Privacy Policy

Spark No 9 (“Spark” or “We” or “we”) provides this privacy policy to apply to information collected when you visit our websites and any related websites or mobile applications (including without limitation, (www.ecoforgesolutions.com) (“Sites”) operated by Spark No 9, its subsidiaries, or affiliates (collectively “Spark”), or sign up through the Sites (such sign up provided via the Sites, the "Services"). We urge you to read the complete Privacy Policy set forth below, as well as our Terms of Service, and contact us if you have any questions.
 
By using our Services or interacting with us offline you agree to the terms of this Privacy Policy and the accompanying Terms of Service and consent to the collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree to all of these terms and conditions you may not use the Sites for any purpose.
 
Capitalized terms not defined in this Privacy Policy have the meaning ascribed to them in the Terms of Service.
 
If you are a Nevada Resident, California Resident, or a data subject in Europe, please see respectively the “Additional Disclosures for Nevada Residents,” “Additional Disclosures for California Residents,” and “Additional Disclosures for People in Europe” sections below. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.
 
I. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
 
We collect information about you when you visit the Sites, or use the Services, including information you provide when you sign up for our email subscription list or otherwise access our content, contact customer support or otherwise interact with us. The information that we have collected in the last twelve months includes the following: 
 
A. Information that you Provide and that is collected from other sources: You provide personally identifiable information, such as names, mailing addresses, e-mail addresses, telephone numbers, demographic information, and similar information in a variety of situations, including but not limited to the following: when you use the Services 
 
We also work with third parties (including, for example, business partners, third party contractors for technical services, ad networks, analytics providers, social networks such as Facebook, Twitter, TikTok, and Instagram, search information providers, credit reference agencies, and other third parties who enable sign on and other functionalities and social media integration) and may receive information about you from them. If you choose to use features on this Site that connect to your online profiles, accounts or services (including social media accounts) (“Connected Accounts”), we may collect any information that you permit through your settings on those Connected Accounts. If, for example, you elect to use Facebook Connect or similar logins to automatically populate certain information on our registration page or otherwise use features on our Site that connect to your online profiles, accounts, or services, (including social media accounts), you are authorizing Spark to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that Facebook or such other entities could provide to us through their application programming interface. You control the information that we receive from Facebook or other similar social media sites, and such information may include, without limitation, your first and last name, Facebook username, Facebook profile picture, unique Facebook identifier and access token, and e-mail address. Please review your Connected Account privacy settings to control what information is provided to us through this option.
 
B. Profile Data and Comments: We may collect information including your interests, inferences, preferences, and favorites. We collect information regarding any messages you send (such as feedback and interactions with customer support) or publicly post. You may also choose to voluntarily provide other information to us that we do not request and if you do you are solely responsible for that information. 
 
C. Information Collected Automatically: Certain data is automatically collected when you use the Services. These include the following:
 
1. Service Use Data: This includes data about features you use, pages you visit, emails and advertisements you view, Services you view and sign up for, the time of day you browse, and your opening and exiting pages.
Device Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
 
2. Geo-locational Information. Certain features and functionalities of the Services may be based on your location. In order to provide these features and functionalities while you are using a mobile device, we may automatically collect geo-locational information from your mobile device or wireless carrier and/or certain service providers. Collection of this information occurs only when the Services are running on your mobile device. You may decline to allow us to collect such information by adjusting your devices settings, in which case we will not be able to provide certain features or functionalities to you.
 
We use various tracking technologies to automatically collect information when you use access the Sites, purchase the Products or use the Services, including the following:
 
1. Cookies. Like most websites, our websites use automatic data collection technology when you visit our Sites to collect information that identifies your computer. This comprises information about your operating system, your IP addresses, browser type and language, referring pages and URLs, keywords, date and time, and what sections of the Sites you visit (the “usage information”). We collect this usage information by using cookies. Cookies are small packets of data that a website stores on your computer's hard drive. Some cookies are used so that your computer will “remember” information about your visit and your preferences. They help personalize your experience, support security features, and bring you advertising both on and off our Sites. Other cookies we use help you navigate our Sites and expire when you close your browser. We also use cookies (and the usage information collected) to help us identify you and analyze how you use the Sites and Services. You can reject cookies by following the directions provided by your browser vendor or by your Internet provider's “help” file. If you reject cookies, you may still use the Services, but may not be able to use some areas of the Sites and Services. 
 
2. Pixels. Pixels are also known as web beacons, code embedded in a website, video, email or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising both on and off the Services, and provide you additional functionality, such as the ability to connect our Services with your social media account.
 
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “How Can You Control Your Personal Information” sections below.
 
D. Analytics and Advertising
 
We use one or more analytics services (such as Google Analytics) to evaluate your use of the Services, compile reports on activity (based on our partners’ collection of IP addresses, internet service provider, browser type, operating system and language, referring and exist pages and URLs, date and time, amount of time spent on particular pages, what sections of the Sites you visit, number of links clicked while on the Sites, search terms and other similar usage information), and analyze performance metrics. These partners use cookies to collect this usage information. By accessing and using the Services, you consent to the processing of data about you by these other entities in the manner and for the purposes set forth in this Privacy Policy. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/
 
We also use behavior-based performance metrics such as landing page views, time on site, and email sign-up rate as an indicator of interest in or demand for a new product concept or repositioning of an existing product We share your usage information with technology services for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads). These technology services may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such usage information for such purposes. Pixel tags enable us, and these technology services, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. You may opt-out of the tailoring of advertising based on information we collect. We also use technology services (for example, Google Adwords) to advertise to users of our Services on websites owned or operated by other entities. This means that we advertise to previous visitors to the Sites who have not completed a task on the Sites, such as entering an email address to be notified about a new product launch. These technology services may include cookies to track your activities across time and services. We may use data we receive from these technology services to match multiple devices associated with the same identifier as devices belonging to the same user or household. Where we are able to make such a match, we may use this information to deliver targeted advertisements across multiple devices on behalf of ourselves or other entities (“Interest-based Advertising”). Any data collected by technology services will be used in accordance with this Privacy Policy and the privacy policy of such technology services. For more information on such technology services, including how to opt out from certain data collection, please see below.
 
We also use audience matching services to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases (“Matched Ads”). This is done by us incorporating a pixel from technology service into our own Service, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences. Some technology services may provide us with their own data, which is then uploaded into another technology service for matching common factors between those datasets. 
 
As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
 
Google provides tools to allow you to opt-out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
 
To opt out of us using your data for Matched Ads or other third-party sharing for advertising and/or marketing purposes, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt-out of matched ads. We will request that the applicable technology service not serve you matched ads based on information we provide to it.
 
You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).
 
For further information on the types of tracking technologies we use on the Services and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “How Can You Control Your Personal Information” sections.
 
II. WHAT DO WE DO WITH COLLECTED INFORMATION?
 
We use the personal information you provide for business and commercial purposes. Our business purposes for collecting and using information, including within the last 12 months, includes the following:
 
A. to fulfill your requests, and improve our Services and to operate our business; 
B. to send you promotional offers related to us or our clients, including providing your personal information to our clients so they may send you information and promotional offers directly;
C. to provide our Sites, Services and related support;
D. to perform services requested by you, such as respond to general inquiries, comments, questions, requests, and provide customer service;
E. to use behavior-based performance metrics such as landing page views, time on site, and email sign-up rate as an indicator of interest in or demand for a new product concept or repositioning of an existing product
F. to send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
G. to prevent and address fraud, breach of policies or terms, and threats or harm; 
H. to monitor and analyze trends, usage, and activities;
I. to conduct research, including focus groups and surveys;
J. to develop and provide you direct marketing and relevant content on our Sites, and as part of the Services, including advertisements regarding services of ours or other entities, and communications from us and from our business partners about our and other entities’ offers, promotions, rewards, events, and services; 
K. to communicate with you regarding our current and future Service offerings;
L. to send you advertising;
M. to comply with legal and regulatory requirements;
N. to fulfill any other business or commercial purposes at your direction or with your notice and/or consent.
 
In some cases, we collect Personal Information about you and your interests through our Sites as a service provider on behalf of a client business, who may either be named or un-named on the Site. In that case, we will provide your Personal Information to that client for their business uses and will not use it for our purposes (other than to provide the services to our client). The client may then communicate with you directly, including sending you information about offers and promotions. You may un-subscribe at any time as instructed in the communication.
 
We may combine information we receive from other sources with information you give to us and information we collect about you (including information in relation to your devices). We may use this combined information for the purposes set out above.
 
You may, at any time, opt out of receiving promotional offers from us or our business partners by mail or e-mail and you may opt out of other collection practices as specified below. You may also, at any time, opt out of receiving promotional offers from us or our business partners by SMS or text messaging by texting STOP in reply to the text that you received or using any other method of opting out of such messages that we or our business partners have notified you about. 
 
We also use collected information to evaluate and administer our Services, respond to any problems that may arise, such as difficulties in navigating our Sites or accessing certain features, as well as to gauge user trends to determine what Services are most popular with users, and to put you in touch with fulfillment partners who can provide services that we cannot. 
 
 
III. HOW DO WE SHARE PERSONAL INFORMATION?
 
We share information we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have shared information with in the last 12 months, include the following:
 
A. Sharing Within the Spark Corporate Family. We may share your personal information with any parent company, subsidiary, or affiliate in the Spark corporate family. All entities within the Spark corporate family may have access to your personal information as well as anonymous, aggregate demographic data.
 
B. Service Providers. Spark may share personal and non personal information with companies that work on behalf of or with Spark. These companies may use this information to assist Spark in serving its customers, , or devising effective marketing strategies to reach more consumers. Examples of these service providers are suppliers under contract with Spark, analytics, hosting and search engine providers. 
 
C. Corporate Customers and Business Partners. Spark may share personal and non personal information a client business, who may either be named or un-named on the Site. These companies may use this information for their own commercial purposes or for devising effective marketing strategies to reach more consumers. You may opt out of communications from these companies using the instructions below. 
 
 
D. Public Postings. You should be aware that if you voluntarily disclose information, personal or otherwise, online in any community area (whether through the Sites or any other service available online), that information can be collected and used by others. Accordingly, you should use caution when sharing any personal information with others in any community area (whether through the Sites or any other service available online).
 
E. Required Disclosures of Information. We reserve the right to use or disclose any information without notice or consent as needed to satisfy any law, regulation or legal request; to conduct investigations of consumer complaints or possible breaches of law; to protect the integrity of our Sites and our property and assure adherence to our terms of use; to protect the safety of our visitors or others; to fulfill your requests; or to cooperate in any legal investigation or process.
 
F. Changes in Corporate Structure. In developing our business, we might sell certain assets, or Spark, or parts of it, may be sold, merged or otherwise transferred. In such transactions, user information, whether personally identifiable or otherwise, may be one of the transferred assets.
 
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see “How Can You Control Your Personal Information” section below.
 
 
IV. Social Media Integrations.
We offer parts of our Services through websites, apps, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Services. Some examples include:
 
A. Links to External Sites. Our Sites may contain links to websites, platforms, and other services not operated or controlled by us. (“External Sites”). We have no control over the privacy practices of these External Sites. As such, we are not responsible for the privacy policies of those External Sites. You should check the applicable third party privacy policy and terms of use when visiting any External Sites, and before providing any personal information to such External Sites.
 
B. Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Services that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration and you should check the social network’s privacy policy and terms of use before providing any personal information to the social networks.
C. Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Services on social media (e.g., by using a hashtag associated with Spark in a tweet or post), we may use your reference on or in connection with our Services.
 
Please note that when you interact with other entities, including when you leave our Services, those entities may independently collect information about you and solicit information from you. The information collected and store by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
 
VI. HOW CAN YOU CONTROL YOUR PERSONAL INFORMATION?
 
We believe that choice in how and when you are contacted is key to customer satisfaction, so we offer several ways for you to update your contact information, change your preferences, or opt out of receiving future communications.
 
A. If you have an online account at our Sites, you may be able to log on and update or change your contact or account information. Check the Sites for further information.
 
B. You may unsubscribe from any of our online e-mail updates or newsletters by following the unsubscribe instructions in the body of any e-mail message. Similarly you may unsubscribe from any promotional or other text messages by following the unsubscribe instruction in the body of any text. Please be aware that some transactional emails and texts relating to your purchase of Products or Services may still be sent to you even if you unsubscribe. 
 
C. Analytics 
1. Google provides tools to allow you to opt-out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/. 
2. Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
 
3. Please be aware that if you disable or remove tracking technologies some parts of the Sites or Services may not function correctly.
 
4. You also may write to us directly if you wish to: (a) update or delete your contact information; (b) ask that we not share your personal information with third parties; or (c) request that we cease sending you promotional or other information via mail or e-mail. Such written requests should be sent to Spark hello@sparkno9.com. In those instances, we will retain your information in a “do not promote” file in our database, and you will receive no further communications from us.
 
5. You may also contact us as set out below for any inquiry or request regarding our privacy policy or the handling of your personal information.
 
If you have opted out of receiving future e-mails from us, we will implement your opt-out request within 10 business days of receiving the opt-out request. If you have opted out of receiving future promotional materials by regular mail, we will implement your opt-out request within a commercially reasonable time.
 
VII. SECURITY OF YOUR PERSONAL INFORMATION
 
All the information you provide may be processed and stored, transferred, or accessed by entities around the world as described in this policy. We will take steps to ensure that your data is treated securely and in accordance with this Privacy Policy. We have put in place technical and organizational procedures designed to safeguard the information we collected on this Site. We incorporate standard industry practices suitable to the degree of sensitivity of the information involved to maintain the security of your personal information and to avoid its disclosure except as described in this policy. Your personal information may also be protected by the password you created when you registered at one of our Sites where this feature is offered. The confidentiality of any password is yours to protect. You may change it anytime by following the instructions at the Site where you registered. Although we use reasonable and appropriate efforts to assure that your data remains secure when maintained by us, security during Internet transmissions or within any system cannot be assured. Spark employees are made aware of its privacy practices through periodic communications and training. Remember, however, that we cannot guarantee the security of your personal information, and we are not responsible for the privacy or security practices of any third party.
 
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. 
 
 
VIII. CHILDREN’S PRIVACY
 
The Service is intended for a general audience and is not directed at children under the age of 13. We do not knowingly gather personal information (as defined by the US Children’s Privacy and Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are under the age of 13, please do not give us any personal information. Most of our publications and Sites are intended for adults. If you are a parent or guardian and you have reason to believe that we have collected personal information from your child in a manner not permitted by law, please contact us at hello@spark.com and we will endeavor to delete that information from our databases to the extent required by applicable laws.
 
We do not knowingly “sell,” as that term is defined under the California Consumer Privacy Act, the personal information of minors under 16 years old who are California residents.
 
If you are a California resident under 18 years old and registered to use the Services, you can ask us to remove any content or information you have posted on the Services. To make a request, email us at the email address set out in “Contact Us” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable, good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
 
IX. Changes to This Privacy Policy
 
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any changes will be effective immediately upon posting of the revised Privacy Policy. By accessing or using our Services after any such changes to this Privacy Policy are posted, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis. If the changes are material, we may provide you additional notice to your email address.
 
X. How to Contact Us
 
If you have any questions about this Privacy Policy or our privacy practices, please e-mail us at hello@sparkno9.com. Please include the URL of the Site and/or name of the publication involved in your request. Requests under California Law SB 27 should be directed to hello@sparkno9.com and include the information noted in Additional Disclosures for California Residents.
 
Or you can contact us by mail at:
Spark No. 9 LLC, 420 W 14th Street, Suite 5SE, New York, NY 10014.
If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at hello@sparkno9.com.
 
XI. Additional Disclosures for Nevada Residents.

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at hello@sparkno9.com
 
XII. Additional Disclosures for California Residents.
 
California residents may have certain rights regarding the collection, use, disclosure, and sale of their personal data. As defined in the California Consumer Privacy Act, we engage in industry-standard advertising business practices that may be considered a sale. We do not knowingly sell personal data related to children under 16 years of age. Spark has sold personal data in the last 12 months in the following ways:
- By allowing advertising networks we partner with to place cookies or other tracking technologies through our sites;
- By sharing hashed or pseudonymized identifiers with advertising networks to create audiences for use in online advertising.
 
California residents may have the right to request:
- Disclosure of personal data we collect, use, disclose, and sell about you;
- Deletion of your personal data that we maintain;
- To opt out of the sale of your personal data.
 
How to Opt-Out and Other Privacy Choices
 
There are two categories of personal information Spark may have about you which are not connected:
 
1. Name, email or physical address, or other information that identifies you (“Profile Information”). To opt out of the sale of your Profile Information, designate an authorized representative, make a general privacy request, or for more information, Contact us at hello@sparkno9.com or as provided in this Privacy Policy.
 
2. Interactions with Spark Sites that use identifiers that cannot directly identify you (“Cookie Data”). To opt out of the sale of Cookie Data use the cookie consent tools available as described above in Section VI.


Spark may verify requests regarding Profile Information by confirming that you control the email address associated with your personal information. If necessary, and taking into account available technology, security and privacy concerns, and the burden on our business, we reserve the right to take additional steps or require additional information to verify your request.
 
You have the right not to receive discriminatory treatment for exercising your privacy rights.
 
Other California Privacy Rights
You may opt out of having your personally identifiable information shared with third parties for those third parties’ direct marketing purposes by contacting Spark at hello@sparkno9.com. 
 
Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. Spark currently does not take action in response to these signals. 
 
XIII. Additional Disclosures for Data Subjects in Europe.
 
Spark does not knowingly collect or retain information about Data Subject in Europe. 
 
A. Roles.
1. Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). 
2. Spark acts as a controller with respect to personal data collected as you interact with our Services.
 
B. Lawful Basis for Processing.
1. Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
 
C. Your Data Subject Rights
 
If you are a data subject in Europe, you may have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us. Please allow us a reasonable time to respond to your inquiries and requests. You may exercise your rights by sending an email to hello@sparkno9.com and we will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your requests. If we decline your request, we will tell you why, subject to legal restrictions.
 
D. Retention of Personal Data
 
We will retain your personal data in a form that identifies you to fulfill the purposes for which it was collected. We may continue to retain and use information even after a data subject request for purposes of our legitimate interests, such as journalism, literature and art, scientific or historical research, statistical analysis, compliance with our legal obligations, resolving disputes, preventing fraud, and enforcing our agreements.
 
E. Complaints.

If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us. To do so, please use the contact information located in the Contact Us section above.
 
Last Update April 18, 2024
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