AEGPay Privacy Policy
Last Update: 1 May 2025
1. INTRODUCTION
Thank you for selecting the relevant service(s) (the “Services”) and/or product(s) (the “Product”), which include but are not limited to AEGPay as outlined in the AEGPay Terms & Conditions, provided by ANGRY EVIL GLOBAL TECHNOLOGY LIMITED (a limited liability company registered in Hong Kong) (“AEGPay”) and its affiliates (hereafter referred to as “I,” “me,” “my,” “we,” “us,” “our,” or the “Company”). By accessing or using our Services/Products, you AGREE to the terms and practices detailed in this privacy policy (the “Privacy Policy”) and affirm that you have obtained the necessary consent and authority from the Relevant Person(s) (defined below) for us to collect, use, disclose, and/or process your Personal Data as specified. This Privacy Policy outlines how we will gather, use, and share your personal data when you access or use our Services/Products. You acknowledge that AEGPay may revise this Privacy Policy at any time by posting the updated version on our website and associated application program interface or mobile applications (the “Site”) or by sending the latest Privacy Policy to you via email. Your use or continued use of any Services/Products following such changes will be considered as your acceptance and agreement to the updates.
2. WHAT PERSONAL DATA WE COLLECT
We may occasionally collect, process, and store certain personally identifiable information that can be used to contact or identify you and your beneficial owners, directors, officers, authorized signatories, employees, representatives, guarantee/security providers, and other individuals associated with you (“Relevant Persons”) through your use of the Services/Products or when you provide consent (“Personal Data”). This Personal Data may include contact information, details and data generated during your relationship with us, information collected during events organized by us in which you or a Relevant Person participates, and data obtained from cookies or other information technology applications. The Personal Data you provide during the onboarding process may also include, but is not limited to:
We may use the collected Personal Data for the following purposes:
- To make decisions regarding the provision or ongoing provision of Services/Products to you.
- To administer, operate, deliver, enhance, and customize the Services/Products.
- To process your payments and transactions and to provide you with statements, invoices, receipts, and other related information regarding the Services/Products.
- To monitor and record the use of the Services/Products and communications with you and/or Relevant Persons (including for investigation and fraud prevention purposes).
- To identify, prevent, and resolve technical issues.
- For risk assessment and data analysis (including data processing, anti-money laundering, and credit assessments), internal management, and to conduct internal/external audits.
- To communicate with you, your affiliates, and/or your representatives regarding events, our Services/Products, and other offerings from AEGPay or its affiliates, unless you have opted out of receiving such information.
- To carry out market research, surveys, promotions, and contests, and to analyze your preferences, interests, and behaviors concerning the Services/Products.
- To comply with any applicable legal, regulatory, and compliance requirements (including anti-money laundering and tax obligations).
- To protect or defend the rights or property of AEGPay, its affiliates, and other users.
- To fulfill any other purposes communicated to you at the time the data was collected.
4. DO WE SHARE YOUR PERSONAL DATA
We may share your Personal Data with the following parties for the purposes mentioned above:
- Our third-party service providers who assist us in providing, operating, maintaining, securing, and enhancing the Services/Products (including but not limited to “Know Your Client” or other blockchain analytics services, credit card networks, banks, financial institutions, payment processors, merchants, loyalty program partners, and those offering website hosting, data analysis, information technology, mailing, telecommunications, human resources, data processing, payments, and credit referencing services).
- Any individual or entity within AEGPay and its affiliates that is bound by confidentiality to the disclosing party.
- Professional advisors of AEGPay and its affiliates.
- Any individual or entity that we collaborate with for marketing, advertising, or promoting our Services/Products, such as social media platforms, online platforms, or third-party websites.
- Any individual to whom we are required to disclose information in accordance with legal processes or any domestic or international legal, tax, or regulatory obligations.
- Any individual or entity you authorize or consent to receive your Personal Data, such as your representatives, agents, advisors, or beneficiaries.
- Any actual or potential assignee or business transferee of AEGPay and/or its affiliates.
We may also share aggregated or anonymized Personal Data with the aforementioned parties to facilitate the administration, operation, delivery, and enhancement of the Services/Products.
5. DO WE TRANSFER YOUR PERSONAL DATA
Your information, including Personal Data, may be transferred to and stored on computers located outside of your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your area. Please be aware that we may transfer and process your data, including Personal Data, outside of your jurisdiction. By consenting to this Privacy Policy and submitting your information, you agree to this transfer.
We will take reasonable steps to ensure that your Personal Data is handled securely and in accordance with this policy, and no transfer will occur to an organization or country unless sufficient controls are in place, including the security of your Personal Data and other personal information.
6. DO WE TRANSFER YOUR PERSONAL DATA
The Personal Data we collect from you may also be transferred to and stored in a location outside of your state, province, country, or jurisdiction. By providing your Personal Data, you consent to this transfer, storage, or processing. Information you provide may also be stored on our or third-party cloud servers.
7. HOW LONG DO WE RETAIN YOUR DATA
We will retain your Personal Data only as long as necessary for the purposes outlined in this Privacy Policy. We will keep and use your Personal Data as needed to fulfill our legal obligations, resolve disputes, and enforce our legal agreements and policies. By accessing or using our Services/Products, you consent to our retention of your Personal Data.
8. MARKETING COMMUNICATIONS
We may send you company news, promotions, and information about our products and services. We may share Personal Data with our affiliates to facilitate marketing communications. However, we will only send you such marketing communications if we have obtained your explicit consent through the appropriate channels in the Services/Products.
If you decide that you do not wish to receive these communications, please email support@aegpay.com with the subject line "MARKETING OPT OUT."
To ensure the quality of our Services/Products, you understand that you cannot opt out of receiving communications related to services or products, such as changes to terms and conditions, updates, and operational notifications.
9. COOKIE USAGE
While you are accessing the Site, we may use cookies, which are small data files saved by your browser. This information may be stored on your computer or other devices you use to visit the Site. Cookies help us recognize you as a customer, gather information on your use of our Services/Products, and improve your experience. We may also use the information collected to ensure compliance with our compliance program and to verify that your account security has not been compromised by identifying any irregular or suspicious activities.
Most browsers are set to accept cookies automatically. Some cookies expire when your session ends, while others may remain on your computer or devices until deleted or until they expire. You have the option to decline our use of cookies, but this may impact the functionality of the Services/Products or your overall user experience.
Some browsers include a "do not track" feature that allows you to indicate that you do not want your online activities tracked. Currently, we do not respond to browser "do not track" signals.
10. INFORMATION SECURITY
We strive to protect both ourselves and you from unauthorized access, alteration, disclosure, or destruction of the data we collect and store. We implement various measures to ensure information security, including encrypting our communications with SSL, requiring two-factor authentication for all sessions, regularly reviewing our Personal Data collection, storage, and processing practices, and limiting access to your Personal Data on a need-to-know basis.
While the security of your data is our priority, you acknowledge that no method of transmission over the Internet or electronic storage is completely secure. Although we aim to use commercially acceptable means to safeguard your Personal Data, we cannot guarantee its absolute security.
11. LINKS TO OTHER SITE
Our Site may include links to other websites not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of each site you visit, as we have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
12. MINOR POLICY
We do not provide Services/Products to anyone classified as a "minor" or equivalent under applicable law. We do not knowingly collect personally identifiable information from anyone regarded as a "minor." If you are a parent or guardian and are aware that your child (classified as a "minor") has provided us with Personal Data, please contact us, and we will take appropriate actions.
13.Your contact with other customers.
You understand that you are solely responsible for your interactions with other Users. We reserve the right, but are not obligated, to monitor disputes between you and other Users.
14. Contacting us about privacy questions or concerns
If you have any questions regarding this Privacy Policy or the use of your Personal Data, please reach out to us by sending an email to support@aegpay.com with the subject line "PRIVACY QUESTION.”
If you wish to find out what Personal Data we hold about you and would like it updated, corrected, or deleted from our systems, please email support@aegpay.com with the subject "DATA INQUIRY." We will make every effort to address your request as soon as possible, although we may deny your deletion request under certain circumstances, such as compliance with legal obligations.
If you want to withdraw your consent, please contact support@aegpay.com with the subject "DATA INQUIRY." If you or a Relevant Person withdraws consent or does not provide the necessary information required for us to deliver our Services/Products, we may be unable to provide or continue offering these Services/Products to you.
In response to requests for data access, correction, deletion, or data portability, we will verify the identity of the requesting party to ensure they are legally entitled to make such a request. While we aim to process these requests at no charge, we reserve the right to charge a reasonable fee, particularly if the request is repetitive or burdensome.
15. LANGUAGE
If this Agreement is translated into any language other than English, the English version will take precedence in case of any discrepancies.
16. SPECIFIC RIGHTS UNDER DIFFERENT JURISDICTIONS
A. Your Rights if Your Personal Data is Subject to the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), our legal basis for collecting and using the personal information outlined in this Privacy Policy depends on the type of Personal Data we collect and the specific context in which we collect it. We may process your Personal Data because:
- We need to use your Personal Data to enter into a contract with you or fulfill our obligations under that contract.
- You have granted us consent to do so.
- The processing is in our legitimate interests or necessary to meet our legal obligations.
- To comply with relevant laws and regulations.
As an EEA resident, you have certain data protection rights. We aim to take reasonable steps to enable you to correct, amend, delete, or limit the use of your Personal Data. Please refer to section 14 (Contacting Us About Privacy Questions or Concerns) above for more details.
In specific situations, you have the following data protection rights:
- The right to access, update, or delete the information we hold about you.
- The right to rectify your information if it is inaccurate or incomplete.
- The right to object to our processing of your Personal Data.
- The right to request a restriction on the processing of your personal information.
- The right to data portability, allowing you to obtain a copy of the information we have on you.
- The right to withdraw consent at any time if our processing relies on your consent.
B. Your Rights If You Are a Resident of California or Certain U.S. States
Under the laws of California, Colorado, Connecticut, Utah, and Virginia (collectively "Applicable States"), you may have the right to ask us to:
- Provide access to certain information we hold about you, potentially in a portable format if technically feasible.
- Update or correct your information.
- Delete specific information we hold about you.
- Opt in or opt out of the use of certain sensitive information we retain about you.
You may also have the right to designate an authorized agent to assist you in exercising these rights. For security purposes, we will generally ask you to verify your identity or that of your authorized agent using the contact information you have provided.
If you would like to exercise any of these rights or appeal a decision related to your rights, please refer to section 14 (Contacting Us About Privacy Questions or Concerns) above.
No sale of personal information: We do not sell any personal information to anyone.
No discrimination: We will not discriminate against anyone exercising their rights under the privacy laws of California or other Applicable States.
California: Below are the additional disclosures required by the California Consumer Privacy Act and the California Privacy Rights Act (collectively, "CCPA"), effective January 1, 2023.
Sensitive Personal Information. The categories of information that AEGPay collects and discloses for a business purpose include "sensitive personal information" as defined by the CCPA. AEGPay does not utilize or disclose sensitive personal information for any purpose that is not explicitly permitted by the CCPA.
1. INTRODUCTION
Thank you for selecting the relevant service(s) (the “Services”) and/or product(s) (the “Product”), which include but are not limited to AEGPay as outlined in the AEGPay Terms & Conditions, provided by ANGRY EVIL GLOBAL TECHNOLOGY LIMITED (a limited liability company registered in Hong Kong) (“AEGPay”) and its affiliates (hereafter referred to as “I,” “me,” “my,” “we,” “us,” “our,” or the “Company”). By accessing or using our Services/Products, you AGREE to the terms and practices detailed in this privacy policy (the “Privacy Policy”) and affirm that you have obtained the necessary consent and authority from the Relevant Person(s) (defined below) for us to collect, use, disclose, and/or process your Personal Data as specified. This Privacy Policy outlines how we will gather, use, and share your personal data when you access or use our Services/Products. You acknowledge that AEGPay may revise this Privacy Policy at any time by posting the updated version on our website and associated application program interface or mobile applications (the “Site”) or by sending the latest Privacy Policy to you via email. Your use or continued use of any Services/Products following such changes will be considered as your acceptance and agreement to the updates.
2. WHAT PERSONAL DATA WE COLLECT
We may occasionally collect, process, and store certain personally identifiable information that can be used to contact or identify you and your beneficial owners, directors, officers, authorized signatories, employees, representatives, guarantee/security providers, and other individuals associated with you (“Relevant Persons”) through your use of the Services/Products or when you provide consent (“Personal Data”). This Personal Data may include contact information, details and data generated during your relationship with us, information collected during events organized by us in which you or a Relevant Person participates, and data obtained from cookies or other information technology applications. The Personal Data you provide during the onboarding process may also include, but is not limited to:
- Full legal name (including former name, and names in English and Chinese, if applicable)
- Identification document type (e.g. Passport)
- Identification document number (e.g. Passport No.)
- Gender
- Date of birth
- Place of birth
- Nationality
- Residential address
- Country/state of residence
- Total net wealth (approximately in USD)
- Purpose of account opening
- Initial and ongoing sources of wealth or income
- Nature and details of the business/occupation/employment
- Level of activity anticipated
- Source of funds/digital assets to be used in the relationship
- Credit history and score
- Contact phone number
- Email address
- Your transaction history and spending pattern
- Bank account information
- Blockchain address
- Your location data
- Additional Personal Data or documentation at the discretion of our compliance team
We may use the collected Personal Data for the following purposes:
- To make decisions regarding the provision or ongoing provision of Services/Products to you.
- To administer, operate, deliver, enhance, and customize the Services/Products.
- To process your payments and transactions and to provide you with statements, invoices, receipts, and other related information regarding the Services/Products.
- To monitor and record the use of the Services/Products and communications with you and/or Relevant Persons (including for investigation and fraud prevention purposes).
- To identify, prevent, and resolve technical issues.
- For risk assessment and data analysis (including data processing, anti-money laundering, and credit assessments), internal management, and to conduct internal/external audits.
- To communicate with you, your affiliates, and/or your representatives regarding events, our Services/Products, and other offerings from AEGPay or its affiliates, unless you have opted out of receiving such information.
- To carry out market research, surveys, promotions, and contests, and to analyze your preferences, interests, and behaviors concerning the Services/Products.
- To comply with any applicable legal, regulatory, and compliance requirements (including anti-money laundering and tax obligations).
- To protect or defend the rights or property of AEGPay, its affiliates, and other users.
- To fulfill any other purposes communicated to you at the time the data was collected.
4. DO WE SHARE YOUR PERSONAL DATA
We may share your Personal Data with the following parties for the purposes mentioned above:
- Our third-party service providers who assist us in providing, operating, maintaining, securing, and enhancing the Services/Products (including but not limited to “Know Your Client” or other blockchain analytics services, credit card networks, banks, financial institutions, payment processors, merchants, loyalty program partners, and those offering website hosting, data analysis, information technology, mailing, telecommunications, human resources, data processing, payments, and credit referencing services).
- Any individual or entity within AEGPay and its affiliates that is bound by confidentiality to the disclosing party.
- Professional advisors of AEGPay and its affiliates.
- Any individual or entity that we collaborate with for marketing, advertising, or promoting our Services/Products, such as social media platforms, online platforms, or third-party websites.
- Any individual to whom we are required to disclose information in accordance with legal processes or any domestic or international legal, tax, or regulatory obligations.
- Any individual or entity you authorize or consent to receive your Personal Data, such as your representatives, agents, advisors, or beneficiaries.
- Any actual or potential assignee or business transferee of AEGPay and/or its affiliates.
We may also share aggregated or anonymized Personal Data with the aforementioned parties to facilitate the administration, operation, delivery, and enhancement of the Services/Products.
5. DO WE TRANSFER YOUR PERSONAL DATA
Your information, including Personal Data, may be transferred to and stored on computers located outside of your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your area. Please be aware that we may transfer and process your data, including Personal Data, outside of your jurisdiction. By consenting to this Privacy Policy and submitting your information, you agree to this transfer.
We will take reasonable steps to ensure that your Personal Data is handled securely and in accordance with this policy, and no transfer will occur to an organization or country unless sufficient controls are in place, including the security of your Personal Data and other personal information.
6. DO WE TRANSFER YOUR PERSONAL DATA
The Personal Data we collect from you may also be transferred to and stored in a location outside of your state, province, country, or jurisdiction. By providing your Personal Data, you consent to this transfer, storage, or processing. Information you provide may also be stored on our or third-party cloud servers.
7. HOW LONG DO WE RETAIN YOUR DATA
We will retain your Personal Data only as long as necessary for the purposes outlined in this Privacy Policy. We will keep and use your Personal Data as needed to fulfill our legal obligations, resolve disputes, and enforce our legal agreements and policies. By accessing or using our Services/Products, you consent to our retention of your Personal Data.
8. MARKETING COMMUNICATIONS
We may send you company news, promotions, and information about our products and services. We may share Personal Data with our affiliates to facilitate marketing communications. However, we will only send you such marketing communications if we have obtained your explicit consent through the appropriate channels in the Services/Products.
If you decide that you do not wish to receive these communications, please email support@aegpay.com with the subject line "MARKETING OPT OUT."
To ensure the quality of our Services/Products, you understand that you cannot opt out of receiving communications related to services or products, such as changes to terms and conditions, updates, and operational notifications.
9. COOKIE USAGE
While you are accessing the Site, we may use cookies, which are small data files saved by your browser. This information may be stored on your computer or other devices you use to visit the Site. Cookies help us recognize you as a customer, gather information on your use of our Services/Products, and improve your experience. We may also use the information collected to ensure compliance with our compliance program and to verify that your account security has not been compromised by identifying any irregular or suspicious activities.
Most browsers are set to accept cookies automatically. Some cookies expire when your session ends, while others may remain on your computer or devices until deleted or until they expire. You have the option to decline our use of cookies, but this may impact the functionality of the Services/Products or your overall user experience.
Some browsers include a "do not track" feature that allows you to indicate that you do not want your online activities tracked. Currently, we do not respond to browser "do not track" signals.
10. INFORMATION SECURITY
We strive to protect both ourselves and you from unauthorized access, alteration, disclosure, or destruction of the data we collect and store. We implement various measures to ensure information security, including encrypting our communications with SSL, requiring two-factor authentication for all sessions, regularly reviewing our Personal Data collection, storage, and processing practices, and limiting access to your Personal Data on a need-to-know basis.
While the security of your data is our priority, you acknowledge that no method of transmission over the Internet or electronic storage is completely secure. Although we aim to use commercially acceptable means to safeguard your Personal Data, we cannot guarantee its absolute security.
11. LINKS TO OTHER SITE
Our Site may include links to other websites not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of each site you visit, as we have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
12. MINOR POLICY
We do not provide Services/Products to anyone classified as a "minor" or equivalent under applicable law. We do not knowingly collect personally identifiable information from anyone regarded as a "minor." If you are a parent or guardian and are aware that your child (classified as a "minor") has provided us with Personal Data, please contact us, and we will take appropriate actions.
13.Your contact with other customers.
You understand that you are solely responsible for your interactions with other Users. We reserve the right, but are not obligated, to monitor disputes between you and other Users.
14. Contacting us about privacy questions or concerns
If you have any questions regarding this Privacy Policy or the use of your Personal Data, please reach out to us by sending an email to support@aegpay.com with the subject line "PRIVACY QUESTION.”
If you wish to find out what Personal Data we hold about you and would like it updated, corrected, or deleted from our systems, please email support@aegpay.com with the subject "DATA INQUIRY." We will make every effort to address your request as soon as possible, although we may deny your deletion request under certain circumstances, such as compliance with legal obligations.
If you want to withdraw your consent, please contact support@aegpay.com with the subject "DATA INQUIRY." If you or a Relevant Person withdraws consent or does not provide the necessary information required for us to deliver our Services/Products, we may be unable to provide or continue offering these Services/Products to you.
In response to requests for data access, correction, deletion, or data portability, we will verify the identity of the requesting party to ensure they are legally entitled to make such a request. While we aim to process these requests at no charge, we reserve the right to charge a reasonable fee, particularly if the request is repetitive or burdensome.
15. LANGUAGE
If this Agreement is translated into any language other than English, the English version will take precedence in case of any discrepancies.
16. SPECIFIC RIGHTS UNDER DIFFERENT JURISDICTIONS
A. Your Rights if Your Personal Data is Subject to the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), our legal basis for collecting and using the personal information outlined in this Privacy Policy depends on the type of Personal Data we collect and the specific context in which we collect it. We may process your Personal Data because:
- We need to use your Personal Data to enter into a contract with you or fulfill our obligations under that contract.
- You have granted us consent to do so.
- The processing is in our legitimate interests or necessary to meet our legal obligations.
- To comply with relevant laws and regulations.
As an EEA resident, you have certain data protection rights. We aim to take reasonable steps to enable you to correct, amend, delete, or limit the use of your Personal Data. Please refer to section 14 (Contacting Us About Privacy Questions or Concerns) above for more details.
In specific situations, you have the following data protection rights:
- The right to access, update, or delete the information we hold about you.
- The right to rectify your information if it is inaccurate or incomplete.
- The right to object to our processing of your Personal Data.
- The right to request a restriction on the processing of your personal information.
- The right to data portability, allowing you to obtain a copy of the information we have on you.
- The right to withdraw consent at any time if our processing relies on your consent.
B. Your Rights If You Are a Resident of California or Certain U.S. States
Under the laws of California, Colorado, Connecticut, Utah, and Virginia (collectively "Applicable States"), you may have the right to ask us to:
- Provide access to certain information we hold about you, potentially in a portable format if technically feasible.
- Update or correct your information.
- Delete specific information we hold about you.
- Opt in or opt out of the use of certain sensitive information we retain about you.
You may also have the right to designate an authorized agent to assist you in exercising these rights. For security purposes, we will generally ask you to verify your identity or that of your authorized agent using the contact information you have provided.
If you would like to exercise any of these rights or appeal a decision related to your rights, please refer to section 14 (Contacting Us About Privacy Questions or Concerns) above.
No sale of personal information: We do not sell any personal information to anyone.
No discrimination: We will not discriminate against anyone exercising their rights under the privacy laws of California or other Applicable States.
California: Below are the additional disclosures required by the California Consumer Privacy Act and the California Privacy Rights Act (collectively, "CCPA"), effective January 1, 2023.
- Categories of Personal Information Collected. The personal information we may collect, or have collected from consumers in the past twelve months, falls into the following categories defined by the CCPA, based on your interactions with us:
- - Identifiers, such as your name, email address, physical address, phone numbers, or IP address.
- - Personal information as outlined in subdivision (e) of Section 1798.80 of the California Civil Code, such as a credit card number.
- - Characteristics of protected classifications under California or U.S. federal law, such as age or gender, particularly if we conduct user surveys or analyses.
- - Commercial information, including details of purchase activity.
- - Internet or other electronic network activity information, which includes interaction data such as content downloads, streams, and playback information.
- - Geolocation information, such as the location of your device or computer based on your IP address or the GPS of your mobile device, depending on your device settings.
- - Audio, visual, electronic, or similar information, particularly when you communicate with us via phone or other means.
- - Professional or employment-related information, for example, details you may provide about your business.
- - Inference data, which includes insights into your preferences.
- Categories of Personal Information Disclosed for a Business Purpose. The personal information we may have disclosed about consumers for a business purpose in the past twelve months falls into the following categories defined by the CCPA, based on your interactions with us:
- Identifiers, including your name, email address, physical address, phone numbers, or IP address;
- Personal information as defined in subdivision (e) of Section 1798.80 of the California Civil Code, such as a credit card number;
- Characteristics of protected classifications under California or U.S. federal law, such as age or gender, especially if we conduct user surveys or analyses;
- Commercial information, including details of your purchasing activity;
- Internet or other electronic network activity information, which encompasses content interaction details like downloads, streams, and playback information;
- Geolocation information, indicating the location of your device or computer, for instance, if you enable location services to improve your experience with our applications;
- Audio, visual, electronic, or similar information, particularly when you communicate with us by phone or other means;
- Professional or employment-related information, such as details you may share about your business;
- Inference data, which includes insights into your preferences.
Sensitive Personal Information. The categories of information that AEGPay collects and discloses for a business purpose include "sensitive personal information" as defined by the CCPA. AEGPay does not utilize or disclose sensitive personal information for any purpose that is not explicitly permitted by the CCPA.
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