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Sweet Bandits Studios INC
Privacy Notice

This page hosts the Sweet Bandits Studios Privacy Notice, last updated February 21st, 2023.  If you wish to contact us with a specific data subject request, the exact method is listed in the relevant section below. If you have any questions or concerns about this Privacy Notice, please contact us by sending an email to: privacy@sweetbanditsstudios.com, or as described in the “Contact Us” section below.

1. Introduction

Sweet Bandits Studios, Inc. (“Sweet Bandits Studios”, “We” or “Us”) is a Canadian video game developer based in Québec, Canada. Our headquarters are located at :
Sweet Bandits Studios, Inc.  

247 St-Vallier Est, Suite 310

Québec, QC

G1K 3P4

Canada
 

This Sweet Bandits Studios Privacy Notice (“Privacy Notice”) describes how Sweet Bandits Studios collects, uses, shares, and retains personal data that you provide to us, or that We collect, when you use any Sweet Bandits Studios game We create or license.

Please read this Privacy Notice carefully. If you disagree with anything in this Privacy Notice you must not provide personal data for anything through the website or use Sweet Bandits Studios’ games or services. By using or continuing to use the website or any of our games or services, you are accepting the terms, conditions and directions set forth in this Privacy Notice, as described below.

2. Data Sweet Bandits Studios Collects

2.1 General Description

The specific data Sweet Bandits Studios collects, stores and processes depends on which products you use and how you use them. We collect personal data and non-personal user data and will disclose in this Privacy Notice the circumstances under which Sweet Bandits Studios collects either personal data or non-personal data.

 

For purposes of this Privacy Notice, Sweet Bandits Studios adopts the definition of personal data set forth in the General Data Protection Regulation (EU) 2016/679 (“GDPR”) at Article 4(1) which broadly defines personal data as “any information relating to an identified or identifiable natural person” and includes identifiers such as a name, online identifiers such as an IP address, and email addresses. This is not an exhaustive list, but a few examples aimed at helping you understand what constitutes personal data.

 

Non-personal user data is data that should not identify a person or to allow Sweet Bandits Studios to contact a specific person. Some examples of non-personal data are information about the number of users that visit Sweet Bandits Studios’s website and the pages of the website which are visited, as well as usage data as to certain features of Sweet Bandits Studios games that are not connected to any particular user. These are examples and not an exhaustive list of all types of non-personal data.

 

If you are from the United States, you may be accustomed to the term “personally identifiable information” or “PII” to describe personal data. For purposes of this Privacy Notice, personally identifiable information is personal data as defined in Article 4(1) of the GDPR except as specified under Children.

 

Where this Privacy Notice describes processing personal data, Sweet Bandits Studios adopts the definition of “processing” set forth under Article 4(2) of the GDPR: “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”

 

2.2 Games Data Collection

Sweet Bandits Studios strives to create the best gaming experience possible. To provide an enhanced and personalized gaming experience that minimizes the interruption of bugs and service errors, prohibits and investigates fraudulent activity, and helps us determine how we can improve our games, we automatically process a range of personal data described below.

 

For all the personal data processing activities described in sections 2.2.1-2.2.5, Sweet Bandits Studios is the data controller as defined by Article 4(7) of the GDPR. This means Sweet Bandits Studios determines the purposes and means of the processing of the personal data. We do not delete the data we collect described in subsections 2.2.1-2.2.3 unless the law governing your personal data provides you with a right to deletion and you request to delete this data.

 

2.2.1 In-Game Analytic Data

We process your proprietary platform identification (such as your Steam ID, Epic Games ID, PSN online ID and/or Gamertag) and your in-game data to allow us to analyze gameplay across the board and improve our games based on how the game is actually being played. In-game analytic data is information that includes, but is not limited to, maps played, characters played, weapons used, results of matches, heatmap information on where players died/were killed from in-game and current level achieved. Sweet Bandits Studios partners with several third parties detailed below to maintain these analytics data, including:

  • Amazon Web Services (“AWS”)

  • dynamoDB

  • Accelbyte

  • Backtrace

  • Gamesight

 

2.2.2 Achievements, Player Stats

We also process your Steam ID, Epic Games ID, PSN online ID and/or Gamertag along with your Achievements/Trophies and statistics related to the level of play you achieved in a particular session and over time, weapons used, characters defeated, and various details relevant to the particular game you are playing. This data allows us to provide you with a seamless gaming experience where you can begin each game session on the highest level previously achieved and access your personal dashboard of game accomplishments and statistics from within the game.

 

2.2.3 Inventory of Gifts & In-Game Purchases

Your Steam ID, Epic Games ID, PSN online ID and/or Gamertag is also processed in conjunction with any in-game purchases, gifts or other game inventory you may have obtained so that there is a permanent record of your inventory acquired in the game that you can access. Sweet Bandits Studios partners with several third parties detailed below to maintain these inventory data, including:

  • Amazon Web Services (“AWS”)

  • Epic Games Store

  • Valve Corporation (Steam)

  • Microsoft

  • Sony

  • Accelbyte

 

2.2.4 Surveys

Sweet Bandits Studios occasionally creates surveys administered by Google. These surveys are placed onto the main menu of your game. You are invited to participate in the survey but your participation is entirely voluntary. If you elect to participate in a survey, we collect, record and store your email address because we use your email address to confirm that you are a real person and not a bot or some other type of spam actor. When the time period for the survey has ended, the link to the survey will be removed from the main menu of your game. Once the survey is closed to further participation, all email addresses are deleted, so that we can begin analysis of the survey.

 

2.2.5 Prevent Cheating

Sweet Bandits Studios is committed to keeping our games fair and prohibiting cheating. We partner with third party Easy Anti-Cheat to identify and ban cheaters. Easy Anti-Cheat’s data processing practices are described in more detail in 3.1 Easy Anti-Cheat.

 

2.2.6 Crashes, Bugs & Service Errors

To identify, diagnose, and correct bugs and service errors we partner with Backtrace to log crashes and provide us with diagnostic information. If your game crashes it will request whether you want to send a crash report. If you choose to send the error report, Backtrace will collect, record, store and use your GPU and CPU information, the language you have selected, and your installation folder, so that we can process that data to analyze why the service error occurred. All the data collected is fully anonymized.

3. Data Third Parties Collect

We partner with several third parties to provide our games and services to you. These third parties and their role in processing your personal data are described in detail below.

 

3.1 Easy Anti-Cheat

Sweet Bandits Studios partners with Easy Anti-Cheat to identify cheaters and ban them from our games and services. Easy Anti-Cheat must process your Username and account identifier, in-game analytic data and achievement statistics, technical information about the hardware used to play the Game, such as motherboard manufacturer, CPU identifier, GPU identifier, and general performance indicators, technical information about the methods, technics, technologies or alike used in our games that may be suspected to indicate the use of methods that are considered unacceptable by Sweet Bandits Studios, and/or other equivalent information. Easy Anti-Cheat processes this data as part of its anti-cheating technology that helps keep our games free from cheaters and fraudulent activity. Easy Anti-Cheat cannot delete the personal data and non-personal data it collects in order to prevent any future or further cheating or fraudulent activity. For more information about Easy Anti-Cheat’s data processing activities, go to: https://www.epicgames.com/site/en-US/privacypolicy.

 

3.2 Platform Partners: Steam, Epic Games, Sony & Microsoft

Our games are available on platforms developed by Valve Corporation (Steam), Epic Games Store, Sony (PlayStation), and Microsoft (Xbox) (collectively, “Platform Partners”). Sweet Bandits Studios’s Platform Partners process your Steam ID, Epic Games ID, PSN online ID and/or Gamertag to keep track of your Achievements/Trophies and statistics related to the level of play you achieved in a particular session and over time (as described above), and maintain a record of your in-game inventory purchases or gifts (as described above).

 

3.3 Accelbyte

In-Game inventory data for items purchased, won or gifted are maintained in the Accelbyte service. Accelbyte processes your Steam ID, Epic Games ID, PSN online ID and/or Gamertag to maintain a record of your in-game inventory purchases or gifts (as described above).

 

3.4 Backtrace

As described above, Backtrace helps us analyze crashes, bugs, and other interruptions of service that may occur on our games. If you experience a service interruption while playing one of our games, you will receive a notice from Unreal Engine that asks whether you would like to send a crash report. Backtrace provides us with diagnostic information about service interruptions which we analyze to understand why the service interruption occurred and attempt to avoid similar crashes in the future.

 

3.5 Gamesight

We work with Gamesight, https://console.gamesight.io/, to collect information about players’ game purchase activity and in-game DLC purchases in order to measure the impact of our marketing campaigns on player engagement. Gamesight obtains this information based on the use of a Measurement API. The data stored by the API includes information such as hashed IP address, API version, anonymized User ID, timestamp, Developer API Key, OS version, screen resolution, time zone, system language, and in-game events. To opt out of tracking provided via Gamesight, please follow the steps laid out at https://console.gamesight.io/optout. For more information about the privacy policy of Gamesight, please visit https://console.gamesight.io/privacy-policy. 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 ad partner statements regarding their opt out options or programs.

 

3.6 Tripwire Interactive LLC

As the publisher of Sweet Bandits and Deceive Inc., Tripwire Interactive LLC has access to all materials that Sweet Bandits Studios collects such as player data and game data. For a full understanding of Tripwire Interactive's privacy policy, please visit https://www.tripwireinteractive.com/#/privacy-notice

4. Data Processing & Storage

Personal data processed by Sweet Bandits Studios is processed and stored by Sweet Bandits Studios in Canada. Sweet Bandits Studios uses reasonable physical, technical and administrative measures to safeguard all personal data it processes and prevent unauthorized access and disclosure of any personal data. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any personal information that we process. You acknowledge that Sweet Bandits Studios processes your personal data at your own risk.

5. Dispute Resolution

We take your privacy concerns seriously. If you believe that Sweet Bandits Studios has not adhered to this Privacy Policy, please contact us by sending an email to: Privacy@sweetbanditsstudios.com with the subject line: Privacy Concern. In your email, please describe in as much detail as possible the ways in which you believe that this Privacy Notice has not been complied with. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

6. Data Disclosure

6.1 Requests from Law Enforcement & National Security Issues

Sweet Bandits Studios may disclose information we have about you (i) if we are required to do so by law or pursuant to legal process, (ii) in response to a request from law enforcement authorities or other government officials, including to meet national security requirements, or (iii) when we believe disclosure is reasonably necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or illegal activity.

 

6.2 Service Providers

As noted throughout this Privacy Notice, Sweet Bandits Studios may employ others to facilitate the website and related business functions (“Service Providers”), provide services on our behalf, perform service-related business activities, or assist us in analyzing how the website is used. These Service Providers provide us support services such as credit card processing, website hosting, email and postal delivery, analytics, marketing services, security and fraud prevention. The Service Providers have access to your personal information only to perform these tasks on Sweet Bandits Studios’s behalf and are obligated not to disclose or use it for any other purpose. The Service Providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

 

6.3 Corporate Transactions

We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our website users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your personal information.

7. Children

Sweet Bandits Studios adheres to the Children’s Online Privacy Protection Act (“COPPA”) and does not knowingly collect personal data from children under the age of 16.

8. Notice to California Residents

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that Sweet Bandits Studios collects, the reason we collect the Personal Information, where we obtain the Personal Information, and the third parties with whom we may share the Personal Information.

We generally collect the following categories of Personal Information about you when you use the website, our games or services:

 

  • identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with platforms;

  • commercial information such as records of products or services purchased, obtained, or considered by you;

  • Internet or other electronic information regarding your browsing history, search history, the web page visited before you came to the website, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;

  • inferences about your preferences, characteristics, behavior and attitudes.

We generally do not collect the following categories of Personal Information about you:

  • protected classifications, such as gender;

  • your geolocation;

  • audio recordings of your;

  • education-related information; 

  • and biometric information.

For more information about the Personal Information we collect, how we collect it and details of which data, under different circumstances, please refer to sections 2 and 3 above.

We collect your Personal Information for the business purposes described in sections 2 and 3 above, including for analytics, to support your use of our forums, to provide you requested marketing materials or customer support, to store cookies, and to ensure the integrity of the website and related services. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.

The categories of third parties with whom we may share your Personal Information are listed in sections 2, 3 and 6 above, and include our website, marketing, analytics, and security service providers, and law enforcement authorities when required to do so.

Privacy Rights

If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems. To assert your right to know or your right to delete your Personal Information, please contact us according to the “Contact Us” section below. To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.

Right to Know. You have the right to request in writing: (i) a list of the categories of Personal Information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of Personal Information we have collected about you, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.

Right to Delete. You have the right to request us delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.

Right to Opt-Out of Sales. The CCPA broadly defines “personal information” and “selling” such that sharing identifiers and identifiers linked to you for a benefit may be considered a sale. You have the right to opt-out of having your Personal Information sold. We do not sell your Personal Information.

 

Under California Civil Code Section 1798.83 (also known as the “Shine the Light” law), Sweet Bandits Studios customers who are residents of California may request certain information about Sweet Bandits Studios disclosure of personal data during the prior calendar year to third parties. If you are a California resident and wish to make this request, please send an email to Privacy@sweetbanditsstudios.com with California Shine the Light in the subject line. You may also request this information by mail at: Sweet Bandits Studios ATTN: Privacy Management, Sweet Bandits Studios,

9. Notice to EEA Residents

9.1 General Description

For purposes of this Privacy Notice we define the EEA to include any EU member state, the European Economic Area (“EEA”), the United Kingdom, or Switzerland. EEA Residents includes any data subject located in the EEA at the time of personal data collection. EEA Residents have certain rights concerning the processing of their personal data under the GDPR.

This portion of our Privacy Notice advises EEA Residents of the applicable GDPR rights (often called “data subject rights”), and how to effectuate these rights by communicating with us.

If you are not an EEA Resident, this section of the Privacy Notice does not apply to you.

 

9.2 Legal Basis for Processing Personal Data

Sweet Bandits Studios has a legitimate interest in providing its users with a state of the art gaming experience and to allow users to participate on our forums & blogs, enter contests, complete surveys and other voluntary pursuits at the specific direction and choice of the user, without risk of fraudulent activity and with a minimum of service interruptions caused by bugs or other system failures. In providing our website, games and other services to our users we aim to collect the minimum amount of personal data necessary to achieve these goals.

The lawful basis for processing an EEA Resident’s personal data is the legitimate interests grounds described under Article 6(f) of the GDPR.

 

9.3 Right of Access

EEA Residents have the right to obtain from Sweet Bandits Studios the confirmation as to whether or not personal data concerning him or her are being processed. EEA residents may request access to the following information:

  • the purposes of the processing;

  • the categories of personal data concerned;

  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing discussed in sections 9.4 through 9.6 of this Privacy Notice;

  • the existence of the right to lodge a complaint with a supervisory authority;

  • where the personal data are not collected from the data subject, any available information as to their source;

  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

  • information as to whether the personal data of an EEA resident is transferred to a third country or to an international organization and where this is the case, the EEA resident shall have the right to be informed of the appropriate safeguards relating to the transfer.

 

This Privacy Notice advises you as to the details of the personal data Sweet Bandits Studios is processing. If you need additional confirmation concerning the personal data Sweet Bandits Studios is processing you may request confirmation by sending an email to Privacy@sweetbanditsstudios.com with Right of Access in the subject line. The right to access is described under Article 15 of the GDPR.

 

9.4 Right to Rectification

EEA Residents have the right to request that Sweet Bandits Studios correct or “rectify” any inaccurate personal data concerning him or her. If an EEA Resident believes Sweet Bandits Studios has inaccurate or incomplete personal data, he or she may request rectification by sending an email to Privacy@sweetabdnitsstudios.com with Right To Rectification in the subject line. Sweet Bandits Studios will ensure any inaccurate or incomplete data is corrected within thirty (30) days of receiving your email request. The right to rectification is described under Article 16 of the GDPR.

 

9.5 Right to Erasure (Right to be Forgotten)

EEA Residents have the right to request that Sweet Bandits Studios delete personal data concerning him or her without undue delay. Sweet Bandits Studios will erase personal data under the following circumstances:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

  • The EEA Resident objects to the processing pursuant to Article 21(1) of the GDPR described below, and there are no overriding legitimate grounds for the processing, or the EEA Resident objects to processing personal data for direct marketing purposes which the EEA Resident can terminate by following the instruction described here.

  • The personal data have been unlawfully processed.

The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

 

If one of the aforementioned circumstances applies, and an EEA Resident wishes to request the erasure of personal data stored by Sweet Bandits Studios, he or she may request erasure/deletion by sending an email to Privacy@sweetbanditsstudios.com with Right To Be Forgotten in the subject line. Sweet Bandits Studios will comply with the erasure/deletion request within thirty (30) days of receiving your email request. The right to erasure is described under Article 17 of the GDPR.

 

9.6 Right of Restriction of Processing

EEA Residents have the right to restrict Sweet Bandits Studios’ processing of personal data if one of the following circumstances applies:

  • the accuracy of the personal data is contested by EEA Resident, for a period enabling the controller to verify the accuracy of the personal data;

  • the processing is unlawful and the EEA Resident opposes the erasure of the personal data and requests the restriction of their use instead;

  • Sweet Bandits Studios no longer needs the personal data for the purposes of the processing, but the EEA Resident needs the personal data for the establishment, exercise or defense of legal claims;

  • the EEA Resident has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

 

Where processing has been restricted because the accuracy of the personal data is contested by the EEA Resident, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

 

Sweet Bandits Studios will inform any EEA resident who has obtained restriction of processing because the accuracy of the personal data is contested by the EEA resident before the restriction of processing is lifted.

 

The right to restriction of processing is described under Article 18 of the GDPR.

 

9.7 Right to Object

EEA Residents have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on Sweet Bandits Studios’s legitimate interest grounds for lawful data processing under Article 6(1)(f) of the GDPR and described throughout section 2 of this Privacy Notice. If you are an EEA Resident and object to the processing of your personal data, please notify us by sending an email to Privacy@sweetbanditsstudios.com with Right to Object to Processing in the subject line and Sweet Bandits Studios will no longer process the personal data if we cannot demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims. The right to object is described under Article 21 of the GDPR.

 

9.8 Right to Data Portability

The right to data portability is available when the data processing activity is based on consent under Article 6(1)(a) or Article 9(2)(a) or when the data processing is necessary for the performance of a contract under Article 6(1)(b). There are not any data processing activities that occur based on any of these circumstances, so EEA Residents have no right to data portability when accessing or using any of our games, websites or other services. The right to data portability is described under Article 20 of the GDPR.

 

9.9 Right to Lodge a Complaint with a Supervisory Authority

If you believe that Sweet Bandits Studios processing of personal data infringes the GDPR, please contact us by sending an email to: Privacy@sweetbanditsstudios.com with the subject line: EEA Privacy Concern so that we can address your concerns. As described in Section 5, EEA Residents are entitled to lodge a complaint via JAMS at https://www.jamsadr.com/contact or by visiting the website at https://www.jamsadr.com/eu-us-privacy-shield. In addition, as an EEA Resident you have the right to lodge a complaint with the relevant data protection authority where you live or work, or in the place where the alleged breach of data protection law has taken place if you believe our processing of personal data infringes the GDPR. The right to lodge a complaint is described under Article 77 of the GDPR.

10. Changes to this Privacy Notice

From time to time Sweet Bandits  Studios may need to modify this Privacy Notice to reflect changes in our business practices, data collection practices or processing activities. We reserve the right to amend this Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on our websites and games. It is strongly recommended to check our websites often, referring to the date of the last modification listed at the top. If we change the Privacy Notice in material way that adversely impacts your privacy rights, we will post a notice on our website and may send you an email notifying you of the change, if you have provided your email address to us. If you do not agree to the changes made in any amended Privacy Notice, you should discontinue your use of our website, service and games, and stop providing personal data to us prior to the time the modified Privacy Notice takes effect. If you continue using our website, services or games and provide personal data to us after the modified Privacy Notice takes effect, you will be bound by the modified Privacy Notice.

11. Contact Us

We welcome your questions and comments about Sweet Bandits Studios’s privacy practices. You may contact us anytime via our website located at http://sweetbanditsstudios.com by email at Privacy@sweetbanditsstudios.com, or as follows:

 

Sweet Bandits Studios, Inc.  

247 St-Vallier Est, Suite 310

Québec, QC

G1K 3P4

Canada

Attn: Privacy Policy

 

Last Modified: February 21st, 2023

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