the services we are providing. We collect this information directly from you when you submit a membership application, use our Sites or Services, or attend Keystone Partners events. We may also collect this information from other parties, like social media platforms, third party career sites or platforms, or data analytics and advertising providers when you interact with our Sites, Services, or advertisements on third party websites.
  2. Professional or Employment Information, such as current employer, job title, and contact information of your employer. We collect this information directly from you when you submit a membership application, use our Sites or Services, attend Keystone Partners events, and when you submit this information with your professional profile. We may also collect this information from data analytics and advertising providers, or from third party career sites or platforms, such as LinkedIn.
  3. Education information, such as level of education, degrees earned, or schools attended. This information is collected directly from you when you submit this information with your professional profile, from data analytics and advertising providers, or from third party career sites or platforms, such as LinkedIn.
  4. Demographic information, such as age or gender. This information is collected directly from you when you become a member, create a profile, or provide it via our Sites or Services.
  5. Commercial information, such as business name, business address, and business contact information, such as phone number or email address. We may process this information in connection with your membership. This information is collected directly from you when you use our Sites to apply for membership, or from data analytics and advertising providers when you interact with our Sites or Services.
  6. Geolocation information, such as IP address and zip code. This information is collected directly from you or from data analytics and advertising providers. We do not process precise geolocation information.
  7. Financial account information, such as bank account information or credit card information. This information is collected directly from you by our third party payment processor when you sign up for our Services or renew your membership.
  8. Internet, technical, or other similar network activity, which may include usage and browsing history; device and network information, including device properties, the server you are logged on to, domain name of your internet service provider, browser type and version, or general geographic area associated with your IP address; weblogs; time zone; date; language preferences; browsers used; web addresses visited; and other communication information. This data is collected from data analytics and advertising providers when you interact with our Sites or Services.
  9. Audio, Electronic, Visual, or similar information. This may include call recordings when you contact us or customer support; recordings of our coaching sessions or webinars; or when you submit a photograph. This information is collected directly from you when you contact us, interact with certain features of our Sites or Services, or when you submit the information in connection with your membership or profile. We may also collect this data from service providers when you contact customer support.
  10. Content of communications, such as the content of phone calls, emails, or text messages when you interact with us or third parties working on our behalf. This information is collected directly from you when you contact us or interact with our Sites or Services.
  11. Sensitive personal information, such as your username and password. This information is collected directly from you when you login to the Career Gateway or Customer Portal.
  12. Any other information that you provide to us. We collect this information directly from you, such as when you submit a membership application, or when you provide information in a webform.

 

How We Use Your Personal Information

Keystone Partners uses the personal information described above for the following purposes:

  1. Registration. To register you for Services using any of the Sites. Some of the information requested from you during registration is optional and is clearly identified as such on the Sites. The legal basis for processing your personal information for these purposes is mainly our legitimate interest, consent, or performance of contract.
  2. Internal business purposes. To help us understand our members and do market research, and to provide our Sites, Services, and membership benefits. We may also use your contact information to communicate with you about your account, respond to your inquiries, and to provide customer support. We may also send you emails or other communications regarding updates to the Sites or Services, such as new career opportunities which may be of interest to you. The nature and frequency of these messages will vary depending upon the information we have about you. The legal basis for processing your personal information for these purposes is mainly our legitimate interest.
  3. Improvement of our Sites or member benefits. To improve and grow our Sites, Services, and membership benefits. We may also request your feedback to understand the needs of our members. The legal bases for processing your personal information for these purposes is mainly our legitimate interest or your consent.
  4. Advertising and Marketing. To send you marketing, to personalize the ads you see on other websites, to establish and maintain communication, and to see how well our ads work. We have an area where you can submit feedback. Any feedback you submit in this area becomes our property, and we can use such feedback (such as success stories) for marketing purposes, without attribution, or contact you for further information and release. The legal bases for processing your personal information for these purposes is mainly our legitimate interest or your consent.
  5. Security. To protect our Sites, network, and business operations, and to stop activities that may violate our policies or be fraudulent or illegal. The legal basis for processing your personal information for these purposes is mainly our legitimate interest.
  6. Legal compliance. To comply with legal process like warrants or court orders, and to comply with federal, state, provincial, or municipal law. This includes the monitoring of personal information to ensure compliance with Keystone Partners policies. The legal basis for processing your personal information for these purposes is mainly for our compliance with our legal obligations.

 

Lawful Bases for Processing of Personal Information

We collect and use personal information when we have a lawful basis to do so, as follows:

  • Consent. We may process personal information with the consent of the individual whose data is being processed and/or in reliance upon the consent of the administrator of the account, who must affirm that s/he has obtained appropriate consent from all participants.
  • Performance of a Contract.  When we enter into a contract with you and/or an administrator for your account, we process personal information on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract. This is necessary for us to provide the Sites and Services to you.
  • As required by law.  We may process personal information as required to comply with legal obligations to which we are subject for the for the purpose of compliance with EEA, UK, or Swiss public, governmental, judicial, or other regulatory authorities.
  • For our legitimate interests. This includes but is not limited to legal compliance and the purposes described in this Privacy Statement.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If there is any material change in the purposes for which we collect your personal information, we will inform you of such change, such as by posting an updated version of this policy on the Sites or Services. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purposes, please contact us through the contact methods provided at the end of this Privacy Statement. 

Use of Cookies and Similar Technologies

We use, and may allow certain third parties (including advertisers, third party ad networks, and other ad companies), to use cookies, web beacons, social media pixels, Software Development Kits, and other similar online tracking technologies (together, “cookies”) to provide our Services, serve advertisements on the Sites or Services, and to improve the performance of our advertising across websites. A cookie is a text file that is placed on your hard drive to collect information about your activities on a website. You may remove yourself from the targeted advertising of companies that participate in the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here. For more information about what cookies we use, the personal information collected by cookies, and the purposes for which that personal information is collected, please visit out Cookie Policy.

Session Replay Technology

We may use session replay technology to monitor how you interact with our Sites or Services. The personal information collected by this technology may include which links you click on, pages and content you view, information that you type into our online forms, recordings of mouse clicks and movements, and information about your device or browser.

How We Respond to Do Not Track Signals

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.

We honor the Global Privacy Control as another way to opt out of the sale of your personal information or the sharing of it for targeted advertising purposes. The GPC is available here. GPC only works on your browser ID. If you have an account with us, we can’t tell based on your browser ID as it is not linked to your account, so if you would like to delete your account, please contact us.

How We Disclose, Sell, or Share Your Personal Information

We may disclose any of the personal information we describe above:

  1. The information gathered on the Sites or through use of the Services may be shared within Keystone Partners and its affiliated companies.
  2. Keystone Partners may make aggregate information about our users available to third parties for the purposes of marketing, advertising, and other beneficial services.
  3. We may disclose your personal information to other Keystone Partners companies, agents, contractors, service providers, and individuals we employ to perform functions on our behalf. Only the information necessary to perform a specified business function will be disclosed (e.g., to provide career assistance or host our web servers). These companies and individuals will have access to your personal information only as necessary to perform their functions and are subject to strict terms of confidentiality.
  4. To enable us to more efficiently provide the services you have requested from us, Keystone Partners may share aggregated anonymous information about visitors to the Sites or users of the Services. For example, we may disclose the number of visitors to the Sites with our clients, agents and other third parties so that they may understand the kinds of visitors to the Sites.
  5. During a change in ownership, such as a merger or bankruptcy,  your personal information may be reviewed and transferred along with other business assets.
  6. Where we have received your direction or consent to the disclosure of your personal information. 
  7. To fulfill a service to you or to respond to communications from you.  
  8. To protect the rights or property of Keystone Partners or our members and customers, including enforcing the terms governing your membership or use of the Sites or Services. 
  9. To act on a good faith belief that access or disclosure is necessary to protect the health and/or safety of our employees, members, or the public. 
  1. In other circumstances we may be required or authorized by law to disclose the information you provide. Though we make every effort to preserve user privacy, we may need to disclose personal information if legally required to do so, if requested to do so by law enforcement, a governmental entity, or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect the rights or property of Keystone Partners or its affiliated partners; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
 

We may “sell” or “share” your personal information as follows:

To personalize our ads and marketing experiences, we work with ad and analytics partners, ad networks, and social media sites. These partnerships may be considered a ”sale” or “sharing” for targeted advertising purposes under the California Consumer Privacy Act, even if that sale or sharing is in return for a service but no money changes hands. The personal information we might “sell” or “share” includes: your identifiers; professional or employment information; education information; internet and online activity information; commercial information; geolocation information; financial information; and any other personal information you provide on our Sites where cookies are present. Please contact our Office at: dataprivacy@keystonepartners.com or call 1-800-822-9492 to opt-out of this sale or sharing of your personal information. Keystone Partners does not sell or share the personal information of children under the age of 16. 

Prior to disclosing personal information to a third party and as required by applicable law, Keystone Partners will notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure, where allowed by applicable law.

Personal Information Options and Rights

Your Membership AccountPlease visit your account page to update your account information. You can choose to make this information visible to the public in your resume or you may choose for this information to remain private.

Email UnsubscribeYou have the option to elect to receive additional communications and information, including without limitation, free informational newsletters from Keystone Partners relating to topics that may be of special interest to you. You always have the option, however, to tell us not to share your personal information with other Keystone Partners Companies or to exclude you from offers for other products or services. You can unsubscribe from our updates at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing our Privacy Officer at dataprivacy@keystonepartners.com.

Text or SMS MessagingWe may also offer text/SMS messaging to you is you subscribe to the Career Transitions Services or Essex. At any time, you may opt out of receiving particular text messages from us (other than necessary reminders) by texting STOP in response to any text message.  

Regional Privacy Rights: Depending on your residence, the rights available to you may differ in some respects. We will respond to any rights request in accordance with local legal regulations.

The following rights may be available to individuals located in the European Economic Area, the U.K., Switzerland:

  • Right to Access: You may have the right to get confirmation about whether your personal information is being processed. If so, you have the right to access the personal information and other information, such as the purposes, the categories of personal information, the recipients (or categories of recipients) to whom the personal information have been or will be disclosed.
  • Right to Correction or Rectification: You may have the right to correct, rectify, or complete your personal information if inaccurate or incomplete.
  • Right to Erasure (“right to be forgotten”): You may have the right to the erasure or deletion of your personal information in certain circumstances.
  • Right to Restriction of Processing: You may have the right to restrict the processing of your personal information.
  • Right to Data Portability: You may have the right to receive the personal information that you have given us, in a structured, commonly used, and machine-readable format. You have the right to send that personal information to another controller if the processing is based on consent pursuant or on a contract and is carried out by automated means. For any further copies, we may charge a reasonable fee based on administrative costs. If you make the request by electronic means, and unless otherwise requested, the information shall be provided in electronic form.
  • Right to Object to Processing: You may have the right to object, on grounds relating to your particular situation, to processing of your personal information which is based on our legitimate purposes. We will stop processing the personal information unless we have compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims. If personal information is processed for direct marketing purposes, including profiling, you may object at any time.
  • Automated Decision-Making Technology, including Profiling: You may have the right not to be subject to a decision based solely on automated processing, including profiling, except under certain exceptions under local law.
  • Right to Withdraw Consent: Where the processing of personal information is based on your consent, you may have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.
  • Right to Lodge a Complaint with a Supervisory Authority: We are committed to working with you in the event that you have a complaint of concern about privacy. If you need help lodging a complaint, you can contact us through the contact methods provided at the end of the Privacy Statement. You may also have the right to lodge a complaint with a supervisory authority. Contact details for data protection authorities in the EEA and Switzerland are available here:
 

Residents of California, Texas, and Nebraska may have the following rights:

  • Right to Access: You may have the right to get confirmation about whether your personal information is being processed. If so, you have the right to access the personal information and other information, such as the purposes, the categories of personal information, the recipients (or categories of recipients) to whom the personal information have been or will be disclosed.
  • Right to Correction: You may have the right to correct, rectify, or complete your personal information if inaccurate or incomplete.
  • Right to Deletion: You may have the right to the erasure or deletion of your personal information in certain circumstances.
  • Right to Data Portability: You may have the right to receive the personal information that you have given us, in a structured, commonly used, and machine-readable format. You have the right to send that personal information to another controller if the processing is based on consent pursuant or on a contract and is carried out by automated means. For any further copies, we may charge a reasonable fee based on administrative costs. If you make the request by electronic means, and unless otherwise requested, the information shall be provided in electronic form.
  • Right to Withdraw Consent: Where the processing of personal information is based on your consent, you may have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.
  • Right to opt-out of profiling: If we base decisions solely on profiling or automated decision-making technology that may result in important legal or similarly significant effects, you may have the right to opt-out.
  • Right to opt-out of sale, sharing, and targeted advertising: You may have the right to opt-out of the sale or sharing of your personal information to third parties. To exercise this right, you may submit a request by contacting us. Note that we do not sell or share the personal information of individuals under 16 years old.
  • Right to limit the use and disclosure of sensitive personal information: You may have the right to limit the use and disclosure of your sensitive personal information if we use such information to infer characteristics about you.
  • Right to Nondiscrimination: We will not discriminate against you for exercising any of these rights.
 

The California “Shine the Light” Law: California law allows California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please put “Shine the Light” in the subject line if submitted by e-mail. 

Nevada’s Direct Marketing Law: Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their personal information to third parties. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us.

How to Exercise these Rights: If you wish to make a request regarding any of the below rights, please contact our Privacy Officer at dataprivacy@keystonepartners.com or call 1-800-822-9492. Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information. You may designate an authorized agent to make a request on your behalf. Such authorized agent must have permission to submit requests on your behalf.

We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. You may have the right to appeal a denial of your request by contacting us as described in the notice of denial. Please note that there are restrictions on the number of times you can exercise some of these rights.

Financial Incentive Programs

We may offer you financial incentive programs, like discounts and special offers in exchange for your personal information. The personal information requested in connection with the offer, as well as other terms, will be provided at the time you sign up. We may share your data with service providers and marketing partners to provide the program. We will provide the name of any program partners at the time you sign up.  In calculating these offers, we consider the expenses related to the offer and the value of your data.

You may withdraw from any of the programs at any time by following the instructions provided.  Please note that if you opt out or request to delete your data, we may no longer be able to provide you with the benefits. For offers involving your e-mail, you may unsubscribe via the “unsubscribe” link in any marketing email you have received.  For offers involving text messaging, you may text STOP.  For all other offers, you may follow the instructions provided with the offer. 

How and Where We Store Your Personal Information, Consent to Transfer

We only keep your personal information for as long as we need to provide the services you have requested and/or as long as permitted under applicable law.

If you are visiting our Sites from a location outside of the U.S., your connection may be through and to cloud based servers located in the U.S. Any information you provide during your visit will be processed and maintained on our server and other internal systems located within the U.S. You acknowledge you understand that by providing your personal information to us, your personal information (i) will be used for the uses identified above in accordance with this Privacy Statement, and (ii) may be transferred to the U.S. as indicated above, in accordance with applicable law. For example, where personal information is transferred from the European Economic Area or United Kingdom to areas which have not been determined to have an adequate level of protection, we take measures designed to transfer the information in accordance with lawful requirements, such as standard contractual clauses or the international data transfer agreement.

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

Disclaimer Regarding Video Content

The Sites and Services may contain social media pixels, cookies, or other similar tools which provide us and third parties with analytics regarding how website visitors interact with video content, audiovisual content, or content of a like nature. You may see targeted advertising on third-party websites or platforms because of these tools. Video content is provided via our Services for educational purposes, professional development purposes, or to enhance the user experience on the Sites. You understand that your personal information, including your video viewing history, may be processed according to this Privacy Statement.  We are not in the business of renting, selling, or delivering Video Content in a commercial manner. By using the Services, you agree that we are not a “video tape service provider” as defined in the Video Privacy Protection Act (“VPPA”), 18 U.S.C.A. § 2710.

Please note that this Privacy Statement does not apply to third-party video content on our Sites or Services. Please review the privacy policies of those third parties to understand their information practices.  

Online Forums, Social Media Pages, and Recorded Sessions

Please remember that any personal information that is disclosed in public areas of the Sites or Services becomes public information. Personal information you provide during recorded sessions will be accessible to other members. We recommend that you exercise caution when deciding to disclose any personal information, as it could be collected and used by others over whom Keystone Partners has no control. We are not responsible for the use made by third parties of information you post or otherwise make available in recorded sessions or in public areas of the Sites or Services.

SMS Text Terms and Conditions

By providing your contact information or confirming the use of our services, you are opting into communications by email, text and/or phone. When opted-in, you will receive text messages (SMS/MMS) to your mobile number. These kinds of messages may include, but are not limited to, appointment reminders or other information related to Keystone Partners service offerings. You can opt-out of this service at any time by simply replying “STOP” to the message. After you text “STOP” to us, you will receive a final SMS reply to confirm that you have successfully unsubscribed, and you will no longer receive SMS messages from us. To reinstate text message communications, text “START”.

Carriers, such as Verizon or AT&T, are not liable for delayed or undelivered messages. Message and data rates may apply for any messages sent to you from us and to us from you. Message frequency will vary. If you have any questions about your text plan or data plan, please contact your wireless provider.

Children’s Data

The Sites and Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.

Security

Keystone Partners has put in place reasonable physical, electronic, and managerial procedures to safeguard and secure your personal information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure due to the inherent risks of data transmission over the Internet. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Sites, Services, or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Sites. We may post a notice via our Sites or Services if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Your profile has a password so that only you can access it. We recommend that you do not provide your password to anyone. You are responsible for maintaining the secrecy of your account information and all activities that occur under your account. If you share a computer with someone else or are using a computer in a public location, remember to sign out and close your browser window when you have finished to ensure that others cannot access your personal information.

Data Integrity and Purpose Limitation

Keystone Partners will only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

Change in Business Ownership

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal information that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use that data only for the same purposes for which it was originally collected by us.

Changes to this Policy

Keystone Partners, LLC is the controller and legal entity which determines the purposes and means of processing your personal information. The Privacy Statement may be amended from time to time. If we plan to make material changes to our Privacy Statement, we will post those changes to the Sites at least 30 days before they take effect. If you have any questions about this Privacy Statement, our information practices, or your dealings with the Sites or Services, you can send e-mail to dataprivacy@keystonepartners.com or call 1-800-822-9492.

Questions or Concerns
If you have any questions or concerns about the information contained in this privacy statement, please contact our Office at: dataprivacy@keystonepartners.com or call 1-800-822-9492.

If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you may contact your supervisory authority:

In Canada:
Office of the Privacy Commissioner at info@privcom.gc.ca
Website: https://www.priv.gc.ca/en/ 

In the European Union:
Website: http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm

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