PT Wireless, Inc. for Primary Academic and Secondary Schools Privacy Statement

Last updated: March 2023

PT Wireless, Inc is committed to continually improving how we communicate our privacy practices. This “Primary Academic and Secondary Schools Privacy Statement” explains how we handle personal information of Student Users (as defined below) of Primary Academic and Secondary Schools Accounts (as defined below) who are under the age of 18 years. It also reflects PT Wireless, Inc.’s compliance with the applicable requirements of the Children’s Online Privacy Protection Act (“COPPA”), the California Consumer Privacy Act (“CCPA”), the Family Educational Rights and Privacy Act (“FERPA”), the California Student Online Personal Information Protection Act (“SOPIPA”), the EU’s General Data Protection Regulation (“GDPR”), and other applicable laws.

For purposes of this Primary Academic and Secondary Schools Privacy Statement, personal information (or “personal data”) means information that relates to an identified or identifiable individual.

Certain Primary Academic and Secondary Schools Accounts may be created under contracts between PT Wireless, Inc. and the School Academic Subscriber that include a data processing addendum or other specific provisions governing Student User personal information. To the extent there is any conflict between such contracts and the terms of this Primary Academic and Secondary Schools Privacy Statement, the terms of our contracts with School Academic Subscriber s will control.

Definitions

Primary Academic and Secondary Schools Accounts

School Academic Subscribers can use PT Wireless, Inc.’s communications platform by establishing Primary Academic and Secondary Schools Accounts for their Primary Academic and Secondary Schools Account Users. Primary Academic and Secondary Schools Account Users can create Primary Academic and Secondary Schools Accounts as authorized representatives of a School Academic Subscriber but should only use PT Wireless, Inc.'s Services with the permission of their school, school district or school system (the School Academic Subscriber ).

Parties’ Roles

School Academic Subscriber

The School Academic Subscriber is the Primary Academic and Secondary Schools Account Owner. For purposes of FERPA, each Primary Academic and Secondary Schools Account User is a “school official” of the School Academic Subscriber . The School Academic Subscriber is the decision-maker that determines how personal information is processed in connection with PT Wireless, Inc.’s provisions of Services under a Primary Academic and Secondary Schools Account. The School Academic Subscriber decides if and why to host a PT Wireless, Inc. meeting, and what features to use. For example, depending on how the School Academic Subscriber has configured its Primary Academic and Secondary Schools Account, a Primary Academic and Secondary Schools Account User may record a meeting. Therefore, the School Academic Subscriber is responsible for obtaining any necessary consent from meeting participants Both Parents and Teachers.

When a Parent and Teacher Users uses PT Wireless, Inc.’s Services through a School Academic Subscriber , the processing of Student User personal information by the applicable School Academic Subscriber is determined and administered by the School Academic Subscriber under its privacy policies. If a parent or legal guardian of a Student User has questions about how and why Student User personal information is collected, the legal basis for processing, or access requests, the parent or legal guardian should refer to the School Academic Subscriber ’s privacy policies and direct all inquiries to the Primary Academic and Secondary Schools Account Administrator or Primary Academic and Secondary Schools Account User.

PT Wireless, Inc.

PT Wireless, Inc. provides a communications platform to Primary Academic and Secondary Schools Account Users on behalf of and at the direction of the School Academic Subscriber . For purposes of FERPA, PT Wireless, Inc. is considered a “school official” and may receive Student User personal information through its contractual agreements because PT Wireless, Inc. is performing a service that furthers a “legitimate educational interest” (i.e., the provision of educational services in a remote setting). PT Wireless, Inc. maintains Student User personal information on behalf of, and at the direction of, the School Academic Subscriber and does not use the Student User personal information for other purposes except as permitted by applicable law, including FERPA and applicable agreements with School Academic Subscriber s. PT Wireless, Inc. is responsible for following the directions of the School Academic Subscriber . For example, on a School Academic Subscriber ’s instructions, PT Wireless, Inc. may provide reports containing personal information relating to the Primary Academic and Secondary Schools Account and its users (including ONLY Parents and Teachers Users) to that School Academic Subscriber.

Information We Collect

From the Primary Academic and Secondary Schools Account User

When creating a Primary Academic and Secondary Schools Account under the direction of a School Academic Subscriber , the Primary Academic and Secondary Schools Account User must provide certain information, such as:

For Adding on Child & Children Information

Depending on how the School Academic Subscriber configures its Primary Academic and Secondary Schools Account, PT Wireless, Inc. may receive personal information contained in “Customer Content.” Customer Content is any data a Primary Academic and Secondary Schools Account User uploads to the PT Wireless, Inc. communication platform connected with use of the Service.

For example, School Academic Subscriber may enable features that allow meeting hosts or co-hosts to record meetings locally or to PT Wireless, Inc.’s cloud, allow Primary Academic and Secondary Schools Account Users to display or upload information that may be seen by other users of that Primary Academic and Secondary Schools Account, allow meeting participants to share files, allow hosts or co-hosts to create meeting transcripts, or allow meeting participants (including Student Users) to communicate in-meeting via chat and create chat logs.

Such Customer Content may include personal information that is part of an “educational record” as defined by FERPA.

PT Wireless, Inc. accesses Customer Content only upon the documented request of a School Academic Subscriber , or if required by law.

Automatically

PT Wireless, Inc. collects certain personal information automatically through the use of a Primary Academic and Secondary Schools Account including:

Use of Personal Information

PT Wireless, Inc. uses personal information collected from and about Parent and Teacher Users only as needed to deliver the functionality of the PT Wireless, Inc. platform, operate the business (including to enhance or improve the PT Wireless, Inc. Services), and as directed by School Academic Subscriber s. For Parent and Teacher Users, this means that:

Regarding cookies, PT Wireless, Inc. publishes two types of webpages: product and marketing. A product webpage enables a Student User to click on a hyperlink and join a PT Wireless, Inc. meeting. PT Wireless, Inc.’s product webpages serve only third-party cookies that are necessary for technical support and to deliver the service. There are no advertising or analytics cookies on our product webpages.

Marketing webpages, such as www.parentteachermobile.com, are designed to encourage sales of PT Wireless, Inc. subscriptions. They are directed at a general audience over the age of 18 with a child and or children in a School.

Sharing Personal Information

We do not share personal information with companies, organizations, or individuals outside of PT Wireless, Inc. unless one of the following circumstances applies:

We will share personal information with companies, organizations, or individuals outside of PT Wireless, Inc. when we have Primary Academic and Secondary Schools Account User consent (as applicable) and in compliance with applicable laws (including FERPA as applicable).

School Academic Subscriber s have access to personal information (including Student User information) connected with their Primary Academic and Secondary Schools Account(s). School Academic Subscriber s may also direct us to share personal information with others.

We provide personal information to third-party service providers to help us provide the Service. Such service providers are prohibited from using personal information for any reason other than to provide the contracted-for services, and in compliance with appropriate privacy and security obligations.

We may share personal information collected during a PT Wireless, Inc. meeting with other participants of the same meeting during the use of the Service. For example, video and audio recordings, chat messages and other content shared by a either Parent and Teacher User during a meeting, which may contain personal information of Student Users, may be available to all other participants in that meeting, as well as to any Primary Academic and Secondary Schools Account Users who host or co-host that meeting and the Primary Academic and Secondary Schools Account Administrator.

We may share personal information where, whether for strategic or other business reasons, PT Wireless, Inc. decides to sell, buy, merge, or otherwise reorganize its businesses. In such transactions, we may disclose or transfer personal information to actual purchasers or receive personal information from sellers. User personal information will remain subject to this Primary Academic and Secondary Schools Privacy Statement unless it is changed by a successor entity.

We share personal information outside of PT Wireless, Inc. if we believe that access, use, preservation or disclosure of the information is reasonably necessary to:

For more information about data we disclose in response to requests from law enforcement and other government agencies, please see our Guidelines for Government Requests.

Third Parties

PT Wireless, Inc. does not share personal information with third parties other than as described herein, or as required by law, except at the direction and on behalf of a School Academic Subscriber.

Security

Maintaining the confidentiality, security, and integrity of students’ personal information is a top priority. We use appropriate technical and organizational measures designed to help protect personal information from unauthorized access, use, or disclosure. Customer Content is encrypted in transit between any devices running a PT Wireless, Inc. client and at rest when in permanent storage in the PT Wireless, Inc. Cloud. We also have taken steps to minimize the risk that meetings that include Student Users are disrupted by uninvited participants. Examples include enabling meeting passcodes and virtual waiting rooms by default for Primary Academic and Secondary Schools Accounts and configuring default screen share settings to limit in-meeting content sharing.

Report a User

All Primary Academic and Secondary Schools Accounts have the ability to Report a User feature enabled by default. The Report a User feature is available to the meeting host or co-host via the Security icon on the meeting taskbar. If an unwelcome participant joins the meeting, the host or co-host can select Report a User, which automatically takes a screenshot of the reported user(s) and their shared content (if any) and creates a report. The feature then sends the report to PT Wireless, Inc.’s Trust & Safety team. A member of the Trust & Safety team will review the report and investigate the reported user(s) for violation of our Terms of Service. Confirmed offending users will have their accounts terminated, and, where appropriate, we will notify relevant law enforcement authorities.

Data Retention

PT Wireless, Inc. retains Primary Academic and Secondary Schools Account Users’ and Student Users’ personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

Access and deletion of information

If Academic Primary or Secondary Schools Subscriber, Parent or Teacher Student User would like to request to access, review, refuse further collection of or delete a Student User’s personal information, they must contact their School Academic Subscriber with his or her request. Because PT Wireless, Inc. is required to comply with contractual confidentiality obligations related to Student Users’ data, we are not able to respond to parental or student requests directly. School Academic Subscriber s may direct requests to access, delete or restrict further collection or use of a Student User’s personal information to support@parentteachermobile.com PT Wireless, Inc. also deletes information associated with Primary Academic and Secondary Schools Accounts upon receiving a valid deletion request from a School Academic Subscriber or automatically following the termination of the Primary Academic and Secondary Schools Account. Primary Academic and Secondary Schools Account Users can delete their content Primary Academic and Secondary Schools Account Users may access or request deletion of their personal information in the same manner as set forth in our Privacy Statement.

Additional Rights of California and European Users

If you are a resident of the State of California or the European Users, please refer to our Privacy Statement and our California Privacy Rights Statement for additional information on the rights that you may have and how you can exercise those rights.

Interpretation of Conflicting Terms

This Primary Academic and Secondary Schools Privacy Statement provides summary information about our collection and use of personal information from related to Primary Academic and Secondary Schools Accounts. It is consistent with the Privacy Statement, which provides additional examples and explanations that may be useful. Where terms differ, as with the limitations on advertising in Primary Academic and Secondary Schools Accounts, this Primary Academic and Secondary Schools Privacy Statement takes precedence.

Notice of Changes to this Statement

If we make any material changes to this Primary Academic and Secondary Schools Privacy Statement, we will post the revised statement with the date of revision on this page and provide notice of this change on our website. We will duly inform Primary Academic and Secondary Schools Account Users of any material changes via our platform. We will provide our School Academic Subscriber the opportunity to express consent for processing personal information for different and new purposes, or we will, in any case, provide the legal basis of such processing other than consent.

European Data Protection Specific Information

Data Subjects Rights

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

To exercise your rights, please email support@parentteachermobile.com . If you have any other questions about our use of your personal data, please send a request and contact details to support@parentteachermobile.com . Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data. You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when PT Wireless, Inc. processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

International Data Transfers

PT Wireless, Inc. operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where PT Wireless, Inc. or its service providers have customers or facilities – including in countries where meeting participants or account owners hosting meetings or webinars that you participate in or receiving messages that you send are based.

Therefore, by using PT Wireless, Inc. products and services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.

We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. Please contact us if you would like further information in that respect.

California Notice at Collection

Categories of Personal Information PT Wireless, Inc. Receives: PT Wireless, Inc. may collect, or process on behalf of our customers, the following categories of personal data, (such as in Account Information, Profile and Participant Information, Contact Information, and Registration Information), financial account information (such as in Account Information); commercial information (such as in Account Information); internet or other electronic network activity information (such as Device Information, Usage Information Regarding Meetings, Webinars, Message, Collaborative Features, and the Website, and Limited Information from PT Wireless, Inc. Email and Calendar Services); audio, electronic, and visual information (such as in Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features) education information such as from university customers; inferences we derive from the preceding or other information we collect; and sensitive personal information (such as certain categories in Account Information, Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features.

Sources: We receive information from sources, including: from you (including through your use of our products and services); from partners; from customers; and from publicly available sources. We collect education information from schools that use our services.

PT Wireless, Inc.’s business and commercial purposes for use: PT Wireless, Inc. uses personal data for the following business and commercial purposes: to provide PT Wireless, Inc. Products and Services; for Product Research and Development; for Marketing and Promotions (PT Wireless, Inc. does not use meeting, webinar, or messaging content, or any content generated or shared as part of other collaborative features for any marketing or promotions); Authentication, Integrity, Security, and Safety; to Communicate with You; and for Legal Reasons.

PT Wireless, Inc. may permit advertising and analytics services that are intended to deliver advertising to you and/or analyze your interactions, based on your interactions with our website or app, which may constitute a “sale” or “sharing” of data under California law. See “California & Other U.S. State Privacy Rights” for more information regarding your right to opt-out.

Retention: PT Wireless, Inc. retains personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law. Additional detail on retention criteria can be found under Retention, above.

California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:

Sensitive Information. PT Wireless, Inc. receives information that may be considered sensitive under some state laws, such as certain Account Information (e.g., financial information, log-in information) , certain Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features and certain Limited Information from PT Wireless, Inc. Email and Calendar Services (e.g., messaging content in cases described herein) PT Wireless, Inc. processes sensitive personal information to provide PT Wireless, Inc. products and services, for product research and development, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. PT Wireless, Inc. does not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require PT Wireless, Inc. to provide a right to limit under the CCPA. Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual’s information that would produce a legal or similarly significant effect. PT Wireless, Inc. does not engage in this type of profiling of individuals.

To exercise your rights, email support@parentteachermobile.com . To opt out of the use of cookies on our sites for interest-based advertising purposes, follow the instructions above. We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to a total of 90 days) in writing.

These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. To verify your identity, we may require you to log into your existing PT Wireless, Inc. account (if applicable), give a declaration as to your identity under penalty of perjury, and/or provide additional information, such as providing at least two pieces of personal information relating to your account (which will be compared to information we have, such as profile information) or as we otherwise may already have in our possession, such as your email address and phone number. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

To see our Disclosure of Privacy Rights Requests, please click here.

California’s Shine the Light Law

California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

Changes to This Privacy Statement

We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Statement on our website, with a “Last Updated” date at the top. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review before you choose to continue using our products and services.

European Data Protection Specific Information

Data Subjects Rights

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

To exercise your rights, please click here. If you have any other questions about our use of your personal data, please send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when PT Wireless, Inc. processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

International Data Transfers

PT Wireless, Inc. operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where PT Wireless, Inc. or its service providers have customers or facilities – including in countries where meeting participants or account owners hosting meetings or webinars that you participate in or receiving messages that you send are based.

Therefore, by using PT Wireless, Inc. products and services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.

We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. Please contact us if you would like further information in that respect.

California Notice at Collection

Categories of Personal Information PT Wireless, Inc. Receives: PT Wireless, Inc. may collect, or process on behalf of our customers, the following categories of personal data, as described above, in the “What Personal Data Do We Receive?” section: identifiers (such as in Account Information, Profile and Participant Information, Contact Information, and Registration Information), financial account information (such as in Account Information); commercial information (such as in Account Information); internet or other electronic network activity information (such as Device Information, Usage Information Regarding Meetings, Webinars, Message, Collaborative Features, and the Website, and Limited Information from PT Wireless, Inc. Email and Calendar Services); audio, electronic, and visual information (such as in Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features) education information such as from university customers; inferences we derive from the preceding or other information we collect; and sensitive personal information (such as certain categories in Account Information, Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features.

Sources: We receive information from sources, including: from you (including through your use of our products and services); from partners; from customers; and from publicly available sources. We collect education information from schools that use our services. Please see our Children’s Educational Privacy Statement for more information.

PT Wireless, Inc.’s business and commercial purposes for use: PT Wireless, Inc. uses personal data for the following business and commercial purposes: to provide PT Wireless, Inc. Products and Services; for Product Research and Development; for Marketing and Promotions (PT Wireless, Inc. does not use meeting, webinar, or messaging content, or any content generated or shared as part of other collaborative features for any marketing or promotions); Authentication, Integrity, Security, and Safety; to Communicate with You; and for Legal Reasons. For more information, please see “How We Share Personal Data?” Categories of third parties to whom we disclose Personal Information for business purposes are described in “How We Share Personal Data?”

PT Wireless, Inc. may permit advertising and analytics services that are intended to deliver advertising to you and/or analyze your interactions, based on your interactions with our website or app, which may constitute a “sale” or “sharing” of data under California law. See “California & Other U.S. State Privacy Rights” for more information regarding your right to opt-out.

Retention: PT Wireless, Inc. retains personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law. Additional detail on retention criteria can be found under Retention, above.

California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:

PT Wireless, Inc. will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law.

Sensitive Information. PT Wireless, Inc. receives information that may be considered sensitive under some state laws, such as certain Account Information (e.g., financial information, log-in information) , certain Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features and certain Limited Information from PT Wireless, Inc. Email and Calendar Services (e.g., messaging content in cases described herein) PT Wireless, Inc. processes sensitive personal information to provide PT Wireless, Inc. products and services, for product research and development, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. PT Wireless, Inc. does not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require PT Wireless, Inc. to provide a right to limit under the CCPA. Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual’s information that would produce a legal or similarly significant effect. PT Wireless, Inc. does not engage in this type of profiling of individuals.

To exercise your rights, email support@parentteachermobile.com To opt out of the use of cookies on our sites for interest-based advertising purposes, follow the instructions above. We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to a total of 90 days) in writing.

These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. To verify your identity, we may require you to log into your existing PT Wireless, Inc. account (if applicable), give a declaration as to your identity under penalty of perjury, and/or provide additional information, such as providing at least two pieces of personal information relating to your account (which will be compared to information we have, such as profile information) or as we otherwise may already have in our possession, such as your email address and phone number. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

To see our Disclosure of Privacy Rights Requests, please click here.

California’s Shine the Light Law

California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

Changes to This Privacy Statement

We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Statement on our website, with a “Last Updated” date at the top. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review before you choose to continue using our products and services.

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