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KURASI

Privacy Policy

Kurasi (“KU”, “Us” or “We”) respects your privacy and strives to protect it in a lawful, ethical and transparent manner through the practices described in this notice (“Privacy Notice”).
KURASI has only one website for all these worldwide activities. Therefor depending on you location, the supplemental notice applicable to EEA/UK, the US or to Canada may apply to you.
This Privacy Notice applies to our practices for collecting, processing, storing, protecting and disclosing the personal data we may collect from you or that you may provide when you visit our website, including when you contact us through the ‘Contact’ page of this website (our “Website”), regardless of how the Website is accessed.
This Privacy Notice applies to the personal data collected through and processed in the context of our Website, regardless of the country where you are located and the applicable law that applies there (“Applicable Law”). For certain countries, specific information applies which we have set out in a supplemental notice which you can find below (“Supplemental Notice”).
If you provide us with the personal data of other individuals, you guarantee that the data subject was informed of this Privacy Notice, and that insofar as certain processing requires the consent of the data subject, you have obtained the relevant consent from the data subject for this processing by KU.
This Website may use cookies and/or other similar technologies. More information on this processing can be found in our Cookie Notice https://www.kurasi.com.sg/cookie-policy
Please consider this document together with this Privacy Notice.
By engaging with our Website, you acknowledge to have read this Privacy Notice. This notice may change from time to time (see Section 8 “Changes to our Privacy Notice”).

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1. Data we may process about you
Unless otherwise defined under the Applicable Law, the terms “personal data” and “personal information” used in this Privacy Notice describe information that can be used to identify or reasonably link to an individual, such as full name, mailing address, email address, business contact information, and IP address, or other identifying computer/browser information. Data that has been anonymized, and therefore can no longer be used to identify an individual, is not considered personal data by KU.
If you use this Website, we collect and use different types of personal data from and about you (“Website User” or “data subject”). Below we outline which categories and types of personal data we collect and use in this context:

  • Information the Website User enters voluntarily on this Website, e.g. through contact forms, registration for updates and occasional questionnaires/surveys, which may include:

    • contact information (full name, email address, phone number)

    • company name and description of company activities and consumption behaviour (i.e. type of services sought) (if personal data)

    • order number

    • other personal data entered into an open field of a contact form and/or survey

 

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.

 

  • Details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, though, 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), methods used to browse away from the page, or any phone number used to call our customer service number.



2. How we collect personal data about you
We use different methods to collect personal data from and about you including through:

  • Direct interactions. You may give us information about you by filling in the contact form on this Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you track a package, sign-up for our newsletter, perform a search, participate in use of social media functions, answer a survey on our Website.

 

  • Automated technologies or indirect interactions. As you interact with our Website, we may automatically collect and use technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies and other similar technologies (see our Cookies Notice https://www.kurasi.com.sg/cookie-policy for more information).

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3. How we use your personal data
KU may collect and use your personal data in the context of our Website to present our Website and provide you with information, products, services, and to deliver support that you request from us. In particular, we process personal data to:

  • provide you with requested information, process your questions and/or answer your queries.

  • help us design, personalise and deliver better services to our clients and to guide you to the solutions best suited to your needs and to make suggestions and recommendations to you about our products and services.

  • provide you with updates, newsletters and information about our Website, products and/or services via email if you sign-up for such communication.

  • gauge customer satisfaction and experience, and ultimately improve the quality of our services through (occasional) surveys and to enable your participation in our Website's interactive, social media or other similar features.

  • enforce our Terms of Use or this Privacy Notice, and establish, exercise and defend our rights, including in legal proceedings.

  • comply with court orders, law enforcement requests, regulator inquiries, or other legal requirements.

  • ensure that we present our Website content in the most effective manner for you and for your computer.

  • administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.

  • measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.

  • protect our Website, affiliates, employees, or operations.

  • prepare for and effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets,

KU may also process personal data from Website Users to fulfil the purposes for which you provided the data or that were described when it was collected.


4. Disclosure of your personal data
KU shares your personal data only for the fulfilment of one or more of the purposes set out above. In that context, we may share your personal data with:

  • third party service providers, including IT service providers, sub-contractors and suppliers, used to provide or support the Website, products and/or services. If necessary, to carry out their task, your personal data may also be transferred to these third-party service providers. In that case, they process your personal data solely in accordance with the instructions of KU and in line with the Applicable Law.

  • members of the KURASI group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.

  • a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.

  • regulatory authorities, government authorities, law enforcement, or courts in order to comply with any court order, law, or legal process, including responding to any government or regulatory request, or to establish, exercise or defend our rights.

  • other companies and organizations for the purposes of cybersecurity and fraud protection, and to protect the rights, property, or safety of our business, our employees, our customers, or others in accordance with Applicable Law.

KU will not share your personal information with external third-parties for their marketing purposes without your consent.
KU requires that all information is handled in accordance with Applicable Law.

5. Accessing and correcting your personal data
You can access, review, correct and change your personal data, by emailing privacy@kurasi.co.id.
If you wish to opt-out of marketing-based communication, please email privacy@kurasi.co.id, or select ‘Unsubscribe’ on a relevant email.
More rights may be available to you depending on the Applicable Law. For more information, please consult the relevant Supplemental Notice for your jurisdiction below to see whether additional rights apply.


6. External links and third-party data collection
The Website may include links to external 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.
Please note that these third parties have their own privacy policies and we encourage you to read them. We do not control these third-party websites or services and we do not accept any responsibility or liability for their policies or processing activities.


7. Data Security
The security of your personal data is very important to KU. We use physical, electronic, and administrative safeguards designed to protect your personal data. We encrypt your data to keep your data safe during transmission across public networks. Unfortunately, no data transmission or storage system is 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Information” section below.
In addition, we urge you to take care when providing personal data through social media channels as other social media users may be able to view this information.
If you have questions about the security of your personal information, please contact privacy@kurasi.co.id.

8. Changes to the Privacy notice
The Privacy Notice is regularly reviewed and updated with changes and improvements when necessary. Please check the notice periodically for updates, as your continued engagement with our Website after any such revisions indicates that you acknowledge and accept them.

9. Contact Information
Please address questions, comments, and requests regarding this Privacy Notice and our privacy practices to:
privacy@kurasi.co.id

10. SUPPLEMENTAL NOTICE TO EEA and UK DATA SUBJECTS Scope of the Supplemental Notice
Controller responsible for the processing of personal data
This Supplemental Notice applies if you are a data subject in the European Economic Area (the European Union, Iceland, Liechtenstein, and Norway) (“EEA”) or the UK or otherwise subject to the EU General Data Protection Regulation (“ EU GDPR”) or the UK General Data Protection Regulation (“UK GDPR”).
The data controller is: PT. Kurasi Indonesia Jaya
Registered office: Jl. Tanjung Duren Raya No.90, Jakarta Barat, Jakarta, Indonesia 11470
E-mail: privacy@kurasi.co.id

Representative for the processing of personal data - EU
The data controller is: Kurasi Pte Ltd
Registered office: Jl. Tanjung Duren Raya No.90, Jakarta Barat, Jakarta, Indonesia 11470
E-mail: privacy@kurasi.co.id

Representative for the processing of personal data - UK
The data controller is: Kurasi Pte Ltd
Registered office: Jl. Tanjung Duren Raya No.90, Jakarta Barat, Jakarta, Indonesia 11470
E-mail: privacy@kurasi.co.id

Contact information
If you have any questions or concerns about our Privacy Notice or you wish to exercise any of your rights related to your personal data (as described in more detail below), please contact us by email privacy@kurasi.co.id.

Purpose(s) and legal basis for processing
The processing of personal data for the purposed described above (see Section 3 “How we use your personal data”) is necessary:

  • for purposes we consider to be in our legitimate interests, which may include the following interests: improving the Website and our products and services, maintaining a good business relationship and providing adequate answers to queries, ensuring that our customers are kept up-to-date with information about our services and helping us understand your interests, concluding and/or performing the agreement we have with your company or organisation, preparing and effecting corporate transactions (e.g. merger, reorganisation), enforcing and defending our legal rights, personalize our interactions with you, and develop our business relationship, as this helps us to preserve our business operations or grow our business.

 

  • to comply with a legal obligation to which KU is subject, such as to detect and prevent illegal uses, abuse, spam, fraud, security incidents and other harmful activity or to comply with government or court orders.


In other instances or where we are required by law to obtain your consent before processing such information, we will rely upon your consent as our basis for processing. In addition, if we use your information for purposes other than those mentioned above we will notify you of these purposes before using your information and obtain your consent (where necessary).


Retention of personal information


The principle that we apply is that your personal information will be deleted when that information is no longer necessary for the purpose for which it was collected.
The personal data we have collected through cookies and similar technologies are not retained for more than 1 year without renewing our notice, and, if required, obtaining your consent.
The storage period for other personal data will depend on: (i) the period of time required for the purposes for which it was collected; (ii) any compatible and lawful purposes subsequently established; (iii) any new purposes to which you subsequently consent; and/or (iv) compliance with legal and regulatory requirements, including statutory retention terms and prescription periods under Applicable Law.


Your rights as an EEA/UK data subject


In addition to the rights mentioned in Section 5 (“Accessing and correcting your personal data”), you have the following rights with respect to your personal data if the relevant conditions of the EU GDPR or the UK GDPR are fulfilled:

  • request access to and be provided with information relating to our processing of your personal data;

  • request rectification of your personal data if such personal data proves inaccurate or incomplete;

  • request, on legitimate grounds, your personal data to be erased provided we are not under a legal obligation to keep these;

  • request, on legitimate grounds, the restriction of our processing of your personal data

  • object to the processing of your personal information for direct marketing purposes or to any processing which we carry out based on our legitimate interest;

  • withdraw your consent at any time where our processing of your personal data is based on consent;

  • receive personal data which you provided to us in a structured, commonly used and machine-readable format and to transmit those to another controller (provided these are processed based on your consent);

  • obtain a copy upon request at privacy@kurasi.co.id of the appropriate or suitable safeguards for international data transfers.

 

Although we urge you to contact us first to find a solution for any concern that you might have, you always have the right to lodge a complaint with your competent data protection authority (i.e. the authority of your place of habitual residence, place of work or place of alleged infringement (within an EEA-country or the UK).
If you have questions about your data protection rights, or if you would like to exercise one or more, please email privacy@kurasi.co.id.

 


Data transfers outside the EEA / UK


We currently do not transfer your personal data within the meaning of the EU GDPR or the UK GDPR to any location outside of the EEA and the UK. We may, however, collect and process personal data that you disclose directly to us on your own initiative in locations outside the EEA and the UK.
If this changes in the future, we will ensure that your personal data is only transferred to parties that apply an appropriate level of data protection (e.g. where the European Commission / UK government has issued an adequacy decision or by including the so-called EU / UK standard contractual clauses in the agreement with the recipient and subject to an appropriate data transfer impact assessment).


Requirements to provide personal information


Unless otherwise indicated, the provision of personal data to KU is not a statutory or contractual requirement and you are not obliged to provide your personal data to us. If you decide not to provide your personal data, we might, in some instances, not be able to provide you with all features of the Website or a product or service. Completion of any forms or surveys is entirely voluntary, although you may be required to submit certain personal data to KU to allow us to adequately handle your inquiries or requests.

Children and minors’ information
The Website is not directed at or marketed to children. KU does not knowingly process personal data from children under the age of 16 (“Children”). If you are a parent or guardian and you are aware that your child has provided us with personal information without your consent or believe we mistakenly or unintentionally processed your Childs’ personal data, please contact us at privacy@kurasi.co.id and we will take steps to remove that information from our servers.


11. SUPPLEMENTAL NOTICE TO DATA SUBJECTS IN THE USA
This Supplemental Notice applies if you are accessing our Website from within the USA. If you are a California or Nevada resident, you may have additional rights as explained below.

 

Children’s Personal Information
This Website is not intended for children. We do not knowingly collect personal information from children under 13. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us at privacy@kurasi.co.id. You can also write to us at the address listed above. Please mark your inquiries “COPPA Information Request.”

 

Do Not Track Requests
Some web browsers or smartphones have the ability to send “Do Not Track” requests or signals to block user activity from being tracked across web pages or devices. Our Website does not recognize “Do Not Track” browser signals.

 

Additional Information for Nevada Residents
KU does not sell personal information, as these terms are defined under Nevada law. Nevada residents may contact us regarding our privacy practices under Nevada law by emailing privacy@kurasi.co.id.


Additional Information for California Residents
In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

 

1. Categories of Personal Information Under the CCPA (Last Updated: August 2, 2022)


While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about California residents in the prior 12 months (from the Last Updated data above).

Categories and Sources of Personal Information Collected. The table below identifies, generally, the categories of personal information (as defined by the CCPA), we have collected about California residents. For more information about the business or commercial purposes for which we collect and use personal information, please see the Use of Information section above. Below we outline which categories and types of personal data we collect and use in this context:

  • Information the Website User enters voluntarily on this Website, e.g. through contact forms, registration for updates and occasional questionnaires/surveys, which may include:

    • contact information (full name, email address, phone number)

    • company name and description of company activities and consumption behaviour (i.e. type of services sought) (if personal data)

    • order number

    • other personal data entered into an open field of a contact form and/or survey

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.

  • Details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, though, 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), methods used to browse away from the page, or any phone number used to call our customer service number.

 

Sources of Personal Information. We may collect personal information from the following sources:

  • directly from the user

  • Automated technologies or indirect interactions

Disclosures of Personal Information. There will be no disclosure of any kind.
 

2. California Residents’ Rights


CCPA Rights. In general, California residents have the following rights with respect to their personal information:

  • Do-not-sell (opt-out): we do not sell any data.

  • Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.

  • Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):

    • categories of personal information collected;

    • categories of sources of personal information;

    • categories of personal information about them we have disclosed for a business purpose or sold;

    • categories of third parties to whom we have sold or disclosed for a business purpose their personal information;

    • the business or commercial purposes for collecting or selling personal information; and

    • a copy of the specific pieces of personal information we have collected about them.

  • Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

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Submitting CCPA Requests. California residents may submit CCPA requests including, requests to know (access) and requests to delete their personal information through one of the following methods:

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When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide us with personal information sufficient for us to verify your identity, including your name, email address, phone number. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.


Authorized Agents. Authorized agents may initiate a request on behalf of another individual. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Businesses operating as an authorized agent on behalf of a California resident must provide the following:

  1. Certificate of good standing with its state of organization; and

  2. A written authorization document, signed by the California resident, containing the California resident’s name, address, telephone number, and valid email address, and expressly authorizing the business to act on behalf of the California resident.

Individuals operating as an authorized agent on behalf of a California resident must provide the following:

  1. A notarized power of attorney signed and dated by the California resident naming the authorized agent as the California resident’s representative; or

  2. A written authorization document, signed by the California resident, containing the California resident’s name, address, telephone number, and valid email address, and expressly authorizing the individual to act on behalf of the California resident.

 

Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at privacy@kurasi.co.id, and include in your request a current California address and your attestation that you are a California resident.

12. SUPPLEMENTAL NOTICE TO DATA SUBJECTS IN CANADA
Scope of the Supplemental Notice

This Supplemental Notice applies if you reside in Canada or are otherwise subject to the Personal Information Protection and Electronic Documents Act (Canada) S.C. 2000 c.5 (“PIPEDA”) or any equivalent provincial legislation, including the Personal Information Protection Act (British Columbia) S.B.C. 2003 c. 63 (“BC PIPA”), or the Personal Information Protection Act (Alberta) S.A. 2003. C. P-6.5 (“AB PIPA”) or the Act respecting the protection of personal information in the private sector (Quebec) CQLR c. P-39.1 (“Quebec Privacy Act”).
 

Contact Us
KURASI’s Privacy Officer is responsible for our compliance with applicable privacy laws and this Privacy Notice. The Privacy Officer may be contacted as follows:
The data controller is: PT Kurasi Indonesia Jaya
Registered office: Jl. Tanjung Duren Raya No.90, Jakarta Barat, Jakarta, Indonesia 11470
E-mail: privacy@kurasi.co.id

If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws. Our Privacy Officer will provide you with the contact information to do so if requested. We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.

 

Legal Basis for Processing Your Personal Information
Consent
We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request. Your consent can also be provided by your authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed. By using our Website or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Privacy Notice and as may be further identified when the personal information is collected. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.
If you are a resident of the province of Quebec, we will always seek your express consent to the collection, use, and communication of your personal information, except when specifically allowed by applicable law. For example, we may, in certain cases, use or communicate your personal information, without your consent for purposes of fraud prevention or to provide a service requested by you. You may, in certain circumstances, be asked to confirm your consent in a separate document. When we process your personal information for a new purpose, we will, when required by applicable law, document that new purpose and ask for your consent again.
If you do not consent to the processing of your personal information in accordance with this Privacy Notice, please do not access or continue to use the Website or otherwise provide any personal information to us.
You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences through the Website, (ii) deleting your account with the Website and stopping use of the Website, (iii) opting out of the use of your personal information by contacting our Privacy Officer. However, if you refuse, withdraw or change your consent, we may not be able to provide you with the Website or other associated goods or services where it is impossible for us to do so without processing your personal information.


Means by which your Personal Information is Collected
The means by which your personal information will be collected are described in Section Error! Reference source not found. (“How we collect personal data about you”) of our General Website Privacy Notice.

 

Purposes for which your Personal Information is Used
The purposes for which your information is collected and used are those described in Section 3 (“How we use your personal data”) of our General Website Privacy Notice.

 

Communication of your Personal Information
Your personal information may be communicated to the categories of third party service providers and business partners for the purposes identified in Section 4. (“Disclosure of your personal data”) of our General Website Privacy Notice.


Information Sharing and Disclosure outside of your jurisdiction of residence
Because we operate globally, your personal information may be processed, used or stored in jurisdictions other than your jurisdiction of residence. This includes any jurisdiction where we or our affiliates have facilities or in which we engage service providers. As a result, when your personal information is processed, used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
When we transfer your personal information outside your jurisdiction of residence, we will use all reasonable safeguards, including contractual requirements with our service providers, to ensure the adequate protection of your personal information.

 

Limits on Collecting, Using, and Disclosing Your Personal Information
We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.
We will only collect, use or disclose your personal information as described in this Privacy Notice and for the purposes set out above or as permitted or required by law.

 

Retention of Your Personal Information
We generally keep personal information for only as long as it is needed to accomplish the purposes for which it was collected, or as needed for authorized or legitimate purposes. More specifically, we retain personal information as long as necessary for the fulfilment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws or protect our interests. When personal information is no longer necessary or relevant for the identified purposes, or is required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to personal information.

 

Your Rights - Quebec Residents
In addition to the rights mentioned in Section 5 (“Accessing and correcting your personal data”) of our General Website Privacy Notice, if you are a resident of the province of Quebec or otherwise subject to the Quebec Privacy Act, you may, under certain circumstances prescribed by applicable law, have the following rights with respect to your personal information:

  • request access to your personal information;

  • request rectification or correction of your personal information;

  • withdraw your consent to the communication or use of the personal information collected;

  • request, under certain circumstances, that we cease disclosure of or deindex your personal information, provided we are not under a legal obligation to keep it; and

  • receive a copy of the personal information which you provided to us in a structured, commonly used technological format and to transmit such personal information to another person or organization which you may designate.


If you have questions about any of your rights relating to personal information, or if you would like to exercise one of your rights, please contact our Privacy Officer at privacy@kurasi.co.id. Reasonable fees may be charged for any copy, transcription, or communication of personal information: when such fees are applicable, you will be notified in advance.

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