RISR Services Privacy Policy

Effective as of January 5, 2023

1. APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy describes the collection, use, disclosure, and retention of information by RISR, Inc. ("RISR," "we," "us," or "our") from or about you through our services as what your rights are. This Privacy Policy applies to our services regardless of how you access or use them, including through mobile devices. This privacy policy DOES NOT apply to visitors of our publicly-facing website at www.risr.com] which is governed by its own privacy policy.

BY USING OUR SERVICES YOU ARE ACCEPTING THE TERMS OF THIS PRIVACY POLICY AND YOU ARE CONSENTING TO OUR COLLECTION, USE, DISCLOSURE, AND RETENTION OF INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, THEIR CHOICE IS NOT TO USE OUR SERVICES.

Information We Collect on Behalf of Our Customers

We provide business valuation services and business insights to our customers, who are third party businesses advisors and other entities. If you have a relationship with one of our customers, it may be that RISR's software or services are integrated with that customer's websites, applications or services. In those instances RISR technology may collect certain personal data about you on behalf of our customers. We use any personal data in accordance with our contractual obligations to customers, which may include (1) providing services to customers; and (2) generating anonymized, de-identified or otherwise aggregated data that does not identify individual users ("Customer-Generated Data"). Where permissible either contractually or under the law, we may also use such Customer-Generated Data for purposes of conducting research and analytics relating to our business, benchmarking, improving security for our other users and customers, and enhancing the quality of our products, services and websites. For information about how we use information that we collect from you, please see the "How We Use Information We Collect From Or About You" section below.

IF YOU HAVE A CONTRACTUAL RELATIONSHIP WITH ONE OF OUR CUSTOMERS AND THAT CUSTOMER COLLECTS YOUR DATA UTILIZING RISR TECHNOLOGY, THE COLLECTION AND USE OF YOUR DATA MAY BE GOVERNED BY THE AGREEMENTS AND/OR PRIVACY POLICIES THAT YOU ENTER INTO WITH SUCH CUSTOMER AND NOT BY THE TERMS OF THIS PRIVACY POLICY.

If you use our Services outside of the United States, you understand and consent to the transfer of information we collect from or about you to, and the collection, processing, and storage of information about you in, the United States and elsewhere. The laws in the U.S. and these countries may be different than the laws of your country.

Under the EU General Data Protection Regulation (“GDPR”) and other similar laws, RISR may be considered a “controller” of certain personal data it has collected because RISR is responsible for determining how that personal data will be handled. This Privacy Policy is applicable to RISR's handling of personal data as a “controller.”

Further, this Privacy Policy also applies to personal data that RISR receives in the context of providing its services to its customers. For many of the services that it offers, RISR acts only as a “processor” (not a controller), which just means that RISR handles the personal data solely pursuant to the relevant customer's instructions, unless legally required to do otherwise. In instances where we act as a processor, not a controller, you should refer to any agreement or privacy policy you have entered into with the customer for whom we are processing data.

Your rights: You have the right to know what we know about you. You can make a request via email to: hello@risr.com. Make sure you include your name, phone number, email address in question and your home address. We will confirm your identity and get back to you.

This Privacy Policy applies to the personal data we collect about you in connection with:

• Management of our customer relationships and the provision of our services including through any accounts set up with RISR or the services that we offer.

• In connection with the use of our services and any other related applications by you, or if you are a RISR customer, by your end users or end customers.

• In email, text, and other electronic messages between you and RISR.

2. TYPES OF PERSONAL DATA WE COLLECT

We collect several types of information from and about users of our services, including information:

• By which you may be personally identified, such as your: name, postal address, e-mail address, telephone number, job title, employer name, or any other identifier by which you may be contacted online or offline and which is defined as person or personally-identifiable information under an applicable law. This includes any personally identifiable information you disclose on our social media platforms and sites when you browse or interact with our products and services.

• If you have a contractual relationship (including, but not limited to, a business advisor relationship) with one of our customers, that customer may provide RISR with information about you.

• If you enable such sharing, RISR may collect information about you and/or your business from your third party services providers. By way of example, if you are a QuickBooks user, you may enable QuickBooks to easily share information about your or your business with RISR to enable RISR to perform business insights services for our customers.

• About you or your customers' experiences with RISR services.

• About your accounts with us including user names, passwords, your feedback and survey responses.

• Concerning the interactions between you and our customers online properties, including any usage and security-related data such as information about authorized or unauthorized log-in attempts

• Unique identifiers such as the IP address or operating system which are assigned to a device that is being used to access our services or the website of our customer with which you interact.

• When you, your customers or visitors to your online properties navigate through and interact with the platforms, mobile apps, plugins, software, hardware and other platforms that comprise our services and products or through which we offer our services and products, we may use automatic data collection technologies such as cookies, web beacons and JavaScript and other computer code to collect certain information about your equipment, browsing actions, and patterns. Please see below for more details on these automated means.

• From customer networks, websites, customer applications that have integrated RISR hardware, software or plugins and any associated customer logs that are generated in response.

• From third parties and offline sources, such as our partners, vendors, data brokers, marketing and analytics providers, referral information that may have been provided from our other customers.

• From publicly available sources.

When necessary to meet our obligations under applicable law, we may also collect personal data and in turn may notify our customers to do the same.

AS PERMITTED BY LAW WE MAY ALSO DE-IDENTIFY, AGGREGATE OR OTHERWISE ANONYMIZE PERSONAL DATA ABOUT YOU IN WHICH CASE THE DATA WILL NO LONGER IDENTIFY YOU OR BE LINKED TO YOU (“ANONYMIZED DATA”). ANONYMIZED DATA NO LONGER CONSTITUTES PERSONAL DATA AND IS NOT SUBJECT TO THIS PRIVACY POLICY. RISR MAY USE OR DISCLOSE ANONYMIZED DATA FOR ANY LAWFUL PURPOSE.

3. HOW WE USE INFORMATION WE COLLECT FROM OR ABOUT YOU

RISR may use and share personal data for the following types of purposes:

• To provide, review and improve RISR products, services and operations, including for the customization of our products and services.

• To provide you with information, products, or services that you request from us, or which might be of interest to you based on specific requests, including third party products and services.

• For enhancing our understanding of our current and prospective customers' needs and interests.

• Responding to requests for information.

• Analyzing and compiling trends and statistics, including performing market research and conducting surveys.

• For security, IT management, and related research, including for the collective defense of fraud prevention, fraud detection and cybersecurity threats.

• To facilitate the processing of payments.

• For internal business purposes and to facilitate our relationships with our customers, partners, and vendors.

• To provide business continuity, manage our operations or improve our security.

• To comply with any law, court order, legal process or legal terms, or based on our good-faith belief that it is necessary to conform or comply with any law, court order, legal process or legal terms; to cooperate with police and other governmental authorities; or to protect the rights, property or safety of our customers, applications and other platforms through which our services and products are offered to the public.

• To process or engage in a sale of all or part of our business, or if we go through a reorganization, merger or a comparable event.

• For communicating with you.

• To prevent activities that may violate our policies or be fraudulent or illegal.

• For any other purpose with your consent or to fulfill any other purpose requested by you.

We may use or combine the personal data with information that we collect offline or we collect or receive from third-party sources for any number of reasons, including to enhance, expand, and check the accuracy of our records. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.

Data Retention: We may retain information we collect from or about you for as long as reasonably required to satisfy the purposes for which we have collected the information, or as contractually obligated, or as required by law, whichever is longer. This means we will retain information about you both while you are an active user of our services and after you cease to be an active user.

4. HOW WE SHARE INFORMATION WE COLLECT FROM OR ABOUT YOU

We may share personal data with, for example:

• Our affiliates.

• Our customers with whom you have an existing business or contractual relationship. We may share information that personally identifies you with entities that use our service. By way of example, if you place a call to Adam inquiring about a real estate listing from a RISR customer and request a viewing, RISR may disclose your personal information to our customer in order to schedule a viewing.

• To third party vendors and service providers where you have specifically requested that we communicate with such vendor or service provider on your behalf.

• Third party service providers, including our subcontractors. We engage third-party service providers to perform functions on our behalf such as hosting, content syndication, content management, technical integration, marketing, analytics, customer service, and payment processing. These third parties may have access to information about you when needed to perform their functions.

• Contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• Joint marketing partners.

• Governmental entities

• Law enforcement or other entities involved in legal processes: we may use or disclose information we collect from or about you if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or in connection with our products, services; (b) protect and defend our rights or property, our products, services, or our users; (c) respond to a third party that alleges that you or any of customers have infringed their intellectual property rights; or (d) act to protect the personal safety of us, users of our products, services, or for the welfare of the public.

• Entities related to sales of our business, assignments or changes of control. We may change our ownership or corporate organization while providing our products, services and websites. We may transfer some or all information about you in connection with any merger, acquisition, sale of assets, or any line of business, change in ownership control, or financing transaction. Under such circumstances, we will request the acquiring party to follow the practices described in this Privacy Policy with respect to previously collected information. Nevertheless, we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat information about you in the same way as described in this Privacy Policy.

Our uses and disclosures of your personal data are also subject to our contractual obligations.

5. OUR LEGAL BASIS FOR THE COLLECTION, USE AND SHARING OF PERSONAL DATA

The laws in many jurisdictions, particularly in the EU, require data controllers, such as RISR, to inform you about the legal grounds that allow them to use or disclose your personal data. To the extent any such laws apply to RISR's handling, use or sharing of personal data, RISR's lawful basis of processing is as follows:

• Legitimate interests: We handle personal data because it furthers the legitimate interests of RISR, its customers, business partners, and its third party vendors in business activities such as the ones listed below:

• Fraud prevention and detection

• By allowing us to enhance our customers' cybersecurity and the cybersecurity of their online properties and other information technology assets

• To protect our customers, their business activities and/or their customers

• Providing customer service

• To keep our records updated

• To improve our promotional and marketing initiatives

• To analyze trends and conduct research about improving RISR's services and products

• Identifying business and legal risks and conducting assessments of the same

• To contact users and customers about our products, Customer and third party products and services that a user has specifically requested, or responding to users' general requests

We do not believe that our handling of data unduly impacts your interests, rights, and freedoms.

• Contractural Obligations: In many instances, our handling of personal data is necessary to meet our contractual obligations, or because we are planning to enter into a contract.

• Consent: When required by law, we will seek and obtain your consent. On other occasions, we may obtain your consent even when not required by law. For example, you may provide us with consent via the services to contact you for the purpose of providing more marketing information about our products and services or for other direct marketing. Sometimes, even if we do not seek your explicit consent, it may be permissible under the law for RISR to infer your consent from the circumstances. Additionally if you have a contractual or business relationship with one of our customers, our customer may obtain your consent for the processing of personal data described in this Privacy Policy.

• Legal claims: Disclosure and use of personal data may be required to investigate claims (including claims of fraud), and/or legal actions, violations of law or agreements, including this Privacy Policy.

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. COOKIES AND OTHER TRACKING TECHNOLOGIES

Like many comparable online services, we may use tracking technologies such as cookies, web beacons, JavaScript and similar technologies to record your preferences, and track the use of our products, services and websites. We may also use these technologies to monitor traffic, improve or develop our products, services and websites, and make it easier to use and more relevant. Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the applicable service may not work or may not work as designed.

We may use third-party analytics services to support our services, including Google Analytics. These analytics service providers use cookies or other tracking technologies to help us analyze how users interact with and use our services, compile reports about activity concerning our products, services and websites, and provide us other services. The technologies may collect information such as your IP address, time of visit, whether you are a return visitor, any referring website, and other information. We do not use these analytics service providers to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google's privacy policies. To learn more about Google's partner services and to learn how to opt out of tracking of analytics by Google click here.

Your browser or device may include “Do Not Track” functionality. Our information collection, disclosure practices, and the choices that we provide, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

7. CALIFORNIA AND OTHER STATE PRIVACY RIGHTS

The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), provides California residents with specific rights regarding their personal information. If you are a California resident, your rights are described below. If you have any questions about whether any of the following applies to you, please email us at hello@risr.com.

You have the right to request certain information about our collection and use of your personal information over the past 12 months, including the following:

• The categories of personal information that we have collected about you, as those categories are defined under the CCPA and CPRA.

• The categories of sources from which that personal information was collected.

• The business or commercial purpose for collecting or selling your personal information.

• The categories of third parties with whom we have shared your personal information.

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

• If we have disclosed your personal information for a business purpose over the past 12 months, we will identify the categories of personal information shared with each category of third-party recipient.

In addition to the rights described above, California law requires disclosure of the categories of personal information collected and shared with our affiliates and Customers over the past 12 months. Those categories, as described by the CCPA and CPRA, consist of the following:

• Identifiers, including name, email address, IP address, Social Security Number, and an ID or number assigned to your data.

• Customer records information such as Social Security Number, bank account number, and financial information.

• Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.

• Commercial information, including purchases and engagement with Company.

• Professional or Employment-Related Data

• Internet activity, including your interactions with our services and what led you to our Website.

• Inferences, including information about your interests, preferences and favorites.

As stated in the section above titled, “Information We Collect on Behalf of Our Customers Which Is Not Governed by This Policy”, the collection of your information, and your authorization to provide it, is governed by your relationship and contractual agreement with the Customer that is using our software and services. We do not ever sell or disclose your Personal Information.

If we have sold your personal information over the past 12 months, we will identify the categories of personal information purchased by each category of third-party recipient. AT THIS TIME COMPANY DOES NOT SELL ANY PERSONAL INFORMATION AND HAS NOT SOLD ANY SUCH INFORMATION IN THE LAST TWELVE (12) MONTHS.

If you are a California resident you have the right to request correction or deletion of the personal information that we have collected from you, as well as ceasing the sharing of any personal information we have collected from you subject to limited exceptions: for example, we may retain personal information to complete a transaction with you, or we may retain information that would affect the privacy of others or interfere with legal requirements. If your deletion request is subject to an exception under the CCPA or CPRA we may deny your deletion request.

To exercise the rights described above, you should send us written request via email to hello@risr.com or via the Company address listed below. Please ensure that your request (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information; and (2) provides sufficient detail to allow us to understand, evaluate, and respond to your request. We may not be obligated or able to respond to requests that do not meet these criteria.

For your security we may require you to verify your identity before we can act on your request. There may be information we will not return in response to your access request, such as information that would affect the privacy of others or interfere with legal requirements. Similarly, there may be reasons why we cannot comply with your deletion request, such as the need to keep your personal information to fulfill a legal obligation.

Company will use commercially reasonable efforts to respond to any complete and valid request within 30 days of receipt. There is no cost to submit a valid request although Company may require a fee if your request(s) are excessive, repetitive, or unreasonable. You will not be charged a fee, and your fee-bearing request will not be processed, without Company providing you with prior written notice.

Should you choose to exercise any of your rights under the CCPA or CPRA, Company will not deny you any services, charge you different rates, or provide lesser quality services. However, in the future Company may elect to offer different tiers of services as allowed by applicable laws which may contain differing prices, rates, or levels of quality, which may be related to the value of personal information that we receive from you.

California Civil Code Section § 1798.83 permits users of the Website that are 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 send an email to hello@risr.com or write us at RISR Inc., 7 Grey Court, Berwyn PA 19312.

If you are a resident of Colorado, Connecticut, Utah or Virginia you may have similar rights to know the categories of data we collect, use and disclose, as well as potential rights to request corrections or deletions of your data. To submit a request to know, correct or delete, please send an email to hello@risr.com. We may be required to take certain steps to verify your identity before processing your request.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, which may include rights to the following:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at hello@risr.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we can neither guarantee the security of your personal information transmitted to the Website nor can we guarantee that such information will not become publicly available. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. You can reduce these risks by using common-sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software on your electronic devices.

Users Outside of the United States

If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Website may be created on servers located in the United States, and all information you provide may be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country. By using the Website or submitting information to us, you specifically consent to the transfer of your information to the United States and to the facilities and servers we use, and to those with whom we may share your information.

Users in the European Union

If you are a resident of the European Union you may have specific rights with respect to your personal data which are set forth below. Please note that RISR is a data processor that does not collect data directly from individuals in the EU however your data may be collected by a Customer as a controller of your data and then sent to us to process in our role as a data processor.

EU Data Subject Rights

The right to access - You have the right to request RISR for copies of your personal data. We may charge you a small fee for this service.

The right to rectification - You have the right to request that RISR correct any information you believe is inaccurate. You also have the right to request RISR to complete information you believe is incomplete.

The right to erasure - You have the right to request that RISR erase your personal data, under certain conditions.

The right to restrict processing - You have the right to request that RISR restrict the processing of your personal data, under certain conditions.

The right to lodge a complaint with a supervisory authority - You have the right to report any complaints you may have of RISR activities to a supervisory authority.

The right to object to processing - You have the right to object to RISR' processing of your personal data, under certain conditions.

The right to data portability - You have the right to request that RISR transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact as set forth below.

Lawful Basis of Processing

1. With your consent as provided hereunder;

2. Performance of a contract with you or in our role as a processor of data for our Customers;

3. For the prevention of fraud

4. As necessary to comply with a legal obligation; and

5. To fulfill our legitimate interest in conducting our business, where your interests and fundamental rights do not override those interests including, but not limited to:

• providing the services for which you have enrolled and Goods you have purchased;

• to keep our records updated;

• to study how customers use our products/services, to develop them and grow our business and inform our marketing strategy;

• for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercises;

• contacting you about our products, or responding to your requests.

Change of Purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Subprocessors

Amazon Web Services will be our subprocessor and is located at 410 Terry Avenue North, Seattle, WA.

Retention of Data

RISR stores your data in our repositories for as long as the individual agreement with the data controller specifies. Once this period has expired, we will delete your data automatically through technological measures in a secure manner

Transfers of EU Data

We do not transfer your data to anyone except you upon request so there will not be a transfer of your data by RISR to any 3rd country or across international borders. To the extent you have a business relationship with our Customer they may transfer your data to RISR and such transfers are subject to your separate agreements with that Customer. RISR will maintain an audit trail of all data transfers by RISR.

8. OTHER IMPORTANT INFORMATION

Users Under Thirteen (13) : Our products, services and websites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on our websites or through our services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through any of RISR's products, services or websites, make any purchases, use any of the interactive or public comment features of RISR's products, services or websites, or provide any information about yourself to us, including your name, email address, telephone number, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at hello@risr.com.

Changes to Our Privacy Policy : If we make material changes to how we treat our users' personal information, we will notify you by email to the extent you have provided us with an email address (such as by submitting an information request). The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the RISR website and this privacy policy to check for any changes.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information Users provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on actions that you take. Where we have given you a password for access to certain parts of our website or services, you are responsible for keeping this password confidential. You should not share passwords with any third parties.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we can neither guarantee the security of your personal information transmitted to our website or software nor can we guarantee that such information will not become publicly available. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website, software or other applications. You can reduce these risks by using common-sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software on your electronic devices.

For questions about our Privacy Policy, you can contact us at hello@risr.com or contact us at:

515 E. Lancaster Avenue, Wayne, PA 19087 (610) 991-7165

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