Privacy Policy

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Privacy Policy

General

PRIVACY POLICY GENERAL WEBSITE NAVIGATION AND CONTACTS www.mexedia.com

This disclosure does not apply to other websites that may be consulted through links available on the websites of the data controller, who shall not be considered in any way liable for the websites of third parties. 

  1. The “DATA CONTROLLER” Mexedia Public limited company Benefit Company – Via Affogalasino 105 00148 Rome 

    To request information regarding the privacy policy, you can email privacy@mexedia.com.

  2. For the purposes expressed in this policy, only non-particular personal data shall be processed. 
  3. Purposes of processing, data, provision, basis for lawfulness of communication to third parties and storage times, transfers outside the European Economic Area (EEA)

For further processing, please refer to the specific information that will be presented before carrying out the same and, where necessary, consent will be obtained. 

For information on cookies, please refer to the same found on the website www.mexedia.com

A – Allow navigation on the website
More details During normal operation, the computer systems and software procedures used to operate this website acquire some personal data that is then implicitly transmitted during the use of internet communication protocols. This information is not collected to be associated with identified data subjects but is exclusively technical in order to allow navigation.  For processing related to any cookies or similar, click HERE for the cookie policy If you do not provide your data that is strictly necessary to enable navigation, it will not be possible to browse the site. 
What data do we process?  Technical information to allow connection protocols with the website.
With what legal basis: Legitimate interest of the data controller Article 6 letter f GDPR
For how long?  We process the data only to allow the user to log in to the site and for the logged in session time It should be borne in mind that the data can be processed, according to the principle of minimisation (therefore using only the data strictly necessary for the specific case) for the defence of the data controller (in court or before authorities), or for any disputes until the conclusion of the same.
B – Reception and management of contact requests received by contact area, email or telephone
More details Personal data are processed in connection with the request for information and to manage the same. Please be advised that only common personal data must be provided. If you do not provide your data: it will not be possible to follow up on requests.
What data do we process?  The name and surname of the person making the request, any reference company and the contact details and content provided by the data subject.
With what legal basis: Pre-contractual or contractual activities Article 6 letter B GDPR
For how long?  The time that is strictly necessary to follow up on the request. The data will be kept for the management of the rule request for a maximum period of 6 months.  It should be borne in mind that the data can be processed, according to the principle of minimisation (therefore using only the data strictly necessary for the specific case) for the defence of the data controller (in court or before authorities), or for any disputes until the conclusion of the same.
C – Management of data subjects’ rights
More details The purpose is linked to the reception, analysis and management of requests to exercise the rights of data subjects, including interaction with the data subject and providing the appropriate answers and clarifications. The data subject shall receive a response as soon as possible and, in any case, within the legal deadline. The data subject shall receive a response, with the appropriate reasons, even if the request cannot be accepted If you do not provide the data: it will not be possible to manage requests
What data do we process?  According to the type of request, we process all the necessary data to guarantee the correct exercise of the rights of the data subjects.
With what legal prerequisite: Guaranteeing the exercise of rights is a precise legal obligation Article 6 letter C GDPR
For how long?  The data are processed for the time necessary to manage the requests and to verify the same. Storage, as a rule, is for 5 years.  It should be borne in mind that the data can be processed, according to the principle of minimisation (therefore using only the data strictly necessary for the specific case) for the defence of the data controller (in court or before authorities), or for any disputes until the conclusion of the same.
  1. Disclosure to third parties 
Your data will not be disclosed. They will be processed with technological, IT and consulting service providers who, as a rule, operate as data processors. These parties may also include group companies that offer services to the data controller. It is understood that the data will be processed in accordance with the principle of minimisation, favouring, where possible, anonymous or anonymised data.  In particular, the categories of subjects can be the following: Parties, including Group companies, who carry out/provide technical and organisational tasks/services on behalf of the data controller, including the organisational and technological support necessary for the provision of the service or the management of the activity subject to processing Firms and companies in the field of support and consulting relationships  The data may also be communicated to independent third parties with particular reference to public authorities, perhaps including law enforcement authorities, when the legal conditions are met and in the exercise of their functions.
  1. Transfers outside the European Economic Area (EEA)
The data are processed in the European Union. If the transfer is necessary, the guarantee instruments provided for by the GDPR shall be used: adequacy decisions of the EU commission or the standard contractual clauses as promoted by the EU commission itself to regulate transfer relationships outside the European Economic Area and with any supplementary measures as also provided for by the EDPB indications.
  1. Rights of the data subject Articles 15, 16, 17, 18, 19 20, 21 and 77 of the GDPR Rights of the data subject Articles 15, 16, 17, 18, 19, 20, 21, and 77 of the GDPR.

We inform you of the existence of the right to know the recipients of the possible communication, access to personal data, rectification, deletion and possibly complete deletion, limitation of processing, data portability and opposition at any time to the processing of personal data concerning you. 

We also inform you that, if the basis of lawfulness is consent, you have the right to revoke it at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation (Article 7, paragraph 3, of the GDPR). 

Pursuant to Article 77 of the Regulation, you have the right to lodge a complaint with a supervisory authority, in particular in the member state where you usually reside, work or in the place where the alleged violation occurred, which in Italy corresponds to the Guarantor Authority for the Protection of Personal Data, whose references can be found on www.garanteprivacy.it or you can activate your protection actions also by contacting the judicial authority. You can exercise these rights simply by contacting the data controller through the contacts indicated in this policy or on the company websites.

It is understood that the exercise of rights will be promptly assessed and guaranteed, where possible, as in certain cases, requests must be weighted in conjunction with other regulatory impositions that could limit the exercise.

It is understood that even in cases where the requests to exercise the rights cannot have been followed, the data subject shall be promptly informed of the circumstance and the reasons for it.

  1. Contact details of the DPO: either at the registered office of the data controller or DPO@MEXEDIA.COM 

This information was prepared on _180723

Career

Information on the processing of career data from the website

  1. The “DATA CONTROLLER Mexedia S.p.A. SB  Via Affogalasino 105, 00148 Rome
  2. For the purposes expressed in this policy, only non-particular personal data will be processed. Any information on particular data may be processed only if it is necessary to guarantee the right of protected categories and exclusively to guarantee this right. 
  3. Purposes of processing, data, provision, basis for lawfulness of communication to third parties and storage times, transfers outside the European Economic Area (EEA)

Any particular or common data NOT strictly necessary for the selection purposes will NOT be processed and please do not include them in the materials sent.

A  – CV acquisition for application and evaluation of the same
More details Activities for receiving applications and operations related to their management (verification of the professional profile according to business needs and contacts for interviews) If you do not provide your data: it will not be possible to evaluate the application
What data do we process?  We process common personal data: candidate data such as first name, surname, date and place of birth, possibly the candidate’s tax code, residence or domicile, course of education and studies, experience and work skills acquired, It is reiterated that it is not intended to process particular data unless strictly necessary to guarantee the right of protected categories.
With what legal prerequisite:  Contractual and pre-contractual activities (Article 6 letter b GDPR) and guarantee the exercise of a right in the field of labour law in relation to any indication of a protected category (Article 9 point 2 letter B GDPR) 
For how long?  Applications are kept for 6 months unless the interview and onboarding processes are activated. In such cases, the data shall be processed until the termination of these activities.
It should be borne in mind that the data can be processed, according to the principle of minimisation (therefore using only the data strictly necessary for the specific case) for the defence of the data controller (in court or before authorities), or for any disputes until the conclusion of the same.
B – Management of data subjects’ rights
More details The purpose is linked to the reception, analysis and management of requests to exercise the rights of data subjects, including interaction with the data subject and providing the appropriate answers and clarifications. The data subject shall receive a response as soon as possible and, in any case, within the legal deadline. The data subject shall receive a response, with the appropriate reasons, even if the request cannot be accepted If you do not provide the data: it will not be possible to manage requests
What data do we process?  According to the type of request, we process all the necessary data to guarantee the correct exercise of the rights of the data subjects.
With what legal prerequisite: Guaranteeing the exercise of rights is a precise legal obligation Article 6 letter C GDPR
For how long?  The data are processed for the time necessary to manage the requests and to verify the same. Storage, as a rule, is for 5 years.  It should be borne in mind that the data can be processed, according to the principle of minimisation (therefore using only the data strictly necessary for the specific case) for the defence of the data controller (in court or before authorities), or for any disputes until the conclusion of the same.
  1. Disclosure to third parties 
Your data will not be disclosed. They will be processed with technological, IT and consulting service providers who, as a rule, operate as data processors. These parties may also include group companies that offer services to the data controller. It is understood that the data will be processed in accordance with the principle of minimisation, favouring, where possible, anonymous or anonymised data.  In particular, the categories of subjects can be the following: Parties, including Group companies, who carry out/provide technical and organisational tasks/services on behalf of the data controller, including the organisational and technological support necessary for the provision of the service or the management of the activity subject to processing Firms and companies in the field of support and consulting relationships  The data may also be communicated to independent third parties with particular reference to public authorities, perhaps including law enforcement authorities, when the legal conditions are met and in the exercise of their functions.
  1. Transfers outside the European Economic Area (EEA)
The data are processed in the European Union. If the transfer is necessary, the guarantee instruments provided for by the GDPR shall be used: adequacy decisions of the EU commission or the standard contractual clauses as promoted by the EU commission itself to regulate transfer relationships outside the European Economic Area and with any supplementary measures as also provided for by the EDPB indications.
  1. Rights of the data subject Articles 15, 16, 17, 18, 19 20, 21 and 77 of the GDPR Rights of the data subject Articles 15, 16, 17, 18, 19, 20, 21, and 77 of the GDPR.

We inform you of the existence of the right to know the recipients of the possible communication, access to personal data, rectification, deletion and possibly complete deletion, limitation of processing, data portability and opposition at any time to the processing of personal data concerning you. 

We also inform you that, if the basis of lawfulness is consent, you have the right to revoke it at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation (Article 7, paragraph 3, of the GDPR). 

Pursuant to Article 77 of the Regulation, you have the right to lodge a complaint with a supervisory authority, in particular in the member state where you usually reside, work or in the place where the alleged violation occurred, which in Italy corresponds to the Guarantor Authority for the Protection of Personal Data, whose references can be found on www.garanteprivacy.it or you can activate your protection actions also by contacting the judicial authority. You can exercise these rights simply by contacting the data controller through the contacts indicated in this policy or on the company websites.

It is understood that the exercise of rights will be promptly assessed and guaranteed, where possible, as in certain cases, requests must be weighted in conjunction with other regulatory impositions that could limit the exercise.

It is understood that even in cases where the requests to exercise the rights cannot have been followed, the data subject shall be promptly informed of the circumstance and the reasons for it.

  1. Contact details of the DPO: either at the registered office of the data controller or DPO@MEXEDIA.COM 

This information was prepared on _180723

Services SMS Business

Privacy Notice pursuant to Article 13 of EU Regulation 2016/679 GDPR for Telco Services Contract and Activation – SMS Business


MEXEDIA SPA SOCIETA’ BENEFIT

1. Data Controller: Mexedia S.p.A., located at Via di Affogalasino 105, contact information: +39 06 94502581

Purpose of the Notice: This document provides information on the processing of personal data related to telecommunications or telematics communication services, governed by a specific service contract referred to for further details. In this notice, our organization specifies the processing for which it is the data controller. Please note that for processes and activities whose processing purposes can be attributed to the data subject, our organization acts as the data processor, as appropriately regulated during the service contract subscription phase.

For processing carried out on other platforms: Specific information and, if necessary, consents will be provided before specific treatments related to access to platforms, apps, and websites.

2. Purpose of Processing, Data, Provision, Legal Basis, Retention Period, Transfers outside the European Economic Area (EEA)

A- Conclusion and execution of the contract and technical and administrative accounting activities directly related thereto, including legal obligations for identifying the owner of telecommunications or telematics services.
More Details: 
Customer’s personal data will be processed for the management of the contractual relationship, enabling the technical management of services, compliance with legal obligations affecting service activation, and administrative and accounting activities such as: ✓ Contract conclusion, user or service holder identification through standard channels. ✓ Legal obligations in civil and tax law (invoice and accounting documentation retention, civil and tax obligations). ✓ Data to enable technical interconnection with networks and ensure communication service and any contract-based or customer-requested services, as well as data for billing and administrative and technical-organizational management of provided services.
✓ Data related to invoicing, including payment management, including bank domiciliation requests or credit card payments, and payment verification. ✓ Receipt and handling of requests from data subjects or complaints.

If you do not provide your data, it will not be possible to conclude the contract and provide the service.
What data we process: ✓ Type of product or service purchased, personal data (name, surname, age, tax code, gender, place and date of birth), residence or domicile address, contact details (phone, email address), copy of ID document and tax code, service holder’s phone number or data related to the contracting party’s representative. ✓  Technical data generated to enable the provision of the purchased communication service. Please note that only external data (technical data for service management) are processed, with no access to content. ✓  Banking and/or payment data to enable payments, including bank domiciliation or credit card charges, and to verify proper payment and contractual compliance. ✓  The above data may also be used in case of attempted fraud to prevent or counteract it, in accordance with the principle of strictly necessary data minimization for the specific case, for the data controller’s legal defense or for any legal disputes until their conclusion
Legal Basis: ✓ Subscription and activation of services and customer request management: contractual obligation (Art. 6, letter b GDPR) ✓ Identification of the service holder is linked to legal obligations (Art. 6, letter c GDPR).
✓ Technical traffic data related to service provision for interconnections and technical management: contractual obligation (Art. 6, letter b GDPR) and legal obligation (Art. 6, letter c GDPR) for retention ✓
Intervening in cases of fraudulent use: legitimate interest of the data controller (Art. 6, letter f GDPR). Data may be processed according to the principle of minimization (using only data strictly necessary for the specific case) for the data controller’s legal defense or any legal disputes until their conclusion.
Timeframes:
✓  Data for contract activation and management, as well as directly related legal obligations, are retained for the duration of the relationship and for an additional 10 years and 6 months, unless legal disputes and proven protection needs may require longer processing in specific cases ✓ Traffic data is processed for administrative purposes for only 6 months, unless there are legal disputes. Additional retention is based on specific legal requirements. ✓  It should be noted that data may be processed according to the principle of minimization (using only data strictly necessary for the specific case) for the data controller’s legal defense or any legal disputes until their conclusion.
B- Compliance with legal obligations regarding data retention for judicial purposes.
More details:
Processing is strictly related to the obligation to retain telephone and telematic traffic data for judicial purposes as required by current legislation and the management of requests imposed by law. If you do not provide your data, it will not be possible to conclude the contract and provide the service.
What data we process: ✓ Data generated to enable the provision of telematic or telephone communication service in addition to the service holder, as previously indicated. ✓ Please note that only external data are processed with no access to content. It should be understood that in the exercise of their functions, authorities may, depending on the case, have access to all information stored by the data controller.

Legal Basis:

The processing of such data is related to legal obligations of the data controller (Art. 6, letter c GDPR).

Timeframes

✓ Data related to telephone and telematic traffic is retained based on legal obligations. The ordinary reference for retention is Article 132 of the Privacy Code, which requires telecommunications traffic data to be retained by the provider for 24 months and telematics traffic data for 12 months from the date of communication. Data related to unanswered calls is retained for 30 days.

  • ✓ Currently, in derogation from the above terms, data must be retained for up to 72 months due to legal requirements, but they are only available for certain types of offenses. Article 132 of the Privacy Code provides differentiated access to this data depending on the type of offenses for which access is requested. In case of changes in regulations, retention will necessarily be modified in compliance with legal requirements.
  • ✓  It should be noted that data may be processed according to the principle of minimization (using only data strictly necessary for the specific case) for the data controller’s legal defense or any legal disputes until their conclusion.
C – Management of data subject rights.
More Details: ✓ The purpose is related to receiving, analyzing, and managing requests to exercise data subject rights, including interaction with the data subject and providing appropriate responses and clarifications.

What data we process: 

Depending on the type of request, we process all necessary data to ensure the correct exercise of data subject rights.

Legal Basis: Ensuring the exercise of rights is a specific legal obligation (Art. 6, letter c GDPR).

Timeframes:

✓ Data are processed for the time necessary to manage requests and to verify the same. The usual retention period is 5 years.

✓ It should be noted that data may be processed according to the principle of minimization (using only data strictly necessary for the specific case) for the data controller’s legal defense or any legal disputes until their conclusion.

D – Commercial communications regarding all products and activities of the data controller.

More details

  • ✓  With the consent of the data subject, we may conduct commercial actions regarding all products and services provided by our organization. The data subject can choose the preferred contact method (SMS, email, calls with an operator, automated calls, or all methods).
  • ✓  The data subject can object at any time, either through automated procedures managed with links provided in each communication, using systems made available by the data controller (apps, dedicated customer website area), or by contacting our organization. Opposition is simple and free and can apply to all communication methods or only to specific ones.
  • ✓  Concerning phone contacts, in addition to the data subject’s right to object, the provisions of the regulations establishing and regulating the public opposition register will be guaranteed, even in case of service contract termination.
  • ✓  If you do not provide your dati the indicated communications cannot be sent without any other consequences. What data we process: ✓ Name, surname, email, and/or phone number. ✓ The data subject can choose the preferred contact method: email, SMS, calls with or without an operator, all methods. Legal Basis: Consent of the data subject (Art. 6, letter a GDPR).

Timeframes:

  • ✓ Data are processed until the data subject objects, which can apply to all or only specific contact methods, as chosen by the data subject. Subsequently, data are processed only for the management of data subject rights (see explicitly stated purpose).
  • ✓  It should be noted that data may be processed according to the principle of minimization (using only data strictly necessary for the specific case) for the data controller’s legal defense or any legal disputes until their conclusion.

3. Third-Party Communications

Data will not be disclosed. They will be processed by providers of technological, professional, IT, and consulting services who, as a rule, operate as data processors. It is understood that data will be processed in compliance with the principle of minimization, handling only data strictly necessary for the specific activity and, where possible, anonymized or anonymized data.

In particular, categories of entities may include:

  • Entities providing services for data acquisition, processing, and processing necessary for the use of services, user identification, handling of user requests, and more generally, activities related to the processing carried out by the data controller, and for the provision of contractually provided services.
  • Customer support entities. Entities engaged in archiving and data entry.
  • Entities providing services for the management of the data controller’s information system, including archiving and information security in accordance with regulations.
  • Other electronic communications operators, for the management of interconnection and roaming relationships, and more generally, to ensure the correct provision of telephone and telematic connection services based on the provided service
  • sEntities engaged in the transmission, packaging, transport, and distribution of communications to customers.
  • Credit assignee companies or debt recovery entities, banks for domiciliation purposes.
  • Entities performing control, review, and certification of activities carried out by the data controller.
  • Entities performing technical and organizational tasks on behalf of the data controller
    Sales agents, studies, and companies within the scope of assistance and consultancy relationships.
  • Data may also be communicated to independent third-party data controllers, particularly with reference to public authorities, if legal conditions are met and in the exercise of their functions.

4. Transfers outside the European Economic Area (EEA)

Data is processed within the European Union. If transfer is necessary, GDPR safeguards, such as standard contractual clauses promoted by the EU Commission for regulating transfers outside the European Economic Area, will be used, along with any supplementary measures as indicated by the EDPB.

  1. Data Subject Rights – Articles 15, 16, 17, 18, 19, 20, 21, and 77 of the GDPR We inform you of the right to know the recipients of possible communications, access personal data, rectify, erase, and potentially forget, restrict processing, data portability, and object to the processing of personal data concerning you. We also inform you that, if the legal basis is consent, you have the right to revoke it at any time, without affecting the lawfulness of processing based on consent before revocation (Art. 7, paragraph 3 GDPR). Pursuant to Article 77 of the Regulation, you have the right to lodge a complaint with a supervisory authority, particularly in the Member State where you habitually reside, work, or where the alleged violation occurred, which in Italy corresponds to the Italian Data Protection Authority, whose details can be found at www.garanteprivacy.it or by contacting the judicial authority. The exercise of these rights will be evaluated and guaranteed promptly where possible because, in certain cases, such as access to telephone or telematic traffic data, requests must be balanced against other legal requirements that may limit their exercise.
  2. Data Protection Officer Contact: dpo@mexedia.com
    This notice was prepared on July 4, 2023.

Mail Marketing

Information on the processing of email marketing data 

  1. The “DATA CONTROLLER Mexedia S.p.A. SB  Via Affogalasino 105, 00148 Rome  
  2. For the purposes expressed in this policy, only non-particular personal data will be processed. 
  3. Purposes of processing, data, provision, basis for lawfulness of communication to third parties and storage times, transfers outside the European Economic Area (EEA)
A   – Purpose of sending email marketing
More details Forwarding of commercial communications by automated mailing to the email address provided by the data subject. You can object at any time, either through automated procedures managed with links placed at the bottom of each communication you will receive or by contacting the data controller without formalities. Opposition to the processing is easy and free. If you do not provide your data: it will not be possible to forward communications without any other prejudice.
What data do we process?  Name, surname, any company to which the user may belong if provided, email address
With what legal basis: art.6 Letter A)
For how long?  We process the data for this purpose until the data subject objects. It should be borne in mind that the data can be processed, according to the principle of minimisation (therefore using only the data strictly necessary for the specific case) for the defence of the data controller (in court or before authorities), or for any disputes until the conclusion of the same.
B – Management of data subjects’ rights
More details The purpose is linked to the reception, analysis and management of requests to exercise the rights of data subjects, including interaction with the data subject and providing the appropriate answers and clarifications. The data subject shall receive a response as soon as possible and, in any case, within the legal deadline. The data subject shall receive a response, with the appropriate reasons, even if the request cannot be accepted If you do not provide the data: it will not be possible to manage requests
What data do we process?  According to the type of request, we process all the necessary data to guarantee the correct exercise of the rights of the data subjects.
With what legal prerequisite: Guaranteeing the exercise of rights is a precise legal obligation Article 6 letter C GDPR
For how long?  The data are processed for the time necessary to manage the requests and to verify the same. Storage, as a rule, is for 5 years.  It should be borne in mind that the data can be processed, according to the principle of minimisation (therefore using only the data strictly necessary for the specific case) for the defence of the data controller (in court or before authorities), or for any disputes until the conclusion of the same.
  1. Disclosure to third parties 
Your data will not be disclosed. They will be processed with technological, IT and consulting service providers who, as a rule, operate as data processors. These parties may also include group companies that offer services to the data controller. It is understood that the data will be processed in accordance with the principle of minimisation, favouring, where possible, anonymous or anonymised data.  In particular, the categories of subjects can be the following: Parties, including Group companies, who carry out/provide technical and organisational tasks/services on behalf of the data controller, including the organisational and technological support necessary for the provision of the service or the management of the activity subject to processing Firms and companies in the field of support and consulting relationships  The data may also be communicated to independent third parties with particular reference to public authorities, perhaps including law enforcement authorities, when the legal conditions are met and in the exercise of their functions.
  1. Transfers outside the European Economic Area (EEA)
The data are processed in the European Union. If the transfer is necessary, the guarantee instruments provided for by the GDPR shall be used: adequacy decisions of the EU commission or the standard contractual clauses as promoted by the EU commission itself to regulate transfer relationships outside the European Economic Area and with any supplementary measures as also provided for by the EDPB indications.
  1. Rights of the data subject Articles 15, 16, 17, 18, 19 20, 21 and 77 of the GDPR Rights of the data subject Articles 15, 16, 17, 18, 19, 20, 21, and 77 of the GDPR.

We inform you of the existence of the right to know the recipients of the possible communication, access to personal data, rectification, deletion and possibly complete deletion, limitation of processing, data portability and opposition at any time to the processing of personal data concerning you. 

We also inform you that, if the basis of lawfulness is consent, you have the right to revoke it at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation (Article 7, paragraph 3, of the GDPR). 

Pursuant to Article 77 of the Regulation, you have the right to lodge a complaint with a supervisory authority, in particular in the member state where you usually reside, work or in the place where the alleged violation occurred, which in Italy corresponds to the Guarantor Authority for the Protection of Personal Data, whose references can be found on www.garanteprivacy.it or you can activate your protection actions also by contacting the judicial authority. You can exercise these rights simply by contacting the data controller through the contacts indicated in this policy or on the company websites.

It is understood that the exercise of rights will be promptly assessed and guaranteed, where possible, as in certain cases, requests must be weighted in conjunction with other regulatory impositions that could limit the exercise.

It is understood that even in cases where the requests to exercise the rights cannot have been followed, the data subject shall be promptly informed of the circumstance and the reasons for it.

  1. Contact details of the DPO: either at the registered office of the data controller or DPO@MEXEDIA.COM 

This information was prepared on _180723

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