Términos de servicio (EE. UU.)

Last updated: October 20, 2026

1. Introduction

Please take a moment to read this U.S. Privacy Policy (this “Policy”) carefully. This Policy describes when, why and how Ledn US LLC (“Ledn,” “Ledn US”, “we”, “us” or “our”) collects, uses, discloses, retains and protects your personal information. 

By accessing or using our website at https://ledn.io/ and its subdomains, or the Ledn mobile application which can be downloaded from the Apple App Store or Google Play Store (collectively, the “Platform”), you acknowledge that you have read, understood, and accept this Privacy Policy (this “Policy”) and consent to the practices described herein. You acknowledge that Ledn US’s Terms of Service, found at https://ledn.io/legal/terms-of-service are incorporated into this Policy by reference (“Terms of Service”). Capitalized terms used but not defined in this Policy have the meanings given to them in the Terms of Service. If you do not agree with this Policy, you should not access or use the Platform. 

Please note that the Gramm-Leach-Bliley Act (“GLBA”) applies to contexts where you are applying for or obtaining certain financial products or services for personal, family, or household purposes. U.S. state privacy laws do not. For more information about your rights under the GLBA and how we collect, disclose, and secure information when you apply for or obtain those financial products and services, review our GLBA Privacy Notice. 

We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for the purposes described herein. We only collect the necessary information to originate, administer and process our Services (including as necessary to comply with our legal and regulatory obligations).

Our Services may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share personal information about you. If you follow a link to a third-party website or engage a third-party plugin or service, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for those policies. We do not control these third-party websites, and we encourage you to read the policy of every website you visit.

2. What is personal information?

Personal information. Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. It includes your name, mailing address, email address, telephone number, Social Security number, date of birth, account and loan information, digital asset wallet addresses linked to you, Internet Protocol (IP) address, device identifiers, login information, and any other identifier we may use to contact or recognize you.

Nonpublic personal information. “Nonpublic personal information” (“NPI”) is a subset of personal information defined by the GLBA. It is personally identifiable financial information (i) that you provide to obtain a financial product or service from or through Ledn US , (ii) that results from your transactions with or through us, or (iii) that we otherwise obtain in connection with or by providing access to financial products and services to you. NPI is governed primarily by the GLBA and our GLBA Privacy Notice.

Non-personal information. Non-personal information does not directly or indirectly reveal your identity or directly relate to an identifiable individual. Examples of non-personal information are de-identified, statistical or aggregate data. De-identified, statistical or aggregated data does not directly identify a specific person, but we may derive such data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific page on our website. Where we maintain de-identified information, we will take reasonable measures to ensure the information cannot be associated with an individual, will maintain and use it only in de-identified form, and will not attempt to re-identify it.

3. How does Ledn US collect information about you?

3.1. Overview – Sources of Information

Ledn US uses three methods to collect your information.

First, we collect information you provide directly, for example when you apply for a loan or open an account, fill in forms, or correspond with Ledn US by phone, email, videocall, instant messaging app or otherwise. You also provide information when you interact with Ledn US on public websites, including social media.

Second, we collect information automatically through cookies and similar technologies as you navigate the Platform, including usage details, IP addresses and device information.

Third, we collect information about you from third parties, as required or permitted by applicable law. Third-party sources may include public databases, identity verification and fraud prevention partners, sanctions and screening providers, blockchain analytics providers, financial institutions and virtual asset service providers (“VASPs”) that send transfers to your Ledn US account, Travel Rule messaging providers, our affiliates, referral and channel partners, and social media platforms. We also receive personal information when you link a third-party service to your Ledn US account.

3.2. Information you provide to Ledn US

To establish an account, apply for a loan and access Ledn US’s Services, we will ask you to provide information about yourself. Some information is required by law (e.g., to verify your identity under federal or state law), some is necessary to provide the requested services (e.g., the wallet address you wish to link to your account), and some is relevant for the specific purposes described in Section 4. As we add new features, you may be asked to provide additional information. We may also ask you to confirm the information you previously provided if you make an unusual transaction or request.

We may not be able to serve you, or may have to close your account, if you choose not to share certain required information. Any information you provide that is not required is voluntary, for example designating beneficiaries or safelisting wallet addresses.

We may collect the following types of information from you:

1. Personal identification information: such as your full legal name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, information about family members, and email.
2. Formal identification information: including government-issued identity documents such as a passport, driver’s license or state identity card, Social Security number or Individual Taxpayer Identification Number, visa or immigration information, and any other information necessary to comply with our legal obligations under financial, anti-money laundering or counter-terrorist financing laws.
3. Biometric information: during identity verification, our identity verification provider may ask you to take a photograph or short video of your face (a “selfie”) so that it can be compared with your identity document and checked for liveness. This process may generate a facial geometry scan.
4. Employment and financial information: including employer, occupation, industry, job title, income, source of funds and source of wealth, and other information relevant to loan underwriting or required by law.
5. Account and transaction information: including bank account information, payment card information, digital asset wallet addresses, loan applications, loan terms, collateral, repayment, liquidation and top-up history, transaction history, trading data, and information about transactions you make or intend to make.
6. Communications: including the content of your emails, chat messages, support tickets, survey responses, and recordings of telephone or video calls, to which you consent in the Terms of Service.
7. Other information: Ledn US’s compliance team may request additional information as required by law, regulation or Ledn US’s internal policies, including information relating to travel history, relationship/marital status, and criminal convictions or charges.
8. Transfer information: when you deposit digital assets to, or withdraw them from, your account, information about the transfer, including the external account or wallet address, the name of any financial institution or virtual asset service provider (“VASP”) that holds it, and information confirming that you own or control it (for example, an attestation, a signed message or a test transaction).

3.3. Information Ledn US collects through cookies 

As you navigate through and interact with our website, we use cookies and other automatic data collection technologies to collect certain information about you, your equipment, browsing actions, and patterns, including details of your visits to our website, traffic data, location data, logs, information about your computer and internet connection, including your IP address, operating system, and browser type and other communication data and the resources that you access and use on the website.

Cookies (or browser cookies) are small text files sent from a site to the hard drive of your device (e.g., computer or phone) to store bits of information related to you. First-party cookies are put on your device directly by Ledn US’s website, which allows us to collect analytical data and provide other useful functions that create a good user experience.

Third-party cookies are placed on your device by a third party (e.g., advertiser or analytic system). The third parties who serve cookies on our site may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information. Examples of such third-party cookies that Ledn US’s website may use are Facebook, Twitter, LinkedIn, Google and Bing. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of Ledn US’s website. Unless you have adjusted your browser setting so that it will refuse cookies, Ledn US’s system will issue cookies when you visit Ledn US’s website.

Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the website quicker, easier and smoother.

Certain features of our website may use local stored objects (sometimes referred to as flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings that are used for browser cookies.

Pages of our website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow Ledn US, among other things, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

3.4. Third-party cookies and targeted advertising

Some content or applications on the Platform may be served by third parties, including advertisers, ad networks, content providers and application providers. These third parties may use cookies, alone or with web beacons or other tracking technologies, to collect information about your online activities over time and across different websites. They may use this information to provide you with interest-based (targeted) advertising. Under some state laws, allowing these third parties to collect information on the Platform may be considered “targeted advertising” or “sharing” and, in some cases, a “sale”. You can opt out as described in Section 9.2.

3.5. Publicly available information

Anyone can see the balance and transaction history of any public digital asset address (public key). Ledn US, and any other person who can match your digital asset address to other information about you, may be able to identify you from a blockchain transaction. This is because information published on a blockchain can be correlated with information that Ledn US and others may have. This may be the case even if Ledn US, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other information about you. As part of Ledn US’s security, anti-fraud and/or identity verification and authentication checks, Ledn US may conduct such analysis to collect and process such information about you. You acknowledge and agree to allow Ledn US to perform such practices.

3.6. Online tracking and do not track signals

We may, and we may allow third party service providers to, use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of our website. Our website currently does not respond to “do not track” signals and operates as described in this Policy whether or not a “do not track” signal is received. If we do respond to “do not track” signals in the future, we will describe how we do so in an updated version of this Policy. 

3.7. Children

Our services are not intended for persons under the age of 18 (or the age of majority in your state). We do not knowingly collect personal information from such persons and do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. If we learn that we have inadvertently collected personal information from a minor, we will take legally permissible measures to delete that information and will require the account to be closed. If you are the parent or guardian of a minor and you become aware that he or she has provided personal information to Ledn US, please contact us at privacy@ledn.io.

4. Why does Ledn US collect your information and how does Ledn use it?

We collect and use personal information to provide you with our products and services, protect you from fraud and misuse, comply with legal and regulatory obligations, and maintain and improve our services. 

4.1. To maintain legal and regulatory compliance

Most of our services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, we must identify and verify customers using our services in order to comply with anti-money laundering and counter terrorism financing laws across the jurisdictions in which Ledn US operates. This may include the collection and storage of your photo identification and other documents you provide to us.

In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. We may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we may have to close your account.

The Bank Secrecy Act’s “Travel Rule” and similar laws in other countries also require us to collect, verify and keep information about the sender and recipient of transfers, including digital asset transfers and transfers between your own accounts. We compare the information we receive about a transfer with the information we hold, and we may keep information about a sender or recipient who is not our customer. See Section 5.5 for the information we share with other institutions..

4.2. To protect you and Ledn US

We process your personal information to administer and protect our business, prevent and mitigate fraud, criminal activity or misuse of our services, ensure the security of our systems, architecture and networks, and protect you against account compromise or loss of funds.

4.3. To enforce the terms of Ledn US’s agreements

We process your personal information to monitor, investigate, prevent and mitigate potentially prohibited or illegal activities, enforce our agreements with you and third parties, prevent and detect violations of our terms of service, and collect fees based on your use of our services.

4.4. To provide you with Services 

We process your personal information to provide our Services to you. For example, when you want to store digital assets through our platform, we require certain information such as your identification, contact information, and payment information. We generally cannot provide you with Services without such information. Third parties such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services.

4.5. To keep you informed

We send administrative and account-related communications to keep you updated about our Services, inform you of relevant security issues or updates, and provide other transaction-related information. You may not opt out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

4.6. To provide customer service and support and for quality control

We process your personal information when you contact us to resolve questions or disputes, collect fees, or troubleshoot problems. We also process your personal information for quality control and staff training.

4.7. To engage in marketing and promotional activities

We may send you marketing communications (e.g., emails or mobile notifications) about Ledn Group products and events, partner events and promotional offers, and may deliver targeted advertising. Our marketing will be conducted in accordance with your marketing preferences and applicable law.

4.8. To enhance your experience and for development purposes

We process your personal information to understand how you use and interact with our Services, and to customize, measure and improve our services and develop new services. Where possible, we use de-identified or aggregated information for these purposes.

5. With whom does Ledn US share your information, and why?

5.1. Ledn Group affiliates

Ledn US is a wholly-owned subsidiary of 21 Technologies Inc. (“21 Tech”). In this Policy, 21 Tech and their other subsidiaries are together referred to as the “Ledn Group”. 

We share personal information within the Ledn Group, including 21 Tech, to provide and support our services, operate shared systems and customer support, carry out group-wide compliance, fraud prevention and risk management, and, as permitted by law, market our products to you.

5.2. Service providers

We share personal information with service providers that perform services on our behalf, under written contracts that restrict their use of the information to the services they provide to us and require them to protect it. These include providers of identity verification and fraud prevention, sanctions and adverse media screening, blockchain analytics and cryptocurrency forensic analysis, Travel Rule messaging, digital asset custody and liquidity, cryptocurrency exchanges, banking and payment processing, loan servicing and collections, cloud storage and data hosting, authentication, customer support and communications, marketing and analytics, proof-of-reserves attestations, audit, accounting, legal and regulatory compliance services.

5.3. Regulatory and government authorities

We share personal information with law enforcement, regulators (including the state regulators that license Ledn US and the Financial Crimes Enforcement Network) and other government authorities to help prevent fraud, for legal proceedings, or as otherwise required by law. We are also legally obligated to report certain suspicious transactions.

5.4. Transactions you request or authorize

We share personal information as necessary to process transactions you request or authorize, including with financial institutions, payment processors and digital asset networks, and with persons you authorize to act on your behalf (such as an authorized agent, attorney, or a beneficiary you designate).

5.5. Counterparty Institutions and the Travel Rule

We share personal information, such as your name, address, account or wallet address, with the financial institution or VASP that sends a transfer to, or receives a transfer from, your Ledn US account, as required or permitted by the Bank Secrecy Act and other applicable law. These recipients may be located outside the United States and will handle the information in accordance with their own legal obligations and privacy policies.

5.6. To protect legal rights

We may disclose personal information to protect our legal rights and those of our customers, including to establish, exercise or defend legal claims, and to collect amounts owed upon account closure where you have a deficient balance.

5.7. Corporate transactions and loan sales

We may share or transfer personal information, in accordance with applicable law, in connection with a merger, acquisition, financing, reorganization, sale of loans or other assets, or similar transaction, including to a buyer of all or substantially all of our business or assets. Any successor may continue to collect, use and disclose your information as set out in this Policy. We may also share information about loans we originate and/or purchase from third parties with investors, lenders, trustees, rating agencies and their agents in connection with the sale, securitization or financing of those loans. 

6. Where does Ledn US store and process your personal information?

We may transfer your personal information outside the United States to our affiliates, service providers and business partners engaged on our behalf. When we do, we will ensure that the transfer is lawful and that all recipients are obliged to comply with applicable laws, rules and regulations.

In addition, when you transfer digital assets to or from your Ledn US account, we may be required by law to send your personal information to the financial institution or VASP on the other side of that transfer (if any), which may be located outside the United States. That institution will handle the information in accordance with the laws that apply to it and its own privacy policy.

7. How does Ledn US protect your personal information?

We are strongly committed to keeping your personal information safe, throughout the lifecycle of your data and starting with the design of our services. We protect your personal information by maintaining physical, electronic and procedural safeguards in compliance with applicable laws and regulations. For example, we use firewalls and data encryption, enforce physical access controls, and authorize access to personal information only for those personnel who require it to fulfill their job responsibilities.

Protection of Social Security numbers. Ledn US protects the confidentiality of Social Security numbers it collects. Ledn US limits access to Social Security numbers to personnel and service providers with a legitimate business need, prohibits their unlawful disclosure, does not publicly post or display them, does not print them on cards or mailings except as required by law, does not require you to transmit them over the internet unless the connection is secure or the number is encrypted, and disposes of documents containing them securely.

However, no system is completely secure, and we cannot guarantee that loss, misuse, unauthorized acquisition or alteration of your data will not occur. You play a vital role in protecting your own personal information. Choose a password of sufficient length and complexity, enable multi-factor authentication, do not reveal your password to anyone, and notify us immediately if you become aware of any unauthorized access to or use of your account.

8. Ledn US’s data retention policy

We keep each category of personal information described in this Policy, including the categories listed in Section 10.1, only as long as reasonably necessary for the purposes described in this Policy. To decide how long, we consider: the purpose for which the information was collected; whether we have an ongoing relationship with you; legal, regulatory and record-keeping requirements; whether the information is needed to prevent fraud or protect security; and any legal hold or actual or anticipated claim. 

If you close your Ledn Account, we will mark your account in our database as “closed,” but will keep your account information in our database in accordance with our retention policy. If you require more information about Ledn US’s retention policy please contact us at privacy@ledn.io. This is necessary in order to deter fraud and to ensure that we meet all of our legal and regulatory obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Policy.

9. Your privacy choices

The choices in this Section are available to Ledn US customers and Platform users in the United States. The marketing choices in Section 9.1 are available regardless of your state of residence. The choices in Section 9.2 are available depending on your state of residency.

9.1. Marketing communications

You may opt out of marketing emails at any time by using the “unsubscribe” link in the email or by contacting privacy@ledn.io. You may opt out of marketing push notifications through your device settings. Opting out of marketing does not affect transactional, account, security, or legal and regulatory communications.

9.2. Targeted advertising, cookies and opt-out preference signals

You may opt out of the use of third-party advertising cookies and pixels on the Platform (which may be considered targeted advertising, “sharing” or a “sale” under some state laws) by contacting privacy@ledn.io. 

10. U.S. state privacy rights

Residents of certain U.S. states have the rights described in this Section with respect to personal information collected and processed under their state privacy laws. These laws do not apply to personal information governed by the GLBA and our GLBA Privacy Notice. 

10.1. Personal Information we collect and disclose

The table below describes the categories of Personal Information (as defined in Section 2) that Ledn US has collected in the past 12 months.

AS A COURTESY, THE DISCLOSURES IN THIS SECTION INCLUDE INFORMATION THAT IS EXEMPT FROM STATE PRIVACY LAWS, INCLUDING INFORMATION COVERED BY THE GLBA. THE STATE PRIVACY RIGHTS DESCRIBED IN SECTION 10.2, INCLUDING THE RIGHT TO DELETE, DO NOT APPLY TO EXEMPT INFORMATION. THESE COURTESY DISCLOSURES ARE MADE WITH A RESERVATION OF ALL RIGHTS LEDN US HAS UNDER APPLICABLE STATE PRIVACY LAWS.

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Sources. We obtain this information from the sources described in Section 3.1.

Purposes. We use this information for the purposes described in Section 4, including to deliver targeted advertising unless you opt-out. 

Disclosure of personal information.

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Sale and sharing. We will never sell or rent your personal information to third parties for money, and we do not sell or share NPI for targeted advertising. However, the use of third-party advertising cookies and pixels on the Platform (see Section 3.4) may be treated as a "sale," "sharing" or "targeted advertising" under certain state laws. The categories of personal information sold or shared with advertising partners in the past 12 months: A (online identifiers only), D, F and K. You may opt out as described in Section 9.2.

Retention. We retain each category of personal information listed above as described in Section 8.

10.2. Your rights

Depending on your state of residency, and subject to the exceptions and limitations described above, you may have the following rights. Not every right is available in every state, and the scope of a right may differ depending on your state of residency. If a right is not available to you under the law of your state, we will tell you when we respond to your request.

• Right to Know: You have the right to request that we disclose certain information to you about our collection, use and disclosure of your personal information (a “Request to Know”). Once we receive and verify your Request to Know, we will, depending on your state of residency, confirm whether we process your personal information and disclose to you the specific pieces of personal information we have collected about you, in a portable format; the categories of personal information we have collected about you; the categories of sources from which it was collected; the business or commercial purposes for collecting, selling or sharing it; and the categories of third parties (or, where required, the specific third parties) to which we have disclosed, sold or shared it. 
• Right to Correct: You have the right to request that we correct your inaccurate personal information (a “Request to Correct”). Once we receive and verify your Request to Correct, we will use commercially reasonable efforts to correct your inaccurate personal information in our records.
• Right to Delete: You have the right to request that we delete your personal information (a “Request to Delete”). Once we receive and verify your Request to Delete, we will delete your Personal Information from our records unless an exception or exemption applies.
• Right to Opt Out: Depending on your state of residency, you have the right to opt out of (1) the sale of your personal information and (2) the sharing of your personal information for cross-context behavioral advertising, or its use for targeted advertising (a “Request to Opt Out”). You may submit a Request to Opt Out of sale, sharing or targeted advertising as described in Section 9.2. We do not need to verify a Request to Opt Out and will act on it as soon as feasibly possible. 
• Right to Opt Out of Automated Decision-Making and Profiling: Depending on your state of residency, you may have the right to opt out of the use of automated decision-making technology or profiling to make decisions that produce legal or similarly significant effects concerning you, such as decisions about your economic situation, reliability or access to financial or lending services. We do not use automated decision-making technology or profiling for these purposes with personal information that is not exempt under the GLBA or CalFIPA.
• Right to Appeal: Depending on your state of residency, you have the right to appeal a decision by us not to act on your Request to Know, Request to Correct, Request to Delete or Request to Opt Out (an “Appeal”). You may submit an Appeal as described in Section 10.3. We will review your Appeal in light of applicable law and notify you in writing of our decision and the reasons for it.
• Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of these rights. Unless permitted by applicable state privacy laws, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Depending on your state of residency, you may have the right to limit our use of your sensitive personal information, or we may need your consent before processing it. We use sensitive personal information only for purposes permitted by law, such as providing the services you request, verifying your identity, preventing fraud and security incidents, and complying with legal obligations. Where required by law, we process sensitive personal information only with your consent. We do not collect, use or sell personal information for the purpose of training large language models.

10.3. How to exercise your rights

Submitting a request. To submit a Request to Know, Request to Correct or Request to Delete, email privacy@ledn.io. To submit a Request to Opt Out of sale, sharing or targeted advertising, see Section 9.2.

Verification. To protect your information, we may verify your identity before responding to a Request to Know, Request to Correct or Request to Delete. We may ask you to log in to your account or to provide information that matches what we already hold, and may use any information you provide only for verification. We do not need to verify a Request to Opt Out but may deny one we reasonably believe is fraudulent.

Authorized agents. You may use an authorized agent to submit a request on your behalf. We may require the agent to provide your signed written permission and may ask you to verify your identity directly, unless the agent holds a valid power of attorney.

Limits on requests. We may deny or limit a request where a legal exception applies, for example where the information is covered by the GLBA, or where we must keep it under the Bank Secrecy Act or state licensing laws. If we deny a request, we will explain why.

Appeals. Depending on your state of residency, you may submit an Appeal by emailing privacy@ledn.io. We will respond to your Appeal as described in Section 10.2.

11. Changes to this Policy

This Policy is reviewed at least annually and updated to reflect new legal obligations, new technologies, and changes to our business operations and practices. The “Last updated” date at the top of this Policy shows when it was last revised. We will notify you of material changes by posting the updated Policy on the Platform and, where required by law, by email or in-app notice before the change takes effect. Where a change involves processing your personal information for a new purpose that requires your consent, we will obtain that consent first.

12. Contact Ledn US

We would like to hear from you if you have questions, comments or complaints about this Policy or our privacy practices.

• Email: privacy@ledn.io
• Mail: Ledn US LLC, Attn: US Compliance, 860 Broadway, 5^th Floor, New York, NY 10003
• Accessibility: this Policy is available in an alternative format on request to privacy@ledn.io.

We are committed to resolving complaints about our processing of your personal information fairly. If you are not satisfied with our response, you may contact the consumer protection division of your state Attorney General or the state financial regulator that licenses Ledn US in your state.

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