Our response to COVID-19 Events Careers 0800 434 6460 Who we are Business challenges Services Sectors Content Hub Contact us Privacy & cookies Your privacy is important to us We recognise that when you visit our site and provide us with personal information, you trust that we will act responsibly and keep your information secure and confidential. 1. Purpose of this notice This notice describes how we collect and use personal data about you. In the UK this will be in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time. In Guernsey it will be in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017, regulations and secondary legislation, as amended or updated from time to time (‘Data Protection Legislation’). Please read the following carefully to understand our practices regarding your personal data and how we will treat it. 2. About us Price Bailey LLP is an accountancy and business advisory firm. We are registered in England and Wales as a limited liability partnership under number: OC307551 and our registered office is at Causeway House, 1 Dane Street, Bishop’s Stortford, Herts, CM23 3BT. Our group also includes the following entities: Price Bailey Group Limited (registered in England & Wales, number 04615377) Price Bailey Limited (registered in Guernsey, number 39681) Price Bailey Private Client LLP (registered in England & Wales, number OC237009) Price Bailey Mayfair LLP, (registered in England & Wales, number OC366511) Price Bailey Group Limited (registered in England & Wales, number 04615377) For the purpose of the Data Protection Legislation and this notice, one or more of the above entities is the ‘data controller’ (and “we”, “us”, “our” and “ours” in this notice refer to any of those entities). This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice. In most cases it will be clear which entity is the data controller with respect to your personal data (for example because your contract is with that entity), however if you have any queries about this please contact our Data Protection point of contact: Catherine Hardinge, Compliance Partner, compliance@pricebailey.co.uk. Our Data Protection Point of Contact is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. 3. Data retention period Our general policy is to hold data for fifteen years. This applies to all categories of personal data unless a shorter or longer period is specified in respect of particular categories of data. However for existing clients where the information may be required or relevant to future periods the information may be held for longer. 4. What types of personal data we hold and how we collect and use that data The types of personal data that we hold and how we collect and use that data vary according to our relationship with the person whose data it is (the ‘data subject’). Details in respect of each type of data subject are given in the links below: Personal clients and persons associated with corporate clients Other individuals whose personal data we obtain in the course of providing services to our clients Business contacts Our employees and partners Recruitment applicants Suppliers Users of our website Visitors to our offices 5. Data sharing Why might we share your personal data with third parties? We will share your personal data with third parties where we are required by law or regulation, where it is necessary in the provision of services to our clients, or for administration purposes or where we have another legitimate reason in doing so. Which third-party service providers process my personal data? “Third parties” includes third-party service providers and other entities within our group. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, and banking services. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions. What about other third parties? We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator, professional body, or an external quality control reviewer or to otherwise comply with the law. In the case of the external quality control reviewers they are not allowed to use or share you data with any one else. Secure data transfers Where we transmit data via a secure portal or secure e-mail service the data is stored on servers located in the UK maintained by iManage (portal) or Mimecast (e-mail), such data may include personal data. We remain data controllers in respect of this data and iManage/Mimecast only process it for the purposes of transmitting it to or from us. A summary of security relating to the iManage servers can be found at https://imanage.com/security/. iManage have confirmed that their UK servers are compliant with GDPR and we only use their UK servers. A summary of security relating to the Mimecast servers can be found at https://www.mimecast.com/archived-pages/company/mimecast-trust-center/gdpr-center/technical-organizational-measures/cr/. Mimecast have confirmed that their UK servers are compliant with GDPR and we only use their UK servers. If you use the secure portal or secure e-mail service to transmit data to or from us you will be required to set a user name and password directly with iManage/Mimecast. Data supplied in setting this up will be held by iManage/Mimecast and will be dealt with in accordance with their privacy policy, a link to this will be supplied to you at that time. 6. Transferring personal data outside of the United Kingdom (UK) and the European Economic Area (EEA) Except as noted below or where specifically requested by you, we will not transfer the personal data that we collect about you outside the UK and the EEA. Data in respect of clients, suppliers and others connected with group entities registered in Guernsey is normally stored in the UK, but will also be transferred to Guernsey. Where you have chosen to use the MiPB app personal data may be transferred to service providers who provide elements of this service on our behalf. These providers may transfer this data to sub-processors outside the UK and the EEA. In such cases this will either be to a country in respect of which there is an adequacy decision by the European Commission or, if there is not an adequacy decision by the European Commission in relation to it, they will put in place measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation. Where a client asks us to introduce them to a service provider outside the UK and the EEA and have instructed us to transfer personal data to them, we will make this transfer in accordance with their instructions. Where a client is managed outside the UK and the EEA or is part of a group which is managed outside the UK and EEA and they have instructed us to transfer personal data in connection with our engagement with them, we will make the transfer in accordance with these instructions. In such cases this will either be to a country in respect of which there is an adequacy decision by the European Commission or, if there is not an adequacy decision by the European Commission in relation to it, under the terms of a contract to ensure that your personal data is treated in a way that is consistent with and which respects the Data Protection Legislation. 7. MiPB app The MIPB app provides access to various third party services. If we make this service available to you and you choose to access it, in accessing those services you will be subject to the terms and conditions of the third party suppliers, which they will provide to you when you set up your account. Access to the MiPB app is provided on the basis of your agreement to the data sharing as set out in your engagement letter, including where relevant the sharing of personal data, required to deliver those services. The privacy policies of the third party suppliers may be found at: Service Supplier Privacy policy Xero – Xero Limited – https://www.xero.com/uk/about/terms/privacy/ Receipt Bank – Receipt Bank Limited – https://www.receipt-bank.com/privacy-policy/ Futrli – Hamy Limited – https://www.futrli.com/privacy-policy/ The suppliers’ privacy policies explain how the suppliers handle and store personal information and protect your privacy. Please read the suppliers’ privacy policies carefully. Importantly, the suppliers’ privacy policies detail how and why the suppliers may make available your data to service providers based outside the United Kingdom and the European Economic Area. 8. Business systems support Our business systems support teams may, at the invitation of clients using their services, remotely access the systems of such clients using the Go To Assist screen sharing service. Such sessions will always be initiated by the client. Such sessions will not normally involve accessing personal data. In some cases copies of data may be sent to the Business Systems team so that they can provide support, this data may in some cases contain personal information. Such data is held for as long as is necessary for the support query to be address and will normally be deleted within eighteen months. Where applicable the sections of this privacy notice relating to ‘Personal clients and persons associated with corporate clients’ and ‘Other individuals whose personal data we obtain in the course of providing services to our clients’ apply to personal data obtained in the course of providing business systems support. 9. Data security We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to our employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 10. Rights to access, correction, erasure and restriction Your duty to inform us of changes It is important that the personal data we hold is accurate and current. Should your personal information that you have supplied to us change, please notify us of any changes of which we need to be made aware by informing your usual Price Bailey contact. Your rights in connection with personal data Under certain circumstances, by law you have the right to: Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully. Request correction of the personal data that we hold about you. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below). Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible. If you want to exercise any of the above rights, please email Catherine Hardinge, Compliance Partner, at Compliance@pricebailey.co.uk. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. 11. Right to withdraw consent In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact compliance@pricebailey.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. 12. Changes to this notice We will keep this privacy statement under regular review and any changes will be shown on this web page. This privacy notice was last updated on 28 September 2020. 13. Contact us If you have any questions regarding this notice or if you would like to speak to us about the manner, in which we process your personal data, please email Catherine Hardinge, Compliance Partner, at compliance@pricebailey.co.uk. You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone – 0303 123 1113 (local rate) or 01625 545 745 Website – https://ico.org.uk/concerns Personal clients and persons associated with corporate clients Who do we collect information about? We collect information about clients who are individuals, about the owners of our clients, about the management of our clients and about persons connected with our clients who we interact with in the course of our work (for example we may have contact details for various people within the finance department of our audit clients who provide us with information during the course of our work). What personal information do we collect? It is our policy only to collect the personal information which is required for our work. In some cases this may mean that the only personal information that we hold is contact information and details of any communications with that person, but in other cases this may include: Financial information Information about business activities Information about family or business relationships Information about marketing activities What is the source of this information? This information is usually supplied by clients, but may also be supplied by third parties who have been authorised by clients or from publicly available information. How do we use this data? We may use this data to carry out our obligations arising from any agreements entered into between our clients and us (for example in providing tax advice to personal clients). In addition we may use this data in managing our relationships with our clients and in providing to our clients information about our services or other information that we consider may be of interest to them. The basis for this processing is the contracts that we have with our clients, legal obligations and/or that such processing is necessary for our or our clients’ legitimate interests. How long do we retain this data for? We will retain personal data in accordance with our data retention policy for as long as is necessary to fulfil the purposes for which it is collected, including any retention period required by laws or regulations, in most cases we will hold the information for fifteen years. Other individuals whose personal data we obtain in the course of providing services to our clients Who do we collect information about? The services that we provide to our client sometimes require us to collect personal information about other individuals (for example where we provide payroll services we will be provided with the personal information about the employees of our client necessary to deliver this service or where we are auditing a client we may need to obtain personal information about employees in order to verify the wages figures in their accounts). What is the source of this information? This information is usually supplied by clients, but may also be supplied by third parties who have been authorised by clients (for example other payroll providers). What personal information do we collect? It is our policy only to collect the personal information which is required for our work. This may include: Salary details Bank account details Addresses Investments and other financial details Details about people meeting the definition of related parties of our clients (for example close family of directors) Other personal details required to provide our services The GDPR identifies personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation as special categories of personal data. We would not normally receive such data, but may do so where this is necessary for our work (for example in processing a payroll on behalf of a client we may be instructed which employees should have trade union subscriptions deducted). How do we use this data? We may use this data to carry out our obligations arising from any agreements entered into between our clients and us (for example in providing audit reports on our clients’ accounts). Data obtained in this way will only be used to the extent necessary to provide these services. We will not use it for any other purpose. In particular we will not use it for marketing purposes. The basis for this processing is the contracts that we have with our clients, legal obligations and/or that such processing is necessary for our or our clients’ legitimate interests. How long do we retain this data for? We will retain personal data in accordance with our data retention policy for as long as is necessary to fulfil the purposes for which it is collected, including any retention period required by laws or regulations or by our regulators, in most cases we will hold the information for fifteen years. Business contacts Who do we collect information about? We also collect information about business contacts other than personal clients and persons associated with corporate clients. What is the source of this information? This information is provided by the business contacts themselves, usually at exhibitions and events, networking groups and other meetings involving Price Bailey employees and Partners. We also obtain mailing lists of business postal addresses from third parties. What personal information do we collect? In the case of business contacts we collect information necessary for our communications with them. This may include: Contact details Business details How do we use this data? We may use this data to communicate with contacts about possible business opportunities, our range of professional services, sharing insight and to invite them to events. The basis for this processing is either the consent of the contacts themselves or legitimate business interest. This consent may be withdrawn at any time (see the contact us section of the privacy policy for details of who to contact). How long do we retain this data for? We will retain personal data in accordance with our data retention policy for as long as is necessary to fulfil the purposes for which it is collected. For business contacts the data is retained for at least as long as we have a business relationship with them. Our employees and partners Current employees and partners should refer to the Employees and Partners Privacy Notice on PB Online. Recruitment applicants Who do we collect information about? We collect personal data about applicants for a position with a Price Bailey Group entity. What is the source of this information? The principal source of this information is the applicants themselves, however we may also collect information from third parties (for example references) or use publicly available information. What personal information do we collect? We collect information necessary to evaluate individuals for employment with Price Bailey. This may include: Employment history Education References Contact details Our assessment of the candidate’s suitability How do we use this data? We use this data to evaluate the suitability of individuals for employment with Price Bailey. The basis for this processing is that such processing is necessary for our legitimate interests and to comply with legal requirements. How long do we retain this data for? We will retain personal data in accordance with our data retention policy for as long as is necessary to fulfil the purposes for which it is collected. If an applicant becomes an employee of Price Bailey their personal information will be retained in accordance with the policies for our employees and partners (see section above on ‘Our Employees and Partners’). If an applicant does not become an employee of Price Bailey their personal data will no longer be kept unless they consent for us to do so for the purposes of notifying them of future vacancies. Our suppliers Who do we collect information about? We collect personal information about our suppliers (where these are individuals) and persons associated with them (for example our relationship manager at a supplier). What is the source of this information? The source of this information is the suppliers themselves. What personal information do we collect? We collect the information necessary to manage our relationships with our suppliers. This may include: Contact details Business activities Bank details How do we use this data? We use this data to manage our relationships with our suppliers. The basis for this processing is the contracts that we have with our suppliers, legal obligations and/or that such processing is necessary for our legitimate interests. How long do we retain this data for? We will retain personal data in accordance with our data retention policy for as long as is necessary to fulfil the purposes for which it is collected. For suppliers such data will be held for at least as long as we have a business relationship with them. Users of our website Who do we collect information about? We collect personal data about users of our website if they choose to provide this information to us. In addition we collect some limited personal data via the use of cookies on our website. What is the source of this information? The data is provided by users of the website if they choose to do so. What personal information do we collect? The principal information that is collected is the contact details provided by the website user however, depending on the nature of the submission other personal information may be provided. How do we use this data? Data is used in order to respond to communications from the users of the website. In some cases users will sign up to services which will result in them becoming business contacts, in which case their data will be used in accordance with the ‘Business Contacts’ section of this policy. Data is processed on the basis of the consent of the website user, which is given when the data is provided. How long do we retain this data for? We will retain personal data in accordance with our data retention policy for as long as is necessary to fulfil the purposes for which it is collected. Cookies What are cookies? A cookie is a small text file written to the hard drive when a visitor accesses a website, it contains information about their actions on the website. Most web browsers allow users to opt out of receiving cookies, however you may find that some features of the website are impaired if you do this. If you do not know what cookies are, or how to control or delete them, then we recommend you visit https://www.aboutcookies.org for detailed guidance. How we use Cookies We use a number of different cookies on our site. The list below describes the cookies we use on this site and what we use them for. You have the choice as to whether you accept our standard balanced cookies or whether you want to use the private settings or personalise. If you are not happy for any cookies, then you should either not use this site, or you should delete the cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.) If you want to amend your setting at any time you can by clicking on the cookie icon bottom left of the screen. Cookie Policy of pricebailey.co.uk Cookies consist of portions of code installed in the browser that assist the Owner in providing the Service according to the purposes described. Some of the purposes for which Cookies are installed may also require the User’s consent. Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this document. Cookies we use Price Bailey uses cookies to improve your experience of our website.. We use cookies to enhance the sites functionality, personalise content and analyse our traffic. We also share anonymous information about your use of our site with our social media, ad and analytics partners. For more information, you can review our privacy policy. If you do not accept cookies, some parts of the website may not work correctly. Cookies are small text files that can be used by websites to make a user's experience more efficient. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission. This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages. You can at any time change or withdraw your consent from the Cookie Declaration on our website. Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy. Please state your consent ID and date when you contact us regarding your consent. Your consent applies to the following domains: www.pricebailey.co.uk Your current state: Deny. Change your consent Cookie declaration last updated on 11/24/21 by Cookiebot: Necessary (8) Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. Name Provider Purpose Expiry Type _grecaptcha Google This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. Persistent HTML Local Storage _GRECAPTCHA Google This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. 179 days HTTP Cookie _wpfuj www.pricebailey.co.uk Pending 1 year HTTP Cookie CookieConsent Cookiebot Stores the user's cookie consent state for the current domain 1 year HTTP Cookie rc::a Google This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. Persistent HTML Local Storage rc::b Google This cookie is used to distinguish between humans and bots. Session HTML Local Storage rc::c Google This cookie is used to distinguish between humans and bots. Session HTML Local Storage rc::d-# Google This cookie is used to distinguish between humans and bots. Persistent HTML Local Storage Preferences (7) Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. Name Provider Purpose Expiry Type isProactiveInvite www.pricebailey.co.uk Pending Session HTTP Cookie MoneypennyAgentAvatar www.pricebailey.co.uk Pending 1 day HTTP Cookie MoneypennyHistory Google Pending 1 year HTTP Cookie MoneypennyRef Google Pending 1 day HTTP Cookie MoneypennyUserAlias Google Pending 1 year HTTP Cookie MoneypennyVisit Google Pending Session HTTP Cookie times_to_show Google Pending Persistent HTML Local Storage Statistics (5) Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. Name Provider Purpose Expiry Type _ga Google Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 2 years HTTP Cookie _ga_# Google Tag Manager Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit. 2 years HTTP Cookie _gat Google Used by Google Analytics to throttle request rate 1 day HTTP Cookie _gid Google Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 1 day HTTP Cookie test_cookie Google Used to check if the user's browser supports cookies. 1 day HTTP Cookie Marketing (18) Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. Name Provider Purpose Expiry Type _fbp Facebook Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. 3 months HTTP Cookie _gcl_au Google Tag Manager Used by Google AdSense for experimenting with advertisement efficiency across websites using their services. 3 months HTTP Cookie ads/ga-audiences Google Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. Session Pixel Tracker fr Facebook Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. 3 months HTTP Cookie IDE Google Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user. 1 year HTTP Cookie lpv# Salesforce Used in context with behavioral tracking by the website. The cookie registers the user’s behavior and navigation across multiple websites and ensures that no tracking errors occur when the user has multiple browser-tabs open. 1 day HTTP Cookie pagead/1p-user-list/# Google Tracks if the user has shown interest in specific products or events across multiple websites and detects how the user navigates between sites. This is used for measurement of advertisement efforts and facilitates payment of referral-fees between websites. Session Pixel Tracker pagead/landing [x2] Google Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. Session Pixel Tracker tr Facebook Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. Session Pixel Tracker visitor_id# [x3] Cookiebot Salesforce Used in context with Account-Based-Marketing (ABM). The cookie registers data such as IP-addresses, time spent on the website and page requests for the visit. This is used for retargeting of multiple users rooting from the same IP-addresses. ABM usually facilitates B2B marketing purposes. 10 years HTTP Cookie visitor_id#-hash [x3] Cookiebot Salesforce Used to encrypt and contain visitor data. This is necessary for the security of the user data. 10 years HTTP Cookie VISITOR_INFO1_LIVE YouTube Tries to estimate the users' bandwidth on pages with integrated YouTube videos. 179 days HTTP Cookie YSC YouTube Registers a unique ID to keep statistics of what videos from YouTube the user has seen. Session HTTP Cookie Visitors to our office Who do we collect information about? We collect data about who is present in our offices. What is the source of this information? Information is provided by the visitors when they sign in on our electronic register of who is present in our office. What personal information do we collect? The information collected is: Name Company Car registration number (for offices with car parking) How do we use this data? Data is used to manage the security of our offices, for fire safety and to manage our office car parking. The basis for this processing is that such processing is necessary for our legitimate interests and/or to comply with legal obligations. How long do we retain this data for? Data is retained for one day only. Data collection by others Some of our offices are in properties which are managed by others. The managers of these properties may collect personal data for their own purposes (for example by marinating a register of visitors to the property of by use of CCTV systems). Price Bailey is not the data controller with regard to such information. Photography etc When attending any events organised or sponsored by Price Bailey, photography, video and audio recording may occur. The firm reserves the right to use any such material without the expressed written permission of those included and to use it for promotional purposes. If you desire not to be included please contact the marketing team in writing and outline your intentions. We are more than happy to liaise with you and try to make arrangements so you can attend on your conditions. We reserve the right to change, modify, or update this statement at any time without notice. Disclaimer The information contained on our website is of a general nature and not intended to address the circumstances of any particular individual or entity. Whilst we have made an effort to provide accurate and up to date information, it is recommended that you consult us before taking or refraining from taking action based on matters discussed. 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