Privacy Policy

Talenya Privacy Notice

This document sets out the privacy policy of Talenya Ltd., an Israeli company and its U.S. subsidiary, Talenya Inc. (“Talenya”, “we”, “us” and “our”).

Privacy Commitment

Talenya is committed to protecting the privacy of all individuals in respect of whom we collect, receive, hold and process any personal data.
Our privacy policy is designed to be compliant with the laws and regulations of where we conduct our business. Without limiting the foregoing, our privacy policy is consistent with Israeli privacy and data protection regulations, including without limit the Protection of Privacy Law 5741-1981 and the Privacy Protection (Data Security) Regulations 5777-2017 promulgated thereunder (collectively “Israeli Law”), the European Union’s General Data Protection Regulation 2016/679 (“GDPR”) and applicable U.S. privacy laws.
This privacy notice describes how we collect and process the personal data of individuals and we also provide you with details as to your rights in connection with your personal data that we control and process. This privacy policy does not deal with how we treat commercially confidential information that we receive from our customers and other business partners. We are committed to keep confidential and use commercially confidential information of business entities in accordance with all confidentiality agreements that we enter into.

Some Definitions

In this privacy notice, the following terms have the meanings provided below.

Personal data” means any information of any kind relating to a natural individual and which can be connected to that individual either directly or indirectly by reference to other information. If information is pseudonymized so that the individual cannot be identified without additional identifying information, then the information is still personal data to the extent that we must be careful to ensure that we do not reveal any identifying data to any other party unless it is in compliance with our privacy policy, but the risks to your privacy is considerably reduced and when the pseudonymized information is delivered to third parties without the identifying information, it is effectively anonymized until they receive the identifying data from us. Our privacy policy covers all forms of personal data, including without limit, personal data that was collected online and personal data collected off line, personal data stored in electronic form and personal data stored in paper or any other form.

Processing” of personal data means performing any operation or set of operations on 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 of the personal data.

Controller” of personal data is any person or entity that determines how personal data will be processed and by whom.

Processor” of personal data is any person or entity that undertakes any processing activity of the personal data.

With respect to the personal data described in this privacy notice, Talenya is the controller and also a processor. We may also subcontract out certain processing activity to other processors. Talenya customers that receive personal data of talent will also be controllers with respect to that personal data once they receive information that identifies the talent (see below).

Who we are

Talenya’s talent sourcing Bots collect and use data from various online sources to rapidly identify the right talent for each job and to reach out to that talent before they may even start searching for their next job. Talenya is helping leading companies around the world, fill hard-to-fill jobs and make talent acquisition dramatically more efficient. By using Talenya’s AI-powered Bots, Talent Acquisition teams are able to achieve their hiring goals faster, at a higher quality, and at a fraction of the cost.

Talenya will ensure that all personal data collected by us is controlled and processed solely in the manner and for the purposes set out in this privacy notice. We will also ensure that all personal data in our possession will be held and stored safely and in compliance with the applicable laws.

This privacy notice is divided into three parts.

Part 1 is concerned with how we collect and process personal data relating to job candidates for positions our customers are seeking talent to fill.

Part 2 is concerned with how we collect and process personal data relating to other individuals, including representatives of our customers and business partners.

Part 3 is describes those parts of our privacy policy that applies all individuals.

Part 1 – Personal Data of Job Candidates

How we collect an individual’s personal data

Our talent sourcing Bots collect personal data uploaded by the individuals themselves from publicly available websites and social media platforms. Our Bots know how to discern personal data that is relevant to a person’s profession, such as work experience, professional qualifications, skills and courses attended and they only collect that data. Our Bots ignore data related to age, marital status and, except as stated below, sensitive information such as race, ethnicity, religion, health and sexual orientation. When a customer enters into our system new criteria for a particular job, our bots will search the personal data we already hold on our system together and will search for additional suitable individuals who may match the search criteria on the publicly available websites and social media platforms.

How we process an individual’s personal data

Following collection of personal data, our system creates a unified form of candidate profile for each individual whose personal data has been collected. The process for each individual involves merging the personal data collected from the various different sources. Where there are any discrepancies between sources, the information uploaded more recently is preferred to older information.

Our system also uses certain predictive algorithms in order to fill in blanks, such as where the personal data collected from the Bots does not include a particular skill or experience which is normally included in our profiles, the system can predict whether or not the person is likely to have that skill based on the other data collected. Our system also uses predictive algorithms in order to predict future career paths of individuals.

Once a profile has been created, the profile will be stored on Talenya’s servers and the Bots may select the individual at any time (or not at all) as a potential candidate for a position that a customer is looking to fill.

When a customer commences a search for a suitable candidate for a particular job, they input various search criteria. The Bots then scan the profiles maintained in the Talenya system for candidates whose profiles generally match the search criteria. The Bots also rescan the public platforms to find additional potential candidates whose personal data will be collected and processed in the same way.

The Bots will assign a suitability value for each profile based on how closely the profile matches the customer’s search criteria together with an indication about their potential career path.

The Bots will select a number of the top scoring profiles and then search through the original sources of the personal data contained in those profiles to determine whether any of the information needs to be updated. The profiles are then pseudonymized.

Customers are then sent the selected pseudonymized profiles for review. Customer’s initial reviews may result in their selection criteria being adjusted or further configurated and the search process repeated until the customer selects the profiles of individuals that they wish to actually engage with, contact, meet and interview. Up to this point, the profiles remain pseudonymized and the customer has no way of being able to identify the candidates.

Once a customer has asked to reach out to a specific candidate, based on their pseudonymized profile, we will try to obtain that person’s updated contact information. We may find this information on the social media sources or we may try to purchase this information from third party databases. If we cannot obtain the contact information, then the search for a suitable candidate will continue. If we successfully obtain the contact information, then we will provide that information if the individual is based in the U.S. For individuals based in the EU and Israel, we will reach out to the selected individual or individuals, notify them of the fact we hold their personal data, how and why we hold and process that personal data and that they have been selected by a customer for direct contact in connection with a potential job opportunity. For Individuals based in Israel and the EU, we will not provide the customer with the contact and other identifying details until we have obtained their consent as described below under the paragraph titled “Consent”.

Finally, Talenya has created an algorithm that processes data related to race and ethnicity obtained from certain very basic information contained in the profiles it obtains from the social media sources. That data is immediately anonymized and together with data on gender, is aggregated so that Talenya may conduct statistical analysis in order to provide, non-biased and more accurate services to its customers. No data relating to gender, race and ethnicity created by the algorithms is kept in unanonymized form, shared with any other party or processed in any other way.

What is the legal basis for us to collect and process personal data of individuals as described above?

For personal data relating to EU based individuals, the GDPR provides certain legal bases for the control and processing of personal data of EU based individuals.

Legitimate Interests

The legal basis that we rely upon for the collection and processing of personal data described above until, but not including, the point where we are requested to provide identifying data to a customer is the pursuit of our legitimate business interests. We have evaluated the effect that our processing of the personal data may have on the individuals and have determined that the effects of the processing do not impact on the interests or fundamental rights and freedoms of the individuals.

We have made this determination based on the fact that:

The sources of all personal data collected are the individuals themselves, who uploaded the data onto those publicly accessible social media platforms with the clear intention to publicise that information. Therefore, the personal data collected is not data that should be considered by the individuals to be particularly sensitive.
Even though our processing includes profiling the individuals and automatic decision making based on our profiling, this processing does not have any legal or similarly significant effect on the individuals as the individuals’ identities are not revealed to any third party until receipt of the individual’s consent (see below).
Where special categories of data related to race and ethnicity is created by our algorithms, it is minimal in detail, based entirely on data placed in the public domain by the data subjects themselves and immediately anonymized and aggregated and not shared with any other party.
Consent

We will not provide our customers or any other party with any identifying information for any individual based in the EU or Israel until we receive that individual’s consent. In the case of EU based individuals, we will ensure that the consent is freely given, express, clear and informed in accordance with GDPR requirements.

We seek an individual’s consent to provide our customer with their identifying information only once a customer has notified us that they wish to contact that individual in connection with the position that they are looking to fill.

Other Legal Bases

We will also process personal data, including disclosing the personal data to appropriate third parties, in the unlikely event that we determine that the processing is necessary for compliance with applicable law (EU law for EU based individuals) to which we are bound or if the processing is necessary to protect the vital interests of the individual to whom the personal data relates or of another natural person.

Part 2 - Personal data relating to other individuals, including representatives of our customers and business partners

In this section, “you” may refer to:

Individuals who have no relationship with Talenya and represent businesses that may be interested in becoming Talenya Customers. Talenya has acquired data about these individuals and the businesses they represent through a third party (“Leads”).
Individuals who already have contacted Talenya or otherwise inquired about Talenya’s products or services and who may represent businesses that may be interested in becoming Talenya customers (“Prospects”).
Individuals who represent businesses that currently use Talenya’s products and services (“Customers”).
Individuals who are candidates for employment by Talenya

How and what personal data do we collect from you.

Marketing activities. We may conduct marketing activities, such as hosting a webinar, attending trade shows and other events in which we meet you personally and you provide us with certain personal details such as contact details, name of business you are representing and relevant details of the business (though business details are not personal data under this privacy notice). We may then follow up with further correspondence in response to which you provide us with additional personal data.
Demo or contact requests. When you request a demo or otherwise request to be contacted by us, we receive and store any information you knowingly provide to us. For example, when you request a demo of the services, we ask you to provide your first name, last name, company name, phone number, email address and company size.
When you comment on our blog. If you want to comment on our blog posts at blog.Talenya.com you must first register by providing your first and last name and email address. You may also provide an optional website URL. Furthermore, your blog comment may contain personal data.
When you use our services. In order to use our services, we will require personal data from representatives of the Customer, such as contact details and position with the business. These details will be required from you, together with certain confidential business information, when you open an account on our platform.
When you visit our Website. Please refer below to the section titled “Data (including personal data) that we collect from your use of our website – Cookies and other technologies”.

When you apply for a job with Talenya. We will receive a copy of your resume, either directly from you or from a third-party.
Data from third parties. Talenya may engage third parties, who provide us with contact information for Leads. The third parties may provide us with additional personal data relating to the Leads’ representatives. When acquiring personal data from third parties, Talenya will obtain contractual commitments from the third parties that the information provided by them, including personal data, was acquired by them lawfully and that they have appropriate authority under applicable law to provide us with the personal data.

How we process your personal data

We will store your personal data on our system, and we will use the information for the following:

In order to manage our business relationship with you. This includes communicating with you in connection with services you are receiving from us. For example, in connection with candidate searches and to resolve technical issues.
We will use your contact information to communicate with you, but only to the extent that it is required to manage the conduct of our business with you, which may include providing you with offers and other marketing and promotional material that is closely connected to our business relationship, provided however, that the communications are made directly to you and not as part of email, SMS and similar marketing campaigns sent to multiple persons from mailing lists and the like (“Campaign Material“). We will not send to you Campaign Material unless we receive your clear, express and informed consent. You may change your consent settings at any time.
We use the personal data that we have collected from your use of our website (see below) in order to make our communications more interesting for you and improve our services, whether specifically for you or in general for all our customers.
Information gathered from your use of our website (see below) is provided to third-party advertising companies so that they may direct appropriate adverts about our products to you, for example, sidebar ads, banners or search ads when you visit other websites within that advertising network. Most of the data gathered may actually be more relevant to the business you represent than to you personally, but it may also include personal data.

What is the legal basis for us to collect and process your personal data?

Performance of a Contract

We may process your personal data where we have entered into a contract with the business that you represent and we determine certain processing of your personal data is required in the performance of our contractual obligations with that business.

Legitimate Interests

We may process your personal data where we determine that the processing may be performed in pursuit of our legitimate business interests, but we will make sure that our legitimate business interests will not override your fundamental rights and freedoms.

Other Legal Bases

We will also process personal data, including disclosing the personal data to appropriate third parties, in the unlikely event that we determine that the processing is necessary for compliance with applicable law (EU law for EU based individuals) to which we are bound or if the processing is necessary to protect the vital interests of the individual to whom the personal data relates or of another natural person.

Part 3 – Privacy policy matters relating to all individuals

Personal data that we collect from your use of our website – Cookies and other technologies

When you visit the Talenya Website or use our services, we and our third-party service providers acting on our behalf automatically collect certain data using tracking technologies like cookies, web beacons, and similar technologies.

A cookie is a small amount of data, which often includes a unique identifier that is sent to your browser from a website’s computers and is stored on your computer’s hard drive.

These technologies are used to help us expedite login of platform users, better understand user behavior and facilitate and measure the effectiveness of our Talenya website and services.

We use cookies to record current session information. We also use third-party cookies (for example Google Analytics) to provide anonymized and aggregated information on website usage statistics and patterns.

All modern Internet browsers allow you to control your cookie settings. These settings are usually accessed in the Options or Preferences section of your browser. On your computer or mobile device, go to Settings, then go to the specific web-browser, and then to the Cookies section. Please note that certain features of the Website will not be available once cookies are disabled. For further information about cookies and how to manage them, please visit www.allaboutcookies.org.

Talenya also uses web beacons (with cookies and separately) to compile information about your engagement with us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies when you view a particular website tied to the web beacon, and a description of a website tied to the web beacon.

Here is a basic description and overview of the type of cookies Talenya uses:

Cookie Type Description

Required Cookies

Required cookies make it possible for you to access the services, navigate within the services, and access information related to your account.

Each time you log into the Services, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow Talenya to uniquely identify you when you are logged into the services and to process your requests.

Management Setting

Required cookies are necessary to operate the account portal, so you cannot opt-out of them.

Functionality Cookies

Functionality cookies allow the Talenya website and services to remember information you have entered or preferences you select and provide enhanced, more personal features. These cookies allow you to optimize your use of the services after logging in. These cookies can also be used to remember changes you have made to the portions of your account that you can customize.
You can use your browser settings to opt-out of functionality cookies. For more information on how to do that, click here. Note that opting out may affect the functionality of our website or services for you.

Performance Cookies

These cookies collect data about how visitors use the Talenya website or services. This includes data like which pages visitors go to the most. These cookies don’t collect information that individually identifies visitors. The data these cookies collect is aggregated and intended to be anonymous and used to improve how the site functions and performs.

Personal data that we collect from your use of our website – Cookies

Advertising Cookies

Talenya may have third-party service providers track and analyze usage and volume statistical information from those who visit the Talenya website and use our services. Talenya sometimes uses cookies placed by its third-party service providers to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Talenya websites or used the services. This data given to the third-party service providers do not include information that identifies you specifically, but this data may be re-associated with information that identifies you specifically after Talenya receives it.
To learn more about how to opt-out of targeting and advertising cookies, you can go to the Your Online Choices page, the Network Advertising Initiative page, and the Digital Advertising Alliances Consumer Choice page. These opt-out tools are provided by third parties, not Talenya. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

We also use certain third party services and their software tools that help us better understand the experience of visitors to our website and users of our services on our platform. These services and tools enable us to build and maintain our service more appropriately. These tools also use cookies and other technologies to collect data on our users’ behavior and their devices. Some tools store this information in a pseudonymized user profile. If we need to transfer personal data collected from these tools to a service provider for processing, this is done in compliance with all of the relevant provisions of this privacy policy.

Additionally, we track when you open and click content in an email from us. This information helps us make our communications more interesting for you and improve our services. At any time you can inform us of the kinds of promotional messages that you wish to receive from us or to opt-out from receiving any promotional messages of any kind.

How we treat Do-Not-Track Signals

Your browser may offer you a Do Not Track option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Website does not recognize or respond to Do Not Track requests because there is no consistent industry standard for compliance. To learn more about Do Not Track please visit http://www.allaboutdnt.org/.

How long we will hold your information

To the extent permissible by applicable law, we will retain your personal data for such period as we believe is necessary in order for us to use it in the manner intended as described in this privacy notice. Therefore:

For Website visitors, Talenya will retain your information as long as reasonably useful for our commercial purposes.

For Talenya Customers, we will retain your account information for as long as your account is active or as reasonably useful for commercial purposes. If you want Talenya to delete portions of your data used to provide you services, then please email us at Privacy@Talenya.com. We process Customer requests for data deletion within ten (10) business days of receipt of the request. If you are a Talenya Customer and no longer want Talenya to use your data to provide you services, you may close your account. If you close your account then you no longer will be able to use the services.
Personal data of representatives of Customers, Prospects, and Leads will be deleted when we are informed by the relevant organization that the representative has ceased to work for them. As explained above in Part 1, personal data of representatives of Customers will normally be collected and a profile for them created as part of the onboarding process for the Customers. While the former representative will no longer be contacted in connection with Customer business, their profile will be maintained on the system for consideration by our Bots inappropriate talent searches, unless you specifically request us to remove the profile.
Personal data of individuals collected and processed in accordance with Part 1 – Personal Data of Job Candidates will be maintained for as long as an individual may become considered for any talent position required by a Customer, which effectively is until the individual retires.
Personal data of our own job candidates will be maintained until the person is no longer employed by us or until we have decided not to offer the candidate a job.
Notwithstanding the above, we will also continue to hold personal data for so long as we have legitimate business interests to do so, or we are legally required to do so.

Rather than deleting certain information, we may anonymize it and aggregate it with other anonymized information for our record keeping and statistical purposes. Please note that it may not always be possible to entirely delete information. For example, the information may be stored in backup archives. In such cases, we will securely store the information and isolate it from any further processing until deletion is possible.

Business transfers

If Talenya or our assets are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal data stored on our systems, including profiles of individuals described in Part 1 above are likely to be among the assets transferred to or acquired by a third party.

Transfer of personal data to third-party servers

Personal data that we collect is stored on third-party servers that have been selected, among other reasons, based on their commitments to hold and protect the personal data from unauthorized access or transfer and that have provided commitments consistent with the GDPR, Israeli, and U.S. privacy protection laws. Currently, the personal data is stored on Amazon Web Services’ (“Amazon”) servers, currently located in Europe. The personal data is stored on the servers under our own unique account to which no other party has access. Amazon undertakes to store and transfer personal data in accordance with its own privacy policy which can be found at https://aws.amazon.com/privacy/?nc1=f_pr.

Allowing access to the servers where the personal data is stored or allowing for transfers of the personal data to other destinations will only be done where consistent with our privacy policy.

International Transfers of Personal Data

We will only conduct international transfers of personal data in accordance with the applicable laws pertaining to the personal data collected. For example, personal data of EU based individuals will only be transferred to a third party outside the EU or the European Economic Area (EEA), if there is an appropriate legal basis for the transfer being made (see above for descriptions of legal bases for processing of personal data) and the transfer is made to a destination that has received an EU Commission adequacy decision regarding the destination’s privacy laws being sufficiently consistent with those of the GDPR or other appropriate measures are taken by us, consistent with GDPR requirements, to ensure that the personal data will be appropriately protected.

How we secure your personal data and other commercially confidential information

Talenya takes the security of all personal data and commercially confidential information very seriously, regardless of whether the information is stored electronically or in another form.

We have put in place reasonable administrative, organizational and technical safeguards and security measures to protect personal data from unauthorized access, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures and update them when we deem it to be required.

Examples of measures taken include:

Implementing a detailed corporate-wide privacy policy and work rules for Talenya staff and business partners

Training relevant Talenya staff and business partners in connection with implementing the privacy policy
Assigning access authorizations to different members of Talenya personnel, ensuring that access to different sensitive information of any kind is restricted to only those personnel that require access to the information for the purpose of their work with Talenya
Ensuring access described in the above bullet is controlled by sufficiently strong user names and password protections
Implementing technical measures to prevent unauthorized access to Talenya servers, such as “hacking”. Please note, though, that no website or internet transmission is completely secure, so while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss, or a data breach will never occur.

Personal data relating to children

We do not knowingly collect any personal data regarding children under the age of 16. If we discover we have received any personal data regarding a child under the age of 16, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 16, please contact us at privacy@Talenya.com.

Your Rights in Connection with Your Personal Data Held by Us.

You have certain rights in relation to personal data about you that we hold. Details of these rights and how to exercise them are set out below. We will require suitable evidence of your identity before we are able to act on any request with respect to exercising any rights.

Right of Access

You have the right at any time to ask us for a copy of the personal data about you that we hold. The applicable laws provide certain instances where we may refuse your request for a copy of your personal data, or certain parts of the personal data that we hold. If we refuse your request or any element of it, we will provide you with our written reasons for doing so as soon as possible.

Right of Correction or Completion

If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed.

Right of Erasure

You have the right to request that personal data we hold about you is erased if:

your personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
you wish to withdraw your consent on which the processing of your personal data was based and there is no other basis justifying such processing;
you consider and can establish that your personal data has been unlawfully processed, or
your personal data must be deleted in accordance with a legal obligation.
However, we cannot guarantee that we will not later collect other personal data that pertains to you as a job candidate from publicly available websites or third-party vendors as our Bots may not discern that the data pertains to an individual that requested their information be deleted. Please note that even if you request that we delete personal data about you, we may still retain data in an aggregated and anonymized form that does not identify you. We may also be legally prevented from deleting your data and if this is the case, we will inform you upon receipt of your request to be deleted.

Right to object to or restrict processing

You have the right to object to our processing of your personal data and you also have the right to object to the use of your personal data for direct marketing purposes.

Right of Data Portability

You have a right to receive any personal data that we hold about you in a structured, commonly used, and machine-readable format. Please note that if you are requesting the personal data to be transferred to a third party’s system, we cannot guarantee technical compatibility with that system.

Consent

To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.

Exercising your rights

If you wish to exercise any of your rights listed above in connection with any personal data of yours that we hold and process, then please contact us in the manner set out in the next section below.

Communications and Complaints

If you wish to exercise any of your rights described above, or if you wish to communicate with us in connection with any matter related to our processing of your personal data or if you are unhappy about any aspect of our use of your personal data, please do notify us, providing the reasons for any request or complaint and we will endeavor to rectify the problem.

We have appointed a Data Protection Officer within Talenya who is responsible for ensuring that we comply fully with our responsibilities under this privacy notice and under applicable law. Our Data Protection Officer may be reached at privacy@Talenya.com.

If you are based in the EU, you may also lodge a complaint with any Data Protection Authority set up to supervise and enforce the GDPR (“DPA“). There is a DPA in each EU member state and you may report to any DPA, although generally you will report to the DPA set up in the member state in which you are located. Here is a list of all DPAs and their contact details: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. However, we do take your rights with respect to your personal data very seriously and will appreciate the chance to resolve any issues that you may have before you address a DPA.

For residents of the United States, Talenya is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If you have any questions or concerns regarding this privacy notice, please contact our Data Protection Office first at privacy@Talenya.com. You may also contact us at: Talenya Inc, Attn: Privacy Officer, 221 River Street, Hoboken, New Jersey, 07446. If contacting us does not resolve your complaint, you may file a complaint, free of charge, with the United States Council for International Business (USCIB) – https://www.uscib.org/.

California residents

Under California Civil Code Section 1798.83, California residents are entitled to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. You have the right not to receive discriminatory treatment for the exercise of your privacy rights under California law. If you are a California resident and would like to request this information, then please submit a written request to privacy@Talenya.com.

Changes to this Notice

We are constantly trying to improve our Website and our services, so this privacy notice may need to be amended from time-to-time. If we amend the privacy notice, then we will update it on the website accordingly. Therefore, if you continue to use the Website or our services, then you are encouraged to review this policy notice periodically.
Security and compliance

On our website we use cookies to enhance your user experience. To learn more about cookies, how we use them and their benefits please read our Cookie Policy

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