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Privacy Policy

Last Update Date: 03 November 2023

Effective Date: 03 November 2023

This Privacy Policy describes how Pauzible UK Limited of 72 Cannon Street LondonEC4N 6AE, and with England and Wales company registration number 15084663,telephone number 020 8865 3352, email address [email protected] and website address www.pauzible.com, and its related companies, affiliates, and subsidiaries (collectively, as used herein, "we," "us," and" our") collect, use, and share your information when you visit our website located at www.pauzible.com and any of our other websites (our "Websites"), use our mobile applications, if any (our "Apps"), interact with our application programme interfaces and other services we make to interact with you through social networks (such social networks, "Social Networks"), our services that interact with Social Networks, "Social Network Services"), or use other services (our Websites, Apps, Social Network Services and related services are collective your "Services"). This Privacy Policy does not apply to any websites or applications that we do not operate or other websites that have their own privacy policies, including Social Networks. By visiting or using any of our Services, you are consenting to the practices described in this Privacy Policy.

The type of personal information (“Personal Information”) we collect

We currently collect or intend to collect and process the following information:

  1. Name
  2. Address
  3. Telephone number
  4. Email address
  5. Username and password
  6. Age
  7. Employment
  8. Income
  9. Assets
  10. Liabilities
  11. Credit reports
  12. Proof of identity
  13. Pay slips
  14. Tax returns
  15. P&L and Balance sheet for business for the last three years
  16. Bank statements
  17. Mortgage statements
  18. Property register
  19. Deed of purchase
  20. Proof of making timely payment of council taxes, insurance payments, utility bills, maintenance, building service charges, ground rents or any items that may rank pari-passu with or higher than a mortgage
  21. Any other information you choose to provide us

We may also collect certain information related to you and your activities on our websites when you visit the websites. This information may include but is not limited to your IP address, your internet browser and operating system type, the date and time of your visit, and the website that referred you to us (refer to “Use of Cookies and Analytical Tools" for more information about information collected by cookies and similar tracking technologies).

In accordance with your device permissions, we may collect information about the precise location of your device.

Use of Cookies and Analytical Tools

We (and third parties who perform work for us) may use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

Some definitions:

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

For example, our apps may include software development kits (known as SDKs) which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you additional functionality.

How we get the Personal Information and why we have it

We collect Personal Information from you directly through our Services (for example, when you create an account on our websites or Apps, fill out a form or otherwise submit content through our services) and by communicating directly with you by telephone, by email, by any other communication channels broadly used and by using our embedded chat messaging system.

Most of the Personal Information we process is provided to us directly by you for the following reasons:

  1. Help us assess if we might be able to assist you.

                  Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

                    (a) We have a legitimate interest.

                    Any references to products and services are intended to imply those that may be available now or in the future. Your eligibility for these particular products and services shall be subject to our final determination, restrictions, and acceptance. We may discontinue or make changes to the information, products, licenses, or services described on this website at any time. Any dated information is published as of its publication date only. We do not undertake any obligation or responsibility to update or amend any such information. We reserve the right to terminate any or all offerings without prior notice. Furthermore, by offering information, products, or services via our website, no solicitation is made by us to any person to use such information, products, or services in jurisdictions where the provision of information, products, or services is prohibited by law.

  1. Provide you with customer service.

                  Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

                    (a) We have a contractual obligation.

                    (b) We have a legitimate interest.

  1. Communicate with you about our Services and products, about our company, and about your account generally.

                  Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

                    (a) We have a contractual obligation.

                    (b) We have a legitimate interest.

  1. Help us assess if you are a suitable candidate for a role

                  Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

                    (a) We have a legitimate interest.

                    We also receive personal information indirectly, from the following sources in the following scenarios:

Use of Cookies and Analytical Tools

We (and third parties who perform work for us) may use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

Some definitions:

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or" clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

For example, our apps may include software development kits (known as SDKs) which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you additional functionality.

In accordance with your device permissions, we may collect information about the precise location of your device.

As part of our process, we carry out credit and identity checks with credit reference agencies.  We submit your personal information to them and they send us information based, for example, on your credit applications, including things about your financial situation and financial history.

We use the above information to:

  1. Verify the accuracy of the information you have given us

                    Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Mitigate against criminal activity, money laundering and fraud

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Assess your creditworthiness

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Personalize the Services to you, including in communications to you through our Social Network Services and in advertising through our Services and through third-party services (including advertising on other websites that we do not operate). If you give us permission on your mobile device, we may send you promotional and non-promotional "push" notifications to your mobile devices about our Services and products available on our Services.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Improve the security of our Services and to anticipate and respond to unauthorized, fraudulent, or unlawful activity.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

How we share Personal Information

We may share your Personal Information with our employees, independent contractors, and any parent, subsidiary, or affiliated business entity.

We may share your Personal Information with a Principal entity, which is regulated by the FCA, of which we are an Introducer Appointed Representative.

We may share your Personal Information with third-party vendors, consultants and service providers (collectively “Third-Party Service Providers”) in the following circumstances:

We may share your Personal Information with Third-Party Service Providers that access Personal Information to perform services for us.

We may disclose Personal Information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

We may share Personal Information if we believe (1) that your actions are inconsistent with our user agreements or policies, (2) that you have violated the law, or (3) it's necessary to protect the rights, property and safety of our users, the public, or others.

We share Personal Information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

We may share Personal Information in connection with, or during negotiations concerning, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

We share Personal Information with your consent or at your direction, including but not limited to, through third-party integrations you choose to enable.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

We limit the information that we share to third-party service providers, and require that our third-party service providers only uses hared Personal Information to perform the services requested in accordance with this Privacy Policy and have adequate security measures in place to protect any of your shared Personal Information.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting Pauzible UK Limited, 72 Cannon Street London EC4N 6AE.Telephone number 020 8865 3352. Email address [email protected]

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We have a legitimate interest.

Right to Access to and Control Over Information

You may have certain rights under applicable data protection law with respect to Personal Information about you that is collected through our services and our websites, or when you contact or otherwise engage with us. You also have the right to opt-out of receiving electronic direct marketing communications from us.

However, we may retain Personal Information as authorized under applicable law, such as Personal Information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.

We require certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

You may email us at [email protected] to exercise any of these rights. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request.

We will hold your information to contact you about our products and services and to improve your experience. We may also contact you to request updated details.

Dependant on the data you provide us and for what purpose it is provided we may need to retain your data for up to six years after you are no longer a customer with us.

Links to Other Websites

The Services and websites may contain links to third-party websites and other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site.

This Privacy Policy is only applicable to our Services. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

We strongly advise you to review the Privacy Policy ofevery site you visit.

Security

We are committed to protecting your Personal Information. All of our operational and data processing systems are in a secure environment that protects your information from unauthorized access, use or disclosure.

Children's Privacy

This Website is not intended for persons under the age of 18. We do not knowingly collect, maintain, or use Personal Information from children under the age of 13. If we become aware that we have collected Personal Information from a child under 13, we will take steps to delete such information as soon as possible.

Updates to this Privacy Policy

We may change this Privacy Policy from time to time. If we change this Privacy Policy, we will post the updated version on this website and update the "Last Updated" date above.

Contact information

If you have questions regarding this Privacy Policy, please contact us at:

Pauzible UK Limited

72 Cannon Street London EC4N 6AE

[email protected]

020 8865 3352

Please note that we may need to verify your identity before processing certain requests.

Changes to this Notice

We may update this Notice from time to time.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at Pauzible UK Limited, 72 Cannon Street London EC4N 6AE. Telephone number 020 8865 3352. Email address [email protected] if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at

Pauzible UK Limited, 72 Cannon Street London EC4N 6AE. Telephone number 020 8865 3352. Email address [email protected].

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office

Wy cliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Last Update Date: 03 November 2023

Effective Date: 03 November 2023

This Privacy Policy describes how Pauzible UK Limited of 72 Cannon Street LondonEC4N 6AE, and with England and Wales company registration number 15084663,telephone number 020 8865 3352, email address [email protected] and website address www.pauzible.com, and its related companies, affiliates, and subsidiaries (collectively, as used herein, "we," "us," and" our") collect, use, and share your information when you visit our website located at www.pauzible.com and any of our other websites (our "Websites"), use our mobile applications, if any (our "Apps"), interact with our application programme interfaces and other services we make to interact with you through social networks (such social networks, "Social Networks"), our services that interact with Social Networks, "Social Network Services"), or use other services (our Websites, Apps, Social Network Services and related services are collective your "Services"). This Privacy Policy does not apply to any websites or applications that we do not operate or other websites that have their own privacy policies, including Social Networks. By visiting or using any of our Services, you are consenting to the practices described in this Privacy Policy.

The type of personal information (“Personal Information”) we collect

We currently collect or intend to collect and process the following information:

  1. Name
  2. Address
  3. Telephone number
  4. Email address
  5. Username and password
  6. Age
  7. Employment
  8. Income
  9. Assets
  10. Liabilities
  11. Credit reports
  12. Proof of identity
  13. Pay slips
  14. Tax returns
  15. P&L and Balance sheet for business for the last three years
  16. Bank statements
  17. Mortgage statements
  18. Property register
  19. Deed of purchase
  20. Proof of making timely payment of council taxes, insurance payments, utility bills, maintenance, building service charges, ground rents or any items that may rank pari-passu with or higher than a mortgage
  21. Any other information you choose to provide us

We may also collect certain information related to you and your activities on our websites when you visit the websites. This information may include but is not limited to your IP address, your internet browser and operating system type, the date and time of your visit, and the website that referred you to us (refer to “Use of Cookies and Analytical Tools" for more information about information collected by cookies and similar tracking technologies).

In accordance with your device permissions, we may collect information about the precise location of your device.

Use of Cookies and Analytical Tools

We (and third parties who perform work for us) may use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

Some definitions:

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

For example, our apps may include software development kits (known as SDKs) which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you additional functionality.

How we get the Personal Information and why we have it

We collect Personal Information from you directly through our Services (for example, when you create an account on our websites or Apps, fill out a form or otherwise submit content through our services) and by communicating directly with you by telephone, by email, by any other communication channels broadly used and by using our embedded chat messaging system.

Most of the Personal Information we process is provided to us directly by you for the following reasons:

  1. Help us assess if we might be able to assist you.

            Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

Any references to products and services are intended to imply those that may be available now or in the future. Your eligibility for these particular products and services shall be subject to our final determination, restrictions, and acceptance. We may discontinue or make changes to the information, products, licenses, or services described on this website at any time. Any dated information is published as of its publication date only. We do not undertake any obligation or responsibility to update or amend any such information. We reserve the right to terminate any or all offerings without prior notice. Furthermore, by offering information, products, or services via our website, no solicitation is made by us to any person to use such information, products, or services in jurisdictions where the provision of information, products, or services is prohibited by law.

  1. Provide you with customer service.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) We have a contractual obligation.

(b) We have a legitimate interest.

  1. Communicate with you about our Services and products, about our company, and about your account generally.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) We have a contractual obligation.

(b) We have a legitimate interest.

  1. Help us assess if you are a suitable candidate for a role

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

We also receive personal information indirectly, from the following sources in the following scenarios:

Use of Cookies and Analytical Tools

We (and third parties who perform work for us) may use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

Some definitions:

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or" clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

For example, our apps may include software development kits (known as SDKs) which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you additional functionality.

In accordance with your device permissions, we may collect information about the precise location of your device.

As part of our process, we carry out credit and identity checks with credit reference agencies.  We submit your personal information to them and they send us information based, for example, on your credit applications, including things about your financial situation and financial history.

We use the above information to:

  1. ·       Verify the accuracy of the information you have given us

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Mitigate against criminal activity, money laundering and fraud

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Assess your creditworthiness

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Personalize the Services to you, including in communications to you through our Social Network Services and in advertising through our Services and through third-party services (including advertising on other websites that we do not operate). If you give us permission on your mobile device, we may send you promotional and non-promotional "push" notifications to your mobile devices about our Services and products available on our Services.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Improve the security of our Services and to anticipate and respond to unauthorized, fraudulent, or unlawful activity.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

How we share Personal Information

We may share your Personal Information with our employees, independent contractors, and any parent, subsidiary, or affiliated business entity.

We may share your Personal Information with third-party vendors, consultants and service providers (collectively “Third-Party Service Providers”) in the following circumstances:

We may share your Personal Information with Third-Party Service Providers that access Personal Information to perform services for us.

We may disclose Personal Information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

We may share Personal Information if we believe (1) that your actions are inconsistent with our user agreements or policies, (2) that you have violated the law, or (3) it's necessary to protect the rights, property and safety of our users, the public, or others.

We share Personal Information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

We may share Personal Information in connection with, or during negotiations concerning, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

We share Personal Information with your consent or at your direction, including but not limited to, through third-party integrations you choose to enable.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

We limit the information that we share to third-party service providers, and require that our third-party service providers only uses hared Personal Information to perform the services requested in accordance with this Privacy Policy and have adequate security measures in place to protect any of your shared Personal Information.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting Pauzible UK Limited, 72 Cannon Street London EC4N 6AE.Telephone number 020 8865 3352. Email address [email protected]

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We have a legitimate interest.

Right to Access to and Control Over Information

You may have certain rights under applicable data protection law with respect to Personal Information about you that is collected through our services and our websites, or when you contact or otherwise engage with us. You also have the right to opt-out of receiving electronic direct marketing communications from us.

However, we may retain Personal Information as authorized under applicable law, such as Personal Information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.

We require certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

You may email us at [email protected] to exercise any of these rights. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request.

We will hold your information to contact you about our products and services and to improve your experience. We may also contact you to request updated details.

Dependant on the data you provide us and for what purpose it is provided we may need to retain your data for up to six years after you are no longer a customer with us.

Links to Other Websites

The Services and websites may contain links to third-party websites and other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site.

This Privacy Policy is only applicable to our Services. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

We strongly advise you to review the Privacy Policy ofevery site you visit.

Security

We are committed to protecting your Personal Information. All of our operational and data processing systems are in a secure environment that protects your information from unauthorized access, use or disclosure.

Children's Privacy

This Website is not intended for persons under the age of 18. We do not knowingly collect, maintain, or use Personal Information from children under the age of 13. If we become aware that we have collected Personal Information from a child under 13, we will take steps to delete such information as soon as possible.

Updates to this Privacy Policy

We may change this Privacy Policy from time to time. If we change this Privacy Policy, we will post the updated version on this website and update the "Last Updated" date above.

Contact information

If you have questions regarding this Privacy Policy, please contact us at:

Pauzible UK Limited

72 Cannon Street London EC4N 6AE

[email protected]

020 8865 3352

Please note that we may need to verify your identity before processing certain requests.

Changes to this Notice

We may update this Notice from time to time.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at Pauzible UK Limited, 72 Cannon Street London EC4N 6AE. Telephone number 020 8865 3352. Email address [email protected] if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at

Pauzible UK Limited, 72 Cannon Street London EC4N 6AE. Telephone number 020 8865 3352. Email address [email protected].

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office

Wy cliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Last Update Date: 03 November 2023

Effective Date: 03 November 2023

This Privacy Policy describes how Pauzible UK Limited of 72 Cannon Street LondonEC4N 6AE, and with England and Wales company registration number 15084663,telephone number 020 8865 3352, email address [email protected] and website address www.pauzible.com, and its related companies, affiliates, and subsidiaries (collectively, as used herein, "we," "us," and" our") collect, use, and share your information when you visit our website located at www.pauzible.com and any of our other websites (our "Websites"), use our mobile applications, if any (our "Apps"), interact with our application programme interfaces and other services we make to interact with you through social networks (such social networks, "Social Networks"), our services that interact with Social Networks, "Social Network Services"), or use other services (our Websites, Apps, Social Network Services and related services are collective your "Services"). This Privacy Policy does not apply to any websites or applications that we do not operate or other websites that have their own privacy policies, including Social Networks. By visiting or using any of our Services, you are consenting to the practices described in this Privacy Policy.

The type of personal information (“Personal Information”) we collect

We currently collect or intend to collect and process the following information:

  1. Name
  2. Address
  3. Telephone number
  4. Email address
  5. Username and password
  6. Age
  7. Employment
  8. Income
  9. Assets
  10. Liabilities
  11. Credit reports
  12. Proof of identity
  13. Pay slips
  14. Tax returns
  15. P&L and Balance sheet for business for the last three years
  16. Bank statements
  17. Mortgage statements
  18. Property register
  19. Deed of purchase
  20. Proof of making timely payment of council taxes, insurance payments, utility bills, maintenance, building service charges, ground rents or any items that may rank pari-passu with or higher than a mortgage

Any other information you choose to provide us

We may also collect certain information related to you and your activities on our websites when you visit the websites. This information may include but is not limited to your IP address, your internet browser and operating system type, the date and time of your visit, and the website that referred you to us (refer to “Use of Cookies and Analytical Tools" for more information about information collected by cookies and similar tracking technologies).

In accordance with your device permissions, we may collect information about the precise location of your device.

Use of Cookies and Analytical Tools

We (and third parties who perform work for us) may use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

Some definitions:

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

For example, our apps may include software development kits (known as SDKs) which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you additional functionality.

How we get the Personal Information and why we have it

We collect Personal Information from you directly through hour Services (for example, when you create an account on our websites or Apps, fill out a form or otherwise submit content through our services) and by communicating directly with you by telephone, by email, by any other communication channels broadly used and by using our embedded chat messaging system.

Most of the Personal Information we process is provided to us directly by you for one of the following reasons:

  1. Help us assess if we might be right for you.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

Any references to products and services are intended to imply those that may be available in future. Your eligibility for these particular products and services shall be subject to our final determination, restrictions, and acceptance. We may discontinue or make changes to the information, products, licenses, or services described on this website at any time. Any dated information is published as of its publication date only. We do not undertake any obligation or responsibility to update or amend any such information. We reserve the right to terminate any or all offerings without prior notice. Furthermore, by offering information, products, or services via our website, no solicitation is made by us to any person to use such information, products, or services in jurisdictions where the provision of information, products, or services is prohibited by law.

  1. Provide you with customer service.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) We have a contractual obligation.

(b) We have a legitimate interest.

  1. Communicate with you about our Services and products, about our company, and about your account generally.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) We have a contractual obligation.

(b) We have a legitimate interest.

  1. Help us assess if you are a suitable candidate for a role

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

We also receive personal information indirectly, from the following sources in the following scenarios:

Use of Cookies and Analytical Tools

We (and third parties who perform work for us) may use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

Some definitions:

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or" clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

For example, our apps may include software development kits (known as SDKs) which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you additional functionality.

In accordance with your device permissions, we may collect information about the precise location of your device.

As part of our process, we carry out credit and identity checks with credit reference agencies.  We submit your personal information to them and they send us information based, for example, on your credit applications, including things about your financial situation and financial history.

We use the above information to:

  1. ·       Verify the accuracy of the information you have given us

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Mitigate against criminal activity, money laundering and fraud

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Assess your creditworthiness

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Personalize the Services to you, including in communications to you through our Social Network Services and in advertising through our Services and through third-party services (including advertising on other websites that we do not operate). If you give us permission on your mobile device, we may send you promotional and non-promotional "push" notifications to your mobile devices about our Services and products available on our Services.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Improve the security of our Services and to anticipate and respond to unauthorized, fraudulent, or unlawful activity.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

How we share Personal Information

We may share your Personal Information with our employees, independent contractors, and any parent, subsidiary, or affiliated business entity.

We may share your Personal Information with third-party vendors, consultants and service providers (collectively “Third-Party Service Providers”) in the following circumstances:

We may share your Personal Information with Third-Party Service Providers that access Personal Information to perform services for us.

We may disclose Personal Information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

We may share Personal Information if we believe (1) that your actions are inconsistent with our user agreements or policies, (2) that you have violated the law, or (3) it's necessary to protect the rights, property and safety of our users, the public, or others.

We share Personal Information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

We may share Personal Information in connection with, or during negotiations concerning, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

We share Personal Information with your consent or at your direction, including but not limited to, through third-party integrations you choose to enable.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

We limit the information that we share to third-party service providers, and require that our third-party service providers only uses hared Personal Information to perform the services requested in accordance with this Privacy Policy and have adequate security measures in place to protect any of your shared Personal Information.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting Pauzible UK Limited, 72 Cannon Street London EC4N 6AE.Telephone number 020 8865 3352. Email address [email protected]

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We have a legitimate interest.

Right to Access to and Control Over Information

You may have certain rights under applicable data protection law with respect to Personal Information about you that is collected through our services and our websites, or when you contact or otherwise engage with us. You also have the right to opt-out of receiving electronic direct marketing communications from us.

However, we may retain Personal Information as authorized under applicable law, such as Personal Information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.

We require certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

You may email us at [email protected] to exercise any of these rights. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request.

We will hold your information to contact you about our products and services and to improve your experience. We may also contact you to request updated details.

Dependant on the data you provide us and for what purpose it is provided we may need to retain your data for up to six years after you are no longer a customer with us.

Links to Other Websites

The Services and websites may contain links to third-party websites and other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site.

This Privacy Policy is only applicable to our Services. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

We strongly advise you to review the Privacy Policy ofevery site you visit.

Security

We are committed to protecting your Personal Information. All of our operational and data processing systems are in a secure environment that protects your information from unauthorized access, use or disclosure.

Children's Privacy

This Website is not intended for persons under the age of 18. We do not knowingly collect, maintain, or use Personal Information from children under the age of 13. If we become aware that we have collected Personal Information from a child under 13, we will take steps to delete such information as soon as possible.

Updates to this Privacy Policy

We may change this Privacy Policy from time to time. If we change this Privacy Policy, we will post the updated version on this website and update the "Last Updated" date above.

Contact information

If you have questions regarding this Privacy Policy, please contact us at:

Pauzible UK Limited

72 Cannon Street London EC4N 6AE

[email protected]

020 8865 3352

Please note that we may need to verify your identity before processing certain requests.

Changes to this Notice

We may update this Notice from time to time.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at Pauzible UK Limited, 72 Cannon Street London EC4N 6AE. Telephone number 020 8865 3352. Email address [email protected] if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at

Pauzible UK Limited, 72 Cannon Street London EC4N 6AE. Telephone number 020 8865 3352. Email address [email protected].

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office

Wy cliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Last Update Date: 03 November 2023

Effective Date: 03 November 2023

This Privacy Policy describes how Pauzible UK Limited of 72 Cannon Street LondonEC4N 6AE, and with England and Wales company registration number 15084663,telephone number 020 8865 3352, email address [email protected] and website address www.pauzible.com, and its related companies, affiliates, and subsidiaries (collectively, as used herein, "we," "us," and" our") collect, use, and share your information when you visit our website located at www.pauzible.com and any of our other websites (our "Websites"), use our mobile applications, if any (our "Apps"), interact with our application programme interfaces and other services we make to interact with you through social networks (such social networks, "Social Networks"), our services that interact with Social Networks, "Social Network Services"), or use other services (our Websites, Apps, Social Network Services and related services are collective your "Services"). This Privacy Policy does not apply to any websites or applications that we do not operate or other websites that have their own privacy policies, including Social Networks. By visiting or using any of our Services, you are consenting to the practices described in this Privacy Policy.

The type of personal information (“Personal Information”) we collect

We currently collect or intend to collect and process the following information:

  1. Name
  2. Address
  3. Telephone number
  4. Email address
  5. Username and password
  6. Age
  7. Employment
  8. Income
  9. Assets
  10. Liabilities
  11. Credit reports
  12. Proof of identity
  13. Pay slips
  14. Tax returns
  15. P&L and Balance sheet for business for the last three years
  16. Bank statements
  17. Mortgage statements
  18. Property register
  19. Deed of purchase
  20. Proof of making timely payment of council taxes, insurance payments, utility bills, maintenance, building service charges, ground rents or any items that may rank pari-passu with or higher than a mortgage

Any other information you choose to provide us

We may also collect certain information related to you and your activities on our websites when you visit the websites. This information may include but is not limited to your IP address, your internet browser and operating system type, the date and time of your visit, and the website that referred you to us (refer to “Use of Cookies and Analytical Tools" for more information about information collected by cookies and similar tracking technologies).

In accordance with your device permissions, we may collect information about the precise location of your device.

Use of Cookies and Analytical Tools

We (and third parties who perform work for us) may use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

Some definitions:

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

For example, our apps may include software development kits (known as SDKs) which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you additional functionality.

How we get the Personal Information and why we have it

We collect Personal Information from you directly through hour Services (for example, when you create an account on our websites or Apps, fill out a form or otherwise submit content through our services) and by communicating directly with you by telephone, by email, by any other communication channels broadly used and by using our embedded chat messaging system.

Most of the Personal Information we process is provided to us directly by you for one of the following reasons:

  1. Help us assess if we might be right for you.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

Any references to products and services are intended to imply those that may be available in future. Your eligibility for these particular products and services shall be subject to our final determination, restrictions, and acceptance. We may discontinue or make changes to the information, products, licenses, or services described on this website at any time. Any dated information is published as of its publication date only. We do not undertake any obligation or responsibility to update or amend any such information. We reserve the right to terminate any or all offerings without prior notice. Furthermore, by offering information, products, or services via our website, no solicitation is made by us to any person to use such information, products, or services in jurisdictions where the provision of information, products, or services is prohibited by law.

  1. Provide you with customer service.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) We have a contractual obligation.

(b) We have a legitimate interest.

  1. Communicate with you about our Services and products, about our company, and about your account generally.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) We have a contractual obligation.

(b) We have a legitimate interest.

  1. Help us assess if you are a suitable candidate for a role

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

We also receive personal information indirectly, from the following sources in the following scenarios:

Use of Cookies and Analytical Tools

We (and third parties who perform work for us) may use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. If your browser is set to reject cookies, you may continue to use the Website, but some aspects of the Website may not function as intended.

Some definitions:

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and which emails and advertisements you view, authenticate users, reconstruct or observe activity relating to a session or by a user for troubleshooting, issue resolution, and other purposes, and count visits to our websites.

Web beacons (also known as "pixel tags" or" clear GIFs") are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. In our mobile apps, we may also use technologies that are not browser-based like cookies.

For example, our apps may include software development kits (known as SDKs) which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you additional functionality.

In accordance with your device permissions, we may collect information about the precise location of your device.

As part of our process, we carry out credit and identity checks with credit reference agencies.  We submit your personal information to them and they send us information based, for example, on your credit applications, including things about your financial situation and financial history.

We use the above information to:

  1. ·       Verify the accuracy of the information you have given us

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Mitigate against criminal activity, money laundering and fraud

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Assess your creditworthiness

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Personalize the Services to you, including in communications to you through our Social Network Services and in advertising through our Services and through third-party services (including advertising on other websites that we do not operate). If you give us permission on your mobile device, we may send you promotional and non-promotional "push" notifications to your mobile devices about our Services and products available on our Services.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

  1. Improve the security of our Services and to anticipate and respond to unauthorized, fraudulent, or unlawful activity.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is:

(a) We have a legitimate interest.

How we share Personal Information

We may share your Personal Information with our employees, independent contractors, and any parent, subsidiary, or affiliated business entity.

We may share your Personal Information with third-party vendors, consultants and service providers (collectively “Third-Party Service Providers”) in the following circumstances:

We may share your Personal Information with Third-Party Service Providers that access Personal Information to perform services for us.

We may disclose Personal Information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

We may share Personal Information if we believe (1) that your actions are inconsistent with our user agreements or policies, (2) that you have violated the law, or (3) it's necessary to protect the rights, property and safety of our users, the public, or others.

We share Personal Information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

We may share Personal Information in connection with, or during negotiations concerning, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

We share Personal Information with your consent or at your direction, including but not limited to, through third-party integrations you choose to enable.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

We limit the information that we share to third-party service providers, and require that our third-party service providers only uses hared Personal Information to perform the services requested in accordance with this Privacy Policy and have adequate security measures in place to protect any of your shared Personal Information.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting Pauzible UK Limited, 72 Cannon Street London EC4N 6AE.Telephone number 020 8865 3352. Email address [email protected]

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We have a legitimate interest.

Right to Access to and Control Over Information

You may have certain rights under applicable data protection law with respect to Personal Information about you that is collected through our services and our websites, or when you contact or otherwise engage with us. You also have the right to opt-out of receiving electronic direct marketing communications from us.

However, we may retain Personal Information as authorized under applicable law, such as Personal Information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.

We require certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

You may email us at [email protected] to exercise any of these rights. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request.

We will hold your information to contact you about our products and services and to improve your experience. We may also contact you to request updated details.

Dependant on the data you provide us and for what purpose it is provided we may need to retain your data for up to six years after you are no longer a customer with us.

Links to Other Websites

The Services and websites may contain links to third-party websites and other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site.

This Privacy Policy is only applicable to our Services. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

We strongly advise you to review the Privacy Policy ofevery site you visit.

Security

We are committed to protecting your Personal Information. All of our operational and data processing systems are in a secure environment that protects your information from unauthorized access, use or disclosure.

Children's Privacy

This Website is not intended for persons under the age of 18. We do not knowingly collect, maintain, or use Personal Information from children under the age of 13. If we become aware that we have collected Personal Information from a child under 13, we will take steps to delete such information as soon as possible.

Updates to this Privacy Policy

We may change this Privacy Policy from time to time. If we change this Privacy Policy, we will post the updated version on this website and update the "Last Updated" date above.

Contact information

If you have questions regarding this Privacy Policy, please contact us at:

Pauzible UK Limited

72 Cannon Street London EC4N 6AE

[email protected]

020 8865 3352

Please note that we may need to verify your identity before processing certain requests.

Changes to this Notice

We may update this Notice from time to time.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at Pauzible UK Limited, 72 Cannon Street London EC4N 6AE. Telephone number 020 8865 3352. Email address [email protected] if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at

Pauzible UK Limited, 72 Cannon Street London EC4N 6AE. Telephone number 020 8865 3352. Email address [email protected].

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office

Wy cliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

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