Privacy Policy

| Staff

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Effective: July 1, 2020

Updated: July 9, 2020

This Privacy Policy describes the type of information that HigherEducation.com and its affiliates (“we”, “our”, “us”) may collect for our own purposes, how we use, protect, and share that information, and the choices that you have. In some circumstances, we may receive or process personal information on behalf of a client. This Privacy Policy does not describe all the information we may collect on behalf of or receive from our clients as a service provider. It also does not describe how we use, protect, or share that information. In those situations, the privacy policy of the client will apply. 

Types of Information We May Collect

The following provides examples of the type of information that we may collect on our own behalf:

  • Demographic Information. We may collect personal information such as your location. The purpose for collection and use of this data is that we have a business need to understand our users and provide tailored services.
  • Account Registration. We may collect your name and contact information when you create an account. We may also collect information relating to the actions that you perform while logged into your account. The purpose for collection and use of this data is that we have a business need to provide account related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history. 
  • Client Information. We may collect contact information such as name, e-mail, address and/or phone of our business clients and their employees with whom we may interact. The purposes for collection and use of this data is that we have a business need to make our website operate efficiently and to provide our business clients with ability to save preferences such as login and preferred language.
  • E-mail Interconnectivity. If you receive e-mail from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. The purpose for collection and use of this data is that we have a business need to understand how you interact with our communications to you.
  • Feedback/Support. If you provide us feedback or contact us for support we may collect your name and e-mail address, as well as any other content that you send to us, to reply. The purpose for collection and use of this data is that we have a business need to receive and act upon your feedback or issues.
  • Mailing List. If you sign up for one of our mailing lists we collect your e-mail address or postal address. The purpose of collection and use of this data is that we have a business need to share information about our products or services.
  • Partner Promotion. We collect information that you may choose to provide as part of a co-branded promotion with another company. The purpose of collection and use of this data is that we have a business need to fulfill our promotions.
  • Surveys. When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. The purposes of collection and use of this data are that we have a business need to understand your opinions and collect information relevant to our organization.
  • Sweepstakes or contests. When you choose to participate in a sweepstakes or contest, we collect information about you, which includes contact information to notify you if you are selected. The purpose of collection and use of this data is that we have a business need to operate the contest or sweepstakes. In some contexts, we are also required by law to collect information about those that enter our sweepstakes, and we have a business interest in complying with those laws.
  • Mobile Devices. We may collect information from your mobile device such as unique identifying information broadcast from your device when visiting one of our websites. The purposes of collection and use of this data are that we have a business need to identify unique visitors and understand how users interact with us on their mobile devices.
  • Website interactions. We use technology to discover how you interact with our website (e.g., session replay). This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. The purposes of collection and use of this data are that we have a business need to understand how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a business need to detect and prevent fraud.
  • Cookies. We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. We use cookies, and other technologies, to track devices across time and when they visit different websites that deploy or monitor our cookies. See our Cookie Policy for more information. The purposes for collection and use of this data is that we have a business need to make our website operate efficiently, provide you with different website experiences, and to provide you with ability to save your preferences such as login and preferred language. We also participate in behavior-based advertising, which means that technology (e.g., a cookie) is used to collect information about your use of our websites to provide advertising about products and services tailored to your interests on our website, or on other websites. Again, please see our Cookie Policy for more information. The purposes for collection and use of this data are that we have a business need to engage in behavior-based advertising and capture website analytics.
  • Cross-Device Tracking. We and our service providers may collect and store information about users’ interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. The purposes for collection and use of this data are that we have a business need to understand our users’ use of our sites across devices in order to allow users to use our services on one device and pick up seamlessly where they left off on another device. We also have a business need to provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices.
  • Web logs. We may collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. The purpose for collection and use of this data is that we have a business need to monitor our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

When a we receive or processes personal information on behalf of one of our clients, the client generally determines what information we receive, our purpose in processing the information, and how we will use the information.

Data Analytics

We use certain web analytics services, including third-party services such as Google Analytics, to help us understand and analyze how visitors use the site. We may receive reports based on the use of these technologies on both an individual and aggregated basis. These analytics services, including third-party services such as Google Analytics, also use this information to place advertisements for our products on other websites that you visit after your use of the Site. These advertisements may be based on the pages you visited during your use of the Site. For further information about how Google may use data it collects through the Site you may click here. You also may choose to install the Google Analytics Opt-Out Browser Add-on to opt out of Google Analytics data collection.

Use and Processing of Information

In addition to the purposes and uses described above, we use information that we collect on our behalf in the following ways:

  • To identify you when you visit our websites.
  • To provide products and services.
  • To improve our services and advertiser product offerings.
  • To conduct analytics.
  • To respond to inquiries related to support, employment opportunities or other requests. 
  • To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
  • For internal administrative purposes, as well as to manage our relationships.
  • To automatically build user profiles and marketing segments based on the interests of particular groups. These profiles do not have legal or similarly significant effects on individuals.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete an online purchase we may collect your information to perform our contract with you, but we also collect your information as we have a business need in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our need to conduct our business.

Sharing of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

  1. Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company using appropriate safeguards, including at the negotiation stage. 
  2. Our Business Clients. When we collect information on behalf of our business clients, we share that information with our clients. 
  3. Public. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
  4. Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
  5. Service Providers. We may share your information with service providers. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, other administrative functions, process payments, and assist in the fulfillment of orders.
  6. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  7.  Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

Social Features

Some of our websites may include features that are designed to permit interactions that you initiate between our site and third-party websites or services, including third-party social networks (collectively, “Social Features”). For example, you may be able to “like” or “share” content from our site on other websites or services, such as Facebook, Twitter, Instagram, YouTube, and LinkedIn.

If you use Social Features on our site, both us and the third-party services that operate those Social Features may have access to certain information about you and your use of both our site and theirs. The information we collect in connection with your use of Social Features, such as usage information, is subject to this Privacy Policy. The information collected and stored by the third parties remains subject to those third parties’ privacy practices, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third-party websites or services.

Your Choices

You can make the following choices using our online firm here regarding your personal information:

  1. Access to Your Personal Information. You may request access to your personal information that we collect on our own behalf. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. We will require, at minimum, your name, phone number, and email address as part of the process to verify your identity. We may require additional information to verify your identity dependent upon the sensitivity of the personal information we return to you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing. 
  2. Changes to Your Personal Information. We rely on you to update and correct your personal information. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain information, contact us at the address described below. If we are processing your information on behalf of one of our clients, we will forward your modification request to that client and/or follow any instructions provided by that client concerning the modification of information. 
  3. Deletion of Your Personal Information. When we collect information on our own behalf, we typically retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in some situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. If we are processing your information on behalf of one of our clients we will forward your deletion request to that client and await instructions on whether the information should be deleted. 
  4. Objection to Certain Processing.   When we process information on our own behalf, you may object to our use of your personal information by contacting us at the address described below. For example, California residents may be entitled to object, or opt-out, of having their information sold to third parties. If you are a California resident and would like to opt-out of having your information sold, please visit the following link: Do Not Sell My Personal Information. We do not discriminate against California consumers who exercise any of their rights described in this policy and we do not have actual knowledge that we sell any personal information of a minor under age 16. 
  5. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
  6. Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional e-mails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional e-mails, we may still send you service related communications.
  7. Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by e-mailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
  8. Text Messages and Push Notifications.If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP” or “UNSUBSCRIBE.” You control on your device whether you receive push notifications.
  9. Revocation of Consent. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Note that, as required by law, we will require you to prove your identity. Depending on your request, we will require, at minimum, you to provide your name, phone number, and email address. We may require additional information to verify your identity dependent upon the sensitivity of the personal information we return to you.

If you do not want to make requests for access, deletion, or Do-Not-Sell using our online form, you may call 877-336-3738. To get in touch with us about any other privacy requests, you may contact us at privacy@redventures.com or in writing at:

Red Ventures, LLC

C/O HigherEducation.com

1101 Red Ventures Drive

Fort Mill, SC 29707

Attn: Privacy Officer

An authorized agent may make any of the requests above by using our online form or contacting us as noted above.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. If we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Miscellaneous

The following additional information relates to our privacy practices:

  • Transmission of Information to Other Countries. As a multi-national company, we may transmit information between and among our affiliates. As a result, your information may be stored and processed in any country where we have facilities or in which we engage service providers. We take steps to treat personal information using the laws of the country in which we first received your information.
  • Third Party Applications/Websites. We do not control the privacy practices of websites or applications that we do not own. Users are encouraged to read the privacy policy of those properties to make an informed decision regarding use of them.
  • Changes to This Privacy Policy. We may change our privacy policy and practices over time. We will post a notice to our website to inform you of any material changes to our privacy policy and indicate when it was most recently updated. Material policy changes will apply only to information collected after the date of the change. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
  • Collection of Information from Children. We recognize the importance of protecting the privacy and safety of children, and our website and services are directed towards a general audience and are not directed towards children. We do not knowingly collect information about children under the age of 13 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 13 has provided personal information through one of our websites, we will use reasonable efforts to remove that information from our databases.
  •  Information for California Residents. California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we collect on our own behalf and how we share that information in this notice. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the “Contact Information” section below.  

Cookie Policy

Cookies on our services

When you use our services, you may receive cookies or other similar technologies such as pixel tags from us and the third parties that collect information on our Services. We use cookies to determine that we give you a high-quality experience on our Services. We also use cookies to show you advertising that is relevant to you.

However, if you prefer, you can change your cookie settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. You may elect to reject cookies by adjusting your settings, but doing so will limit the range of features available to you on our Services and other major websites that use cookies.

To opt out of interest-based advertising across browsers and devices, please opt out through the Digital Advertising Alliance website and also through the settings within the mobile app or your mobile device. Your opt-out choice may apply only to the browser or device you are using when you opt out, so you should opt out on each of your browsers and devices if you want to disable all cross-device linking for interest-based advertising. If you opt out, you will still receive ads but they may not be as relevant to you and your interests.

Our Services also occasionally use “local shared objects” (also known as “Flash cookies”). Like browser cookies, Flash cookies may be used for coordinating content delivery, website functionality, maintaining preferences, advertising, or analytics. Unlike browser cookies, “Flash cookies” are not stored in the browser. You may be able to manage these Flash cookies by visiting the Adobe website.

There are four types of cookies used on our services:

1. Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without these cookies, services such as shopping activity and paying activity cannot be provided. These cookies also help keep our Services safe and secure.

2. Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.

3. Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.

4. Content / advertising cookies – These cookies gather information about your use of our Services so we may improve your experience and provide you with more relevant content and advertising. They are also used to gather feedback on customer satisfaction through surveys. They remember that you’ve visited our Services and help us understand usage of our Services. Some of these cookies are from third parties that collect information about users of our Services (as described below under “Information collected by third parties on our Services”) in order to provide advertising (on our Services and elsewhere) based on users’ online activities (so-called “interest-based advertising”) on our Services and elsewhere online. The third parties involved in interest-based advertising collect internet browsing information (e.g., websites visited, time of visit) across different websites and over time, and they may use the information they collect on our Services to provide you ads (from us and other companies) across the internet. 

EEA/UK Addendum

The following Addendum applies to users who reside in the European Economic Area (“EEA”) and the United Kingdom, the provisions of which shall prevail over conflicting provisions in this Privacy Policy for EEA/UK residents only.

1. Data Controller

For the purposes of data protection law, the controller is Red Ventures (“we,” “us,” or “our”), comprising of Red Ventures, LLC, of 1101 Red Ventures Drive, Fort Mill, SC, 29707, and its affiliated companies, as appropriate.

2. Addendum to Types of Information We Collect

Generally, we collect information from people in the EEA/UK in a similar manner, and for similar legitimate business purposes, as described above “Types of Information We Collect”

3. Our Legal Basis for Processing

Our legal basis for processing your personal data will typically be one of the following:

Consent

You have actively given your informed consented to our processing of your personal data by completing a form on the site, or have indicated your consent with another affirmative act.

Legitimate Interests

We have a Legitimate Interest in processing your personal data, and our reasons for it do not override your data protection rights. Our Legitimate Interests in processing your personal information are:

  • To ensure our website(s) meets the high standard of usability and security you would expect;
  • To help us identify areas for improvement;
  • To enable us to communicate effectively regarding services we offer; and
  • To enable us to process candidate applications, contacts, queries, or complaints.

Legal Obligation

It is necessary for us to process your personal data for us or another Red Ventures company to comply with our legal or regulatory obligations.

Contractual Obligation

It is necessary for us to process your personal information to perform the tasks associated with a contract to which you are a party, or to take steps at your request prior to you entering into a contract.

4. Your Data Rights

In addition to your rights of access and correction (rectification) described above in “Your Choices”, EEA and UK residents have certain other rights defined in the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Consent Withdrawal – You have the right to withdraw your consent in relation to our processing of your personal data based on your consent.

  • You can unsubscribe from our marketing e-mails at any time using our e-mail preferences page, or by clicking on the “unsubscribe” link.
  • If located in the United Kingdom or European Union, you can opt out of EDAA members online advertising networks and behavioral advertising through the European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page here.

Erasure – You have the right to ask us to right to request deletion of your personal data in certain circumstances.

Restriction of Processing – You have the right to request that we restrict the processing of your data in certain circumstances.

Object to Processing – You have the right to object to the use or disclosures of your personal data.

Data Portability – You have the right to request we transmit your personal data to you or another company in certain circumstances.

We process all requests in accordance with the law, and there may be legal reasons why we cannot fulfill all requests.

Please contact us dpo@redventures.com if you wish to make a request. We have one month to respond to you. You are not required to pay any charge for exercising your rights.

5. International Transfer

We operate in the United States and transfer, store and process personal data outside of the EEA/UK, using approved data transfer mechanisms (for example, the EU Standard Contractual Clauses) to ensure your personal data are adequately safeguarded.

U.S. Privacy Shield

We, along with our affiliates New Imagitas, Inc. (ExpertFlyer.com) and The Points Guy, LLC, participate in and have certified our compliance with the EU-U.S. Privacy Shield Framework. Red Ventures is committed to subjecting all personal data received from European Union (EU) member countries and the United Kingdom, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

We are responsible for the processing of personal data received, under the Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and the UK, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

TRUSTe

6. Cookies

As described above (“Information We Collect Automatically”), with your consent, we use cookies to help us analyze, improve, secure, and market our website and services, and to support functionality which enhances your browsing experience. You can read more about how and why we use cookies on our cookie policy below.

7. Questions & Concerns

If you have any comments or questions, or are concerned about the way in which we have handled any privacy matter, you can contact us using the details below:

Post: Data Protection Officer, Red Ventures, The Cooperage, 5 Copper Row, London, SE1 2LH, United Kingdom

E-mail: dpo@redventures.com.

You may also contact us at privacy@redventures.com or in writing at:

Red Ventures, LLC

1101 Red Ventures Drive

Fort Mill, SC 29707

Attn: Privacy Officer

Complaints (UK)

You also have the right to lodge a complaint about our processing of your personal information with the Information Commissioner’s Office, which is the Supervisory Authority in the UK. Contact details are as follows: https://ico.org.uk/concerns/ or 0303 123 1113 or casework@ico.org.uk/ 

For California Residents – Information Sharing Disclosure

California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that companies should disclose whether the following categories of information are transferred for consideration or for an organization’s “business purpose” as that term is defined under California law. Note that while a category may be marked that does not necessarily mean that we have information in that category about you. The following chart only applies to information that we collect on our own behalf, and for our own purposes; it does not include information that we collect as a service provider to another company.

Category of Personal Information That We CollectTo Whom We Disclose Personal Information for Business PurposeTo Whom We Sell Personal Information
Identifiers: such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, social security number, driver’s license number, passport number, or other similar identifiers.Service Providers
Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
None
Financial information: such as bank account number, credit or debit card number, or other financial information.Service Providers
Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
None
Commercial information: such as information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Service Providers
Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
None
Network activity data: internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.Service Providers
Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
None
Geolocation data: such as precise physical location.Service Providers
Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
None
Electronic and sensory data: such as audio, electronic, visual, thermal, olfactory, or similar information (e.g., pictures, a recording of a customer service call, security video surveillance footage).Service Providers
Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
None
Professional/employment information: such as occupation and professional references.Service Providers
Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
None
Inferences: drawn from any of the information listed above to create a profile.Service Providers
Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
None

10/7/2020 12:11:17

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