Privacy Policy

Date Last Revised: February 7, 2023

Terms and Conditions of Use & Privacy Policy

Last Updated: February 7, 2023

THESE TERMS ARE IMPORTANT AND AFFECT YOUR LEGAL RIGHTS. PLEASE CAREFULLY READ THIS TERMS AND CONDITIONS OF USE & PRIVACY POLICY PRIOR TO USING OUR WEBSITE. THESE TERMS CONTAIN A BINDING ARBITRATION CLAUSE. PLEASE READ THESE TERMS AND THE ARBITRATION PROVISION SO THAT YOU ARE AWARE OF YOUR LEGAL RIGHTS.

TERMS AND CONDITIONS OF USE

Section 1 – Introduction & Consent to Terms

Welcome Sterling Data Company LLC, a Delaware limited liability company, and its affiliates and related parties (referred to herein as “Sterling, “we”, “us”, or “our”) Terms & Conditions of Use (referred to herein as the “Terms”). Sterling is a company engaged in assisting candidates, campaigns, and nonprofits with fundraising efforts, with a variety of products and services (referred to herein as our “Services”).

These Terms apply to all users of our websites – https://sterling.ai/ and https://sterlingdatacompany.com/ and https://www.sterlingstrategies.co/ (each, a “Website”).

If you do not agree to these Terms, we ask that you please not use our Website. Use of our Website constitutes explicit acceptance of these Terms.

We reserve the right to modify the contents of these Terms at any time. You agree that it is your responsibility to monitor changes to these Terms. Any modification to these Terms will be notated at the top of these Terms.

Section 2 – Eligibility, User Account, & Technological Requirements

Access to and use of our Website is not meant to be used by anyone under the age of eighteen (18) and we do not target persons under this age. By using our Website, you represent and warrant that (a) you are at least eighteen (18) years old and (b) have a working smartphone or computer.

Your use of our Services involves hardware, software, and access to the internet. These system requirements may change from time to time. You acknowledge and agree that all system or internet requirements for our Services is/are your sole responsibility, and you acknowledge and agree that failure to comply with all hardware, software, and internet requirements will be borne solely by you.

To register for our Services or the Services of one of our affiliates or related companies, you are required to create a user account through our Website (a “User Account”) or directly with us or our affiliates or related companies via a separate written contractual agreement, and provide all information as requested when prompted to create a user account (referred to herein as becoming a “User”). The specific elements of our Services can be accessed through your User Account.

By registering for our Services and becoming a User, you further represent and warrant that (a) all information submitted is true and correct to the best of your knowledge; (b) if there are any errors or inaccuracies on your User Account, you will update this information as soon as you discover the inaccuracy; (c) you will maintain and continue to update your User Account to ensure that at all times it is current and accurate; and (d) you are only authorized to register a third-party if you have unambiguous consent from that person, preferably in writing, to do so. You will solely be responsible for any and all issues arising out of signing up a third-party.

By signing up and becoming a User or by providing your contact information through our Website, you explicitly consent to receive marketing and other communications related to our Services, products, and future product offerings. You are able to terminate this consent in accordance with our Privacy Policy.

You are solely responsible for maintaining confidentiality of your password and account information and are responsible for all activity that takes place on your account. We are not responsible for any activity through your User Account.

Section 3 – Sterling Intellectual Property

The contents of our Website are protected by United States and international copyright laws. The contents of our Website are owned exclusively by Sterling or licensed to us.

You may not, and may not cause or encourage others to, reproduce, distribute, display, sell, transfer, assign, license or use for commercial purposes any copyrighted material on our Website (the “Intellectual Property”) without our prior written consent. All rights not expressly granted in these Terms are reserved to Sterling.

Sterling and its name, logos, slogans, or otherwise are trademarks or service marks (“Marks”) of Sterling. All rights in these Marks are reserved by Sterling. You may not use any Sterling-provided Marks or other logos or graphics, without our prior written consent.

We grant you a limited, revocable, non-transferable and non-exclusive license to access and make personal use of our Website. This limited license does not include the right to: (a) republish, redistribute, transmit, sell, license or download anything on our Website, except as is necessary to view and/or use our Website; (b) make any use of our Website other than uses consistent with our Services or exploring the Services; (c) modify, reverse engineer or create any derivative works based upon our Website; (d) collect account information for the benefit of yourself or another party; or (e) use software robots, spiders, crawlers, or similar data gathering and extraction tools, or take any other action that may impose an unreasonable burden or load on our infrastructure.

Any unauthorized use by you of our Website automatically terminates this license without prejudice to any other remedy provided by applicable law or these Terms.

Section 4 – Your Content

If you send submissions of any kind, with or without a request from us, including ideas, suggestions, or otherwise, whether online, by email, or otherwise (“Submissions”), you agree that we may, at any time, without restriction, edit, copy, publish, distribute, translate, and otherwise use in any medium any Submissions that you forward to us. This does not include any confidential or personal information that you send to us (such as when signing up for our Services).

We are and shall be under no obligation (1) to maintain any Submissions in confidence; (2) to pay compensation to you for any Submissions; or (3) to respond to any Submissions.

By you submitting Submissions to us, you hereby transfer and assign any claim to any rights that you may have had in those Submissions and do so with full acknowledgment of the same. You agree that your Submissions will not violate any right of any third-party, including copyright, trademark, privacy, personality or other personal or proprietary right. We take no responsibility and assume no liability for any Submissions submitted by you.

Section 5 – Third Party Content and Third-Party Waiver

Our Website may contain links to third-party websites or services that are not owned or controlled by us. Sterling has no control over, and assumes no responsibility for, the content, privacy policies, or business practices of any third-party companies or persons. We strongly encourage you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.

You understand that Sterling may use licensed materials or content on our Website and that there is no agency relationship between Sterling and any of these third-party persons or entities, all of whom are separate from Sterling.

By using our Website, you expressly waive Sterling, our employees, agents, owners, and principals from all liability arising from your use of any content, plans, or services provided by third-parties.

YOU AGREE THAT STERLING WILL NOT, UNDER ANY CIRCUMSTANCES, BE RESPONSIBLE OR LIABLE, DIRECTLY OR INDIRECTLY, FOR ANY CONTENT OF ANY KIND OR FOR ANY HARM RELATED THERETO, OR FOR ANY DAMAGES OR LOSS CAUSED OR ALLEGED TO BE CAUSED BY OR IN CONNECTION WITH YOUR USE OR RELIANCE ON THE CONTENT OF ALL CONTENT PROVIDED BY A THIRD-PARTY.

Section 6 – Community Guidelines

You are prohibited from using our Website or Services:

for any unlawful purpose;
to solicit others to perform or participate in any unlawful acts;
to violate any international, federal, provincial or state regulations, rules, laws, or local ordinances; or
for any obscene or immoral purpose.

We reserve the right to terminate your use of our Website or Services for violating any of these community guidelines.

Section 7 – Copyright Infringement

If you believe that your copyright has been infringed by Sterling, please immediately send us a notice to privacy@sterling.ai with the following information:

A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site.
Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit the service provider to locate the material.
Information reasonably sufficient to permit the service provider to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted.
A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.
A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

We respond to notices of copyright infringement immediately and take any such allegations seriously. The reported content will be taken down within seventy-two (72) hours of written notice unless it is clear that your notice is spam or if we have evidence that your claim is false.

Sterling prohibits any infringement of intellectual property rights by any user of our Website and Services.

Section 8 – Term & Errors

These Terms will remain active and in full force and effect so long as they are posted on our Website.

Occasionally there may be information on our Website that contains typographical errors, inaccuracies or omissions that may relate to descriptions, pricing, promotions, offers, and availability. We reserve the right to correct any errors, inaccuracies, or omissions, at any time.

Section 9 – ADA Compliance

If you believe that you are or may be covered by the Americans with Disabilities Act of 1990, as amended (the “ADA Act”), please reach out to us with any issues or concerns you have governing our Website and/or these Terms. We will be more than happy to assist you to ensure that you are able to access our Website and our Services.

Section 10 – Disclaimer

OUR WEBSITE IS PROVIDED ‘AS IS’ AND, TO THE EXTENT PERMITTED BY APPLICABLE LAW, STERLING AND ITS OWNERS, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, REPRESENTATIVES, LICENSORS, THIRD PARTY PROVIDERS AND AFFILIATES, EXCLUDE ALL REPRESENTATIONS OR WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, SATISFACTORY QUALITY, AND FITNESS FOR A PARTICULAR PURPOSE.

WE DO NOT AND CANNOT GUARANTEE PERFECT AVAILABILITY OF OUR WEBSITE, WHICH MAY BE INACCESSIBLE, IN FULL OR IN PART, FROM TIME TO TIME. IN ADDITION, SOFTWARE UPDATES, BUGS, OR OTHER REASONS WHY OUR WEBSITE MAY BE TEMPORARILY DOWN COULD BE A TIME-TO-TIME OCCURRENCE. BY USING OUR WEBSITE, YOU ACKNOWLEDGE AND AGREE THAT OPERATING A WEBSITE IS LIKE OWNING A LUXURY VEHICLE – UNEXPECTED ISSUES DO ARISE FROM TIME TO TIME AND SHOULD BE EXPECTED. YOU WILL NOT HAVE UNINTERRUPTED SERVICE OF OUR WEBSITE AT ALL TIMES.

WE EXPRESSLY DISCLAIM ANY LIABILITY FOR LOSS OR DAMAGE SUSTAINED BY YOU AS A RESULT OF USING OUR SERVICES.

Section 11– Limitation of Liability

WE SHALL NOT BE LIABLE TO YOU FOR INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES, INCLUDING LOST PROFITS, EVEN IF WE WERE ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, NOR SHALL WE BE HELD LIABLE FOR DELAY OR FAILURE IN PERFORMANCE RESULTING FROM CAUSES BEYOND OUR REASONABLE CONTROL. IN NO EVENT SHALL OUR TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES AND CAUSES OF ACTION EXCEED THE TOTAL AMOUNT STERLING RECEIVED IN CONNECTION WITH YOUR SERVICES, OR IF YOU HAVE NOT USED OUR SERVICES, TEN DOLLARS ($10.00).

YOU AGREE THAT NO CLAIMS OR ACTION IN CONTRACT, WARRANTY, OR IN TORT (INCLUDING NEGLIGENCE) ARISING OUT OF, OR RELATED TO, THE USE OF OUR WEBSITE, OUR SERVICES, OR THESE TERMS MAY BE BROUGHT MORE THAN ONE (1) YEAR AFTER THE CAUSE OF ACTION RELATING TO SUCH CLAIM OR ACTION AROSE. IF YOU ARE DISSATISFIED WITH OUR WEBSITE OR SERVICES, YOU ARE NOT REQUIRED TO CONTINUE TO USE OUR WEBSITE OR SERVICES. WE HAVE NO OTHER OBLIGATION, LIABILITY, OR RESPONSIBILITY TO YOU.

Section 12 – Indemnification

You agree to defend, indemnify and hold Sterling, its agents, employees, directors, officers, owners, etc. harmless for any loss, damages or costs, including reasonable attorneys’ fees, resulting from any claim, action, or demand arising from (i) your use of our Website or Services; (ii) your breach of these Terms; or (iii) breach of applicable law.

Section 13– FTC Disclosures

In connection with our Website: (i) we may run advertisements on our Website concerning third-parties who may provide us compensation to be advertised on our Website; and (ii) we may receive compensation if you click one of the links on our Website.

Section 14 – General Provisions

Entire Agreement. These Terms contains the entire agreement between you and Sterling except for any Services-related contracts you have entered into with Sterling.

Waiver. The failure by Sterling to enforce any provision of these Terms shall not be construed as a waiver or limitation of our right to subsequently enforce and compel strict compliance with every provision of this Agreement.

Assignment. You may not assign, pledge, delegate, or otherwise transfer any of your rights or obligations under this Agreement without Sterling prior written consent.

Relationship. Nothing in these Terms shall create, or is intended to create an agency, employment, franchise, joint venture, or partnership relationship between you and Sterling.

Applicable Law/Dispute Resolution. This Agreement shall be governed by the laws of the State of Delaware. Any dispute arising from this Agreement shall be subject to binding arbitration in Los Angeles, California. The prevailing Party in any dispute shall be entitled to recover its/his/her reasonable attorney’s fees and costs. The governing rules shall be the rules, then-implemented, by the American Arbitration Association commercial division. Sterling and you agree that any such final decisions may be presented to a court of competent jurisdiction for purposes of being confirmed as a judgment enforceable under the law in which that party is domiciled or where their headquarters are located. Should either party forego arbitration, that party shall be barred from recovering their attorneys’ fees or costs.

Severability. If any provision of this Agreement shall be held to be invalid or unenforceable for any reason, the remaining provisions shall continue to be valid and enforceable. If an arbitrator or panel of arbitrators finds that any provision of this Agreement is invalid or unenforceable, but that by limiting such provision it would become valid and enforceable, then such provision shall be deemed to be written, construed, and enforced as so limited.

Updates. We recommend that you check the Terms periodically for updates.

PRIVACY POLICY

Section 1 – Introduction.

1.1. Intro. This Privacy Policy describes the Personal Information (as defined below) collected or processed when you interact with Sterling. It also explains how your Personal Information is used, shared, and is protected by us, and what choices you have relating to your Personal Information. If you have any questions about this Privacy Policy or your Personal Information, please email us at privacy@sterling.ai.

This Privacy Policy governs your privacy rights. We recommend reading this Privacy Policy in its entirety. By using our Website, you consent to this Privacy Policy (and any subsequent amendments). If you do not agree to this Privacy Policy, please do not use our Website.

1.2 Ownership & Services. Our Website is owned and operated by Sterling Data Company LLC, a Delaware limited liability company (“Sterling”, “we” or “us”). Sterling is a company engaged in assisting candidates, campaigns, and non-profits with fundraising efforts, with a variety of products and services (referred to herein as our “Services”).

1.3 Scope. This Privacy Policy applies to all users of our websites – https://sterling.ai/ and https://sterlingdatacompany.com/ and https://www.sterlingstrategies.co/ (each, a “Website”). This Privacy Policy also applies to your information that we have acquired, by license or ownership, from third parties. We collect certain information, including Personal Information, from our third-party sources.

1.4 Additional. Our Website may contain links to third party sites that are not owned or controlled by Sterling. Please be aware that we are not responsible for the practices of such other sites. We encourage you to read the privacy statements of every third-party website that you visit as these websites have no affiliation with Sterling and may have privacy policies that contain different terms from what is included here.

Section 2 – Information We Collect.

2.1 Information Provided by You. You have provided us information through various means. We collect “Personal Information”, which identifies you as an individual, or you as an entity. The information we collect may include the following: name, address, email address(es), age, political party affiliation, past donor history, and inferences drawn from any or all of the foregoing. This information is collected directly from you when you sign up for a user account on our Website.

2.2 Information We Collect from You. We collect certain information automatically as you use our Website, including your Internet Protocol address, browser type, computer type, type of mobile device, mobile carrier, computer operating system, the site from where you navigated to our Website, the time and date of using our Website, how long you use (or have used) the Website and the pages that you view.

2.3 Cookies. When you visit or use our Website, we may send one or more “cookies” to your computer or other device. A cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do, some Website features may not function properly without cookies.

We use cookies for a number of reasons, including without limitation:

Authenticating and identifying you on our Websites so we can provide you the services you requested;
Keeping track of information you have provided to us;
Remembering your preferences or where you left off;
Measuring your use of our Website so we can improve its quality; and
Understanding what you may be interested in.

2.4 Pixel Tags. We may use “pixel tags,” which are small graphic files that allow us to monitor the use of our Website. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.

2.5 Physical Location. We may collect the physical location of your device by, for example, using satellite, cell phone tower, or Wi-Fi signals. We may use your device’s physical location to better understand who you are.

2.6 Age Restriction. Our Website and our Services are not intended for or directed to children under the age of thirteen (13) and we do not knowingly collect Personal Information from children under the age of thirteen (13) on our Website. If we become aware that a child under the age of thirteen (13) has provided us with Personal Information, we will delete the information from our records.

Section 3 – How Sterling Uses Your Information.

3.1 To Provide Services and Information. As described above, we collect or have collected information from you so that we can effectively offer our Services to you, for data or analytic reasons, data trends, usage, to determine the effectiveness of our Services, or any reasonable reason(s) now or hereinafter adopted.

3.2 Our Business Purposes. We may share your information with our clients who may be political campaigns, political organizations, NGO’s, non-profits, and other persons or entities looking for fundraising, financing, or similar services. We may also use your information for our Services and other reasons such as data analysis, developing new Services, sending marketing campaigns, enhancing, improving or modifying our Website, identifying usage trends, determining the effectiveness of our campaigns and any reasonable reason(s) now or hereinafter adopted.

3.3 Other Purposes. We may use non-Personal Information for other purposes, except when not permitted by applicable law. We may use analytics services, such as Google Analytics, on our Website, our social media pages, or our mobile Website to help us evaluate and analyze how visitors use our Website. For specific details on how Google collects and uses information on our Website, social media pages, or mobile applications, please visit Google’s website.

Section 4 – How Your Information is Shared.

4.1 Our Third-Party Service Providers. We may share your information with our third-party service providers, who provide services including, without limitation, website hosting, data analytics, payment processing, customer service, email delivery services, or other services that are used in connection with the Services that we offer.

4.2 Legal Requests or Requirements and to Prevent Harm. We reserve the right to disclose your Personal Information and any other information collected by you as required by law or when that disclosure is necessary to protect our rights, the rights of a third-party, or to comply with a judicial proceeding or otherwise.

4.3 Transfer of Your Personal Information. As a data broker, we reserve the right to transfer your information to another person or entity, with or without consideration, unless you opt out (see below) or unless barred by applicable law. We also reserve the right to transfer your information in the event of a sale of Sterling.

4.4 Other Sharing of Non-Personally Identifiable Information. We may share non-personally identifiable information with third parties unless you opt out or unless barred by applicable law.

Section 5 – Access to Your Information and Opt Out.

Subject to applicable law, you may have the right to request access to and receive details about the Personal Information we have collected and maintain about you, update and correct inaccuracies in your Personal Information, and have the Personal Information deleted. These rights may be limited in some circumstances by local law. We may take reasonable steps to verify your identity before granting access or making corrections.

You can opt-out of us using your Personal Information by sending us an email to the contact listed on our Website or unsubscribing on the communication you receive. If you send us an email, please be sure to provide (i) sufficient information that allows us to verify that you are the person whom we collected Personal Information; and (ii) sufficiently describe your request. Please note if your opt-out request is specific to a particular type of Personal Information.

Finally, we are not obligated to delete Personal Information if we are unable to verify that you are the person whom we collected Personal Information, if we have reason to believe that you are a bot and not a person, or for any other reason that indicates that you may not be the person whom we collected Personal Information.

We will endeavor to comply with your request(s) as soon as reasonably practicable, which may depend on the number of requests we have received at or around the time of your request. If we need additional time, which we reasonably expect to be completed within thirty (30) days, we will contact you in writing and inform you of the reason for the delay.

Section 6 – Security of Your Information.

We use industry standard security measures designed to protect your personally identifiable information. However, no data transmission or storage system is impenetrable, and you acknowledge this. If you have reason to believe that the security of your Personal Information might have with us has been compromised, please immediately notify us.

Unless you’re using an encrypted email, we strongly advise you not to communicate any confidential information in your emails to us.

Section 7 – Changes to Our Privacy Policy.

If we decide to change our Privacy Policy, we will post those changes on our Website so that you are aware of what information we collect, how we use it, and under what circumstances we disclose or transfer it.

We reserve the right to modify this Privacy Policy at any time, so please review the Privacy Policy from time to time. Any changes to this Privacy Policy will become effective immediately upon being made public.

Section 8 – Additional Information If You Live in California.

Under California privacy laws, including the California Consumer Privacy Act (“CCPA”), we are required to notify California residents about how we use their Personal Information.

Under the CCPA, “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

We collect the Personal Information in accordance with Section 2, above.

California residents have the right to opt-out of our sale of their Personal Information by contacting us via email at privacy@sterling.ai, by unsubscribing on the communication you have received, or the form listed on our Website. Please be prepared to provide proof of your residence in California.

We do not use or transfer Personal Information about California residents under 16 years old without opt-in consent.

We are required to notify California residents, at or before the point of collection of their Personal Information, the categories of Personal Information collected and the purposes for which such information is used.

Verifiable Requests to Delete, and Requests to Know. Subject to certain exceptions, California residents have the right to make the following requests, up to twice every twelve (12) months:

Right of Deletion: California residents have the right to request that we delete their Personal Information that we have collected about them, subject to certain exemptions.
Right to Know & to Receive a Copy: California residents have the right to request a copy of the specific pieces of Personal Information that we have collected about them in the prior twelve (12) months and to have this information sent to you via email.
Right to Know & Right to Information: California residents have the right to request that we provide them certain information about how we have handled their Personal Information in the prior twelve (12) months.

Submitting Requests. Requests to exercise the right of deletion, right to a copy, or the right to information may be submitted by contacting us via email at privacy@sterling.ai or the form listed on our Website.

Right to Non-Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. We do not and will not discriminate against you for exercising any of your CCPA rights.

Financial Incentive. We may offer you various financial incentives such as special offers when you provide us with contact information and identifiers such as your name and email address. You may withdraw from a financial incentive at any time by opting out. Generally, we do not assign monetary or other value to Personal Information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the Personal Information is related to the estimated cost of providing the relevant financial incentive(s) for which the information was collected.

Section 9 – Notice for Residents of Nevada.

Nevada law, specifically Senate Bill 220, allows customers who are residents of the state of Nevada to “opt out” of the sale of certain Personal Information, called “covered information.”

You have the right to opt out at any time and direct us not to use or transfer your Personal Information.

Requests to exercise your right to opt out may be submitted by contacting us at privacy@sterling.ai, unsubscribing on the communication you receive, or the form listed on our Website.

Section 10 – Disclaimers.

Sterling is a data broker. We buy, sell, and license the sale of Personal Information.

Your Personal Information may have been acquired by our third-party sources and transferred to Sterling in accordance with the privacy policies of our third-party sources. If your Personal Information was acquired by our third-party sources, what we can and cannot do shall be based on, and in accordance with the privacy policies of our third-party sources, which we invite you to read.

Please be advised that we may not be the only person or entity with access to your Personal Information. While we may have acquired your information, including Personal Information from our third-party sources, our third-party sources may have also sold or licensed your Personal Information to other persons or entities, or may still be in possession of your Personal Information. It is conceivable, if not likely, that if you submit a request for us to delete your Personal Information, and we do, that your Personal Information may be in the hands of multiple persons or entities, and that you may need to contact each person or entity to prevent your Personal Information from being sold. We may have no relationship with and may be ignorant of the names of other persons or entities who have access to your Personal Information. Thus, we shall only be responsible for your Personal Information with Sterling and not of third parties.

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