Privacy Policy

Privacy Policy

uBioDiscovery Inc.

Introduction

We, uBioDiscovery Inc. (“uBioDiscovery”, “We”, “us”, “our”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Privacy Policy” or “policy”). This policy describes how we collect, use, disclose, and protect the Personal Information of our customers and website users (“you”), describes the types of information we may collect from you or that you may provide when you visit the website www.uBiodiscovery.ca (our “Website”), and our practices for collecting, processing, using, maintaining, protecting, sharing and disclosing that information.

Please carefully review this Privacy Policy, and our Terms of Service. By using our Services, you acknowledge that you have read and understood all of the policies outlined in these documents about the collection, storage, use and disclosure of your Personal Information. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy or our Terms of Service, you should immediately discontinue use of our Services and Websites.

Privacy laws in Canada generally define “Personal Information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This policy applies to information we collect, use, or disclose about our customers and Website users:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • When you interact with our advertising and applications on third-party websites and Services if those applications or advertising include links to this policy.
  • Mobile or desktop applications you download from this Website which provide dedicated non-browser-based interaction between you and this Website.
  • When you interact with any future subsidiaries of uBioDiscovery including but not limited to mobile application

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third -party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third-parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

This policy does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by the uBioDiscovery or any third-party (including affiliates).
  • Any third-party (including our affiliates and subsidiaries), through any application or content (including advertising) that may link to or be accessible from the Website.
  • Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your Personal Information.

 

Contents

  1. Definitions.
  2. Information We Collect About You.
  3. How We Collect Information About You.
  4. How We Use Your Information.
  5. How We Share the Information We Collect
  6. Storage of Samples.
  7. Data Security.
  8. Data Retention.
  9. Disclosure of Your Information.
  10. Transferring Your Personal Information.
  11. Choices About How We Use and Disclose Your Information.
  12. Accessing and Correcting Your Account and Personal Information.
  13. Withdrawing Your Consent
  14. Children Under the Age Of 13.
  15. Changes to Our Privacy Policy.
  16. Contact Information and Challenging Compliance.
  17. Last Updated.

 

 

1.     Definitions

“uBioDiscovery” means uBioDiscovery Inc., whose principal place of business is at 2404-201 Sherbourne Street, Toronto, ON M5A-3X2, and all affiliates and entities under common ownership with uBioDiscovery Inc.

“Aggregate Information” information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.

 “Microbiome Data” information regarding the bacteria present in your stool sample (e.g. which bacteria are present and in what proportions), generated through processing of your stool sample by uBioDiscovery or by its contractors, successors, or assignees; or otherwise processed by and/or contributed to uBioDiscovery.

“Personal Information” information that can be used to identify you, either alone or in combination with other information. uBioDiscovery collects and stores the following types of Personal Information: name, date of birth, billing and shipping address, payment information, and contact information (email, phone number).

 “Service” or “Services”: uBioDiscovery’s products, software, services, and Website (including but not limited to text, graphics, images, and other material and information) as accessed from time to time by the user, regardless if the use is in connection with an account or not.

“Terms of Service”: uBioDiscovery’s Terms of Service found at https://ubiodiscovery.com/terms-of-service/

“Website”: uBioDiscovery’s website and all its features found at www.ubiodiscovery.com

User Contributions” is all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials – other than Bacterial Information and Self-Reported Information– generated by users of Services and transmitted, whether publicly or privately, to or through uBioDiscovery.

2.     Information We Collect About You

  1. Information collected through the use of our Website
    1. i) We collect and use several types of information from and about you, including:
      • Personal Information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, data from your use of our Services (i.e. Microbiome Data) and any other identifier we may use to contact you online or offline.
      • We provide an opportunity for any user to discontinue use of our Services at any time or to opt-out of contact for marketing purposes on an ongoing basis by accessing your account on our Website and using the unsubscribe mechanism or emailing us at contact@ubiodiscovey.com.
      • Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated data. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may Aggregate Information to calculate the percentage of users accessing a specific feature of the Website.
      • Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
      • Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
    2. ii) You have the option to provide us with additional information about yourself through our questionnaires. Some of this additional information that you provide may include history of family disease, ethnicity, diet and lifestyle information, and other health-related information. Before you disclose information about a family member, you must make sure you have permission from the family member to do so.
  • iii) When you choose to share your results with another person, we will ask for you to enter that person’s email address. We will use the email address solely to communicate your sharing request to that person, and we will let your contact know that you requested the communication. By choosing to share information with another person, you confirm that the person has given you consent for uBioDiscovery to communicate with him or her.
  1. Information collected through the use of our Services
    1. i) When you register for our Service or create an account on com, we collect Personal Information, such as your name, date of birth, billing and shipping address, payment information, and contact information (including email and phone number).
    2. ii) To use our microbiome testing Services, you must purchase a kit, create an online account, register your kit, and ship your stool sample to our third-party laboratory.
  • iii) When purchasing a kit, you must review our Consent Document, and give consent to participate in the “microbiome services” outlined at https://ubiodiscovery.com/about-consents/. At uBioDiscovery, we do not collect genetic information, however, we collect information on the bacteria present in the sample provided.
  1. iv) uBioDiscovery uses Google Analytics to gather information about what pages on our Website were visited, how frequently, and how these users were directed to the Website. We do not keep or use any Personal Information for other purposes.

3.     How We Collect Information About You

  1. Information Collection Methods
    1. i) We use different methods to collect your information, including through:
      • Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone or email, sending in your stool sample to be analyzed or otherwise.
      • You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third-parties.
      • Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and tracking technologies.
    2. Information You Provide to Us
      1. i) The information we collect directly from you on or through our Website may include:
        • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our Service, posting material, and requesting further Services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
        • Records and copies of your correspondence (including email addresses), if you contact us.
        • Your responses to surveys that we might ask you to complete for research purposes.
        • Details of transactions you carry out through our Website and of the fulfillment of your orders. You will be required to provide financial information before placing an order through our Website.
        • Your search queries on the Website.
      2. Information We Collect Through Cookies and Other Automatic Data Collection Technologies
        1. i) As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
          • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
          • Information about your computer and internet connection, including your IP address, operating system, and browser type.
        2. ii) The information we collect automatically is statistical information and may include Personal Information and we may maintain it or associate it with Personal Information we collect in other ways or receive from third-parties. It helps us to improve our Website and to deliver a better and more personalized Service, including by enabling us to:
          • Estimate our audience size and usage patterns.
          • Store information about your preferences, allowing us to customize our Website according to your individual interests.
          • Speed up your searches.
          • Recognize you when you return to our Website.
  • iii) The technologies we use for this automatic data collection may include:
    • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
    • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information”.
    • Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

4.     How We Use Your Information

We use the information that we collect about you or that you provide to us, including any Personal Information:

  1. To process and analyze your data:

The third-party laboratory provides us with the sequencing data from your samples, which is then processed further by uBioDiscovery in order to provide you with your microbiome results and dietary suggestions. The scientists at uBioDiscovery have utilized the findings from scientific literature to make dietary suggestions based on the community of bacteria identified in each sample. This information is constantly being updated as new literature becomes available. A computer algorithm uses these guidelines to make a prediction for several food categories based on the microbiome sequencing data.

We use the information described above in Section 2 to operate and improve our Services. This may include using your information to register your account, process payments, communicate with you, host our Website, contact you about your account, detect prohibited actions, to perform research and data analysis in order to improve our existing Services, and to develop new products and Services, and other related activities outlined in our Terms of Service and Privacy Policy.

  1. To present our Website and its contents to you.
  2. To provide you with information, products, or Services that you request from us.
  3. To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
  4. To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
  5. To notify you about changes to our Website or any products or Services we offer or provide though it.
  6. To improve our Website, products or Services, marketing, or customer relationships and experiences.
  7. To allow you to share your data with others:

When you choose to use the sharing tool, you are asked to enter the email address of the person you wish to share all of your sample results with. We will use the email address solely to communicate your sharing request to that person, and we will let them know that you requested the communication. By choosing to share information with another person, you confirm that the person has given you consent for uBioDiscovery to communicate via email with him or her.

  1. For research purposes:

When purchasing a kit and/or creating an account on ubiodiscovery.com, you are asked to read and accept our Privacy Policy and Terms of Service. By accepting these terms, you are acknowledging and agreeing to allow uBioDiscovery to use your de-identified data for research purposes. This data may be published by uBioDiscovery personnel or be used to improve our Services.

  1. For customer support

When you create an account on ubiodiscovery.com with your email address, you are agreeing that we may send you promotional emails or notifications about our Services, new products or services, and promotions. You can unsubscribe from receiving these marketing communications at any time by replying with the word “unsubscribe”. You may not opt-out of receiving non-promotional messages regarding your account.

5.     How We Share the Information We Collect

We reserve the right to share the information we collect with;

  1. a) Service Providers

We share the information described above in Sections 2 and 3 with our third-party service providers, only as necessary, to help us operate and deliver our Services to you. Some of these third-party vendors perform services that include web maintenance, consulting, data backup and storage, sample processing and sequencing.

  1. b) Research Collaborators

The information that is to be used in research as described in the Research Consent document, available at, https://ubiodiscovery.com/about-consents/, may be shared with research collaborators for the purpose of publication in a peer-reviewed scientific journal. We may share this information in an aggregated and anonymous form that does not identify you directly as an individual.

We may also share information as required to satisfy any applicable law, regulation, court order, legal process or other government request, or to investigate and defend ourselves against any third-party claims or allegations.

  1. c) Third-Party Websites

Our site may contain links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies.

  1. d) General Third-Parties

We may share Aggregate Information with third-parties. This information is de-identified; it does not include your name, any contact information or any other information that would allow you to be identified, and would be combined with the information of other individuals.

  1. e) Business Transactions

If uBioDiscovery is acquired by another company, your information may be among the assets transferred. In such a case, your information would remain subject to the pre-existing Privacy Policy that was valid when you used our Services.

6.     Storage of Samples

uBioDiscovery retains your stool sample following the microbiome analysis. These samples may be used for future research or for quality control purposes. If you wish to have your stool sample discarded and not used for future research, please contact us at: contact@ubiodiscovery.com.

7.     Data Security

The security of your information is very important to uBioDiscovery. We take administrative, physical and electronic safety measures to maintain the security of your Personal Information and Microbiome Data, and to prevent unauthorized access and accidental loss. Your Microbiome Data is stored in a different location from your registration information, and all Microbiome Data is randomly assigned a code so that an individual’s results cannot be identified by third-parties nor in the event of a security breach. In the event that any of your Personal Information is accessed due to a breach in security, we will investigate the situation and notify any individual whose information may have been accessed. uBioDiscovery uses two factor authentication and our site is hosted in a secure environment.

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 our 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 like message boards, which any Website visitor can view.

Although we do take these measures to secure your privacy, we cannot guarantee the security of your Personal Information transmitted to our Website. 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.

8.     Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

9.     Disclosure of Your Information

We may disclose Aggregated Information about our users, and information that does not identify any individual, without restriction.

  1. We may disclose Personal Information that we collect, or you provide as described in this privacy policy:
  2. To our subsidiaries and affiliates.
  3. In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of uBioDiscovery’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by uBioDiscovery about our customers and users is among the assets transferred.
  • To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with Aggregate Information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisements on a specific day). We may also use such Aggregate Information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the Personal Information we have collected from you to enable us to display our advertisers’ advertisement to that target audience.
  1. To third-parties to market their products or services to you if you have consented to/not opted out of these disclosures.
  2. To contractors, service providers, and other third-parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy.
  3. To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “Share with” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  1. To third-parties who may process your data for the purpose of providing the SUPERBIOME service or any other Service provided by us.
  2. We may also disclose your Personal Information:
  3. To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
  4. To enforce or apply our Terms of Service, available at https://ubiodiscovery.com/terms-of-service/ and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of uBioDiscovery, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

10.  Transferring Your Personal Information

We may transfer Personal Information that we collect or that you provide as described in this policy to contractors, service providers, and other third-parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy.

We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your Personal Information or engaging with the Website, you consent to this transfer, storage, or processing.

11.  Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  1. Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see “Information We Collect Through Cookies and Other Automatic Data Collection Technologies”.
  2. Promotional Offers from uBioDiscovery. If you have opted in to receive certain emails from us but no longer wish to have your email address used by us to promote our own or third-parties’ products or services, you can opt-out at any time by logging into the Website and adjusting your user preferences in your account profile or by sending us an email stating your request to contact@ubiodiscovery.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to us as part of a product purchase, warranty registration, product service experience, or other transactions.
  3. Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by logging into the Website and adjusting your user preferences in your account profile or by sending us an email stating your request to contact@ubiodiscovery.com. For this opt-out mechanism to function, you must have your browser set to accept browser cookies.
  4. We do not control third-parties’ collection or use of your information to serve interest-based advertising. However, these third-parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

12.  Accessing and Correcting Your Account and Personal Information

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.

You can review and change your account settings and Personal Information by logging into the Website and visiting your account profile page. You may contact our support team if you ever lose access to your account login credentials, such as your email address and password. We can help you retrieve this information, or to create a new account. We may require that you submit additional information to verify your identity before providing access or releasing information to you. If you choose not to submit the required documentation, uBioDiscovery may not be able to sufficiently verify your identity in order to complete your request.

If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us an email at contact@ubiodiscovery.com to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your Personal Information, subject to the exceptions set out in applicable privacy legislation.

Examples of such exceptions include:

  • Information protected by solicitor-client privilege.
  • Information that is part of a formal dispute resolution process.
  • Information that is about another individual that would reveal their Personal Information or confidential commercial information.
  • Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Administrator at contact@ubiodiscovery.com

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users and third-parties. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Service https://ubiodiscovery.com/terms-of-service/

13.  Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. If you wish to choose to have your account consent withdrawn, you will be opting out of uBioDiscovery’s Services. Upon request, your account will be deleted. Once your account is deleted, it will no longer be accessible. This process cannot be cancelled or reversed. When your account is deleted, your Personal Information and contact information is deleted. Your de-identified data and any information shared with other users and third-parties may not be deleted. We may need to retain some information to comply with regulatory and legal obligations.

You may opt out of receiving email communications from us regarding promotions, in which case your email address and contact information will be removed from our email list.

14.  Children Under the Age Of 13

uBioDiscovery protects the privacy of both adults and children. Although uBioDiscovery’s Services are not designed for children under the age of 13, a parent or guardian may collect a stool sample, create an account for, and provide information related to, his or her child. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to uBioDiscovery about their child is kept secure and is accurate. If you are under the age of 13, do not use or provide any information on this Website or make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use, without permission from a parent or guardian.

15.  Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. We include the date the privacy policy was last revised 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 our Website and this privacy policy to check for any changes.

16.  Contact Information and Challenging Compliance

If you have any questions about this privacy policy and our privacy practices, please contact our Privacy Administrator through email or by mail. Please include your name and email address for us to identify your records, and either an address, email address, or phone number for where we can contact you.

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy, please contact our Privacy Administrator using the contact information listed below:

uBioDiscovery Inc.

2404-201 Sherbourne Street

Toronto, ON

M5A 3X2

contact@ubiodiscovery.com

 

17.  Last Updated

This Privacy Policy was last updated on December 1, 2019.

 

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