Privacy notice

Introduction

Fastmarkets provides commodity price benchmarks and analysis critical to our customers’ business processes and workflows. It provides prices across the supply chain from the creation of the commodity to recycling in the metals and mining, forest products and agriculture markets.

Fastmarkets and its group companies are committed to respecting the privacy of every person who visits, registers with or subscribes to our websites, publications, events and other products or services, or about whom we otherwise collect personal data.

This privacy notice describes how we use your personal data. Please read it carefully along with our Cookies Notices. We may make changes to this notice from time to time, so please check it regularly. We will make you aware when it has been updated.

Data Controller

Fastmarkets provides commodity price benchmarks and analysis critical to our customers’ business processes and workflows. It provides prices across the supply chain from the creation of the commodity to recycling in the metals and mining, forest products and agriculture markets. There are a number of businesses in our family. You can find out more about these businesses on our website. Fastmarkets is the official Data Controller of your personal data. This Privacy Notice applies to all Fastmarkets businesses. To complement our global approach to privacy protection, this policy also incorporates specific information privacy rights granted to individuals under California and Chinese privacy laws. This reflects our relationship with our customers in these locations.

Data Protection Officer

If you wish to exercise your rights under data protection law, you can do so by contacting us at the details under the heading How to exercise your rights.

The personal data we process

We collect your personal data when you visit our sites and apps, subscribe for products or services, register for, and attend our events, contribute to our businesses or when you otherwise interact with us. We have described below the personal data that we process, what we use it for and where we get it from (which, in each case, may vary depending on the way in which you engage with us).

Personal data type

What we use it for and our lawful basis for processing

Where we get it from

Personal data that you provide to us when you register with one of our websites and/or sign up for a free trial of our products or services. This includes your name, address, email address and telephone number and details relevant to your occupation and employer. It will also include payment details.

To provide you with the product and/or service that you have requested. Our lawful basis is that it is necessary to process this information to fulfil the contract we are about to enter into or have entered into with you.

You

Personal data that you provide when you register for one of our events. This includes your name, address, email address and telephone number and details relevant to your occupation and employer. It will also include payment details.

To complete your registration for an event and to allow you to participate in the event. Our lawful basis is that it is necessary to process this information to fulfil the contract we are about to enter into or have entered into with you.

You

Personal data that you provide to us when you engage with us that relates to your health.

So that we are able to make reasonable adjustments due a personal condition that you may share with us.

You

Personal data that you provide to us when you engage with us.

To send marketing to you. We rely on our legitimate interest to contact you in relation to products and/or services that may be of interest to you.

We provide you with the opportunity to object to receipt of marketing at the time we collect your information, and you can change your preferences at any time.

You

Personal data that you provide to us when you engage with us.

To share with sponsors of our events so that they can contact you in relation to products and/or services that may be of interest to you.

We rely on our legitimate interest to share this information with our sponsors for this purpose. We provide you with the opportunity to object to this information being shared.

You

Information from apps, through your browser or device and your IP address (“Transaction Data”)

This is statistical data and does not identify your individual device. This might be your computer type, screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version for example.

  • To monitor usage and performance of our products, services, processes and platforms, perform analysis (e.g. statistical, market, product analysis), reporting and forecasting;
  • To understand how you interact with our products, services and platforms;
  • To perform checks and prevent, detect, investigate and report usage contrary to our terms and conditions.

We are relying on our legitimate interest to help us understand, develop, improve our products and services and our legitimate interest to manage risk and security.

Your device

Personal data which relates to you and your employment – such as email address, phone number, job title, address, purchase history and account information

To create “segments” of particular audiences so that we can improve the quality and relevance of our sales and marketing activities and provide offers that are relevant to you and your profile.

We rely on our legitimate interest to market our products and services.

You

Your personal data to create a “segment” of particular types of audiences so that we can show you advertisements which may be more relevant to you and the “segments” you may be in.

We use third parties to deliver cookies that collect technical information, including how you interact with our site (e.g. browsing information, which articles you have read etc)

To deliver advertisements to you which may be of interest to you.

We rely on our legitimate interest to market our products and services.

Where we use cookies or other tracking technology, please see our cookie notice for more information and detail on how to manage your cookie choices through your privacy settings.

Your device

Some of your personal data together with Technical Data on your device

To share with third parties to deliver targeted advertising to you on other websites (e.g Facebook Customer Audiences). This could include your email address and cookies, web beacons or other tracking technology to monitor your online behaviour and identify website usage, helping advertisers show you advertising and content that is more relevant to you. This is also known as behavioural advertising.

Third parties, such as Facebook and Google, will have their own privacy policies which you can find below:

Google

You can find more information about how Google uses data that it receives here: https://policies.google.com/technologies/partner-sites

Facebook Custom Audience

For further details in relation to Facebook Custom Audience, please visit https://www.facebook.com/legal/terms/customaudience.

Where we send data to Facebook, we are a Joint Controller with Facebook. This Joint Controller relationship is subject to Facebook’s Controller Addendum.

Facebook is the independent Data Controller once it is in receipt of that data. You can find more information about Facebook’s processing at https://www.facebook.com/policy.php

When processing your information for these purposes, we are relying on our legitimate interest to help us market our products and services.

You

Personal data which may allow us to contact you

To share with trusted third parties to verify the information that we hold and ensure that it remains accurate.

We rely on our legitimate interest to provide you with our products and services.

You and trusted third parties

Personal data that allows us to contact you

To request your feedback and/or ask you to participate in customer and/or market research.

We rely on our legitimate interest to understand, develop and improve our products and services.

You

Personal data that you have provided to us

If we sell a business or assets, we may need to disclose your personal data to the prospective buyer of such business or assets. If Fastmarkets, or any of our group companies, is sold or sells our assets or is acquired by a third party, then personal data about our customers will be acquired by that third party. A transfer of your personal data in these circumstances would be necessary so that the services you have contracted for can still be delivered, or so that you can continue to enjoy the benefits of our products and services. You will receive notice if a new controller assumes responsibility for your personal data.

We rely on our legitimate interest to sell businesses for operational or strategic purposes.

You

Transaction Data

We may include small pixel tags (small image files) within the emails we send you in order to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. We may also collect browser, location and the device used to engage with our email communications. This information allows us to better understand whether we are meeting our users’ needs and how we can improve our communications. No other information is collected.

We rely on our legitimate interest to understand, develop and improve our products and services.

Your device

Publicly available data

To carry out sanctions screening to prevent transactions with persons prohibited from certain transactions and/or activities.

We rely on our legal obligation to carry out sanctions screening and our legitimate interest to manage risk, security and prevent crime and data that you provide to us.

Independently audited third parties.

Publicly available data

To send marketing to you. We obtain such information from trusted sources.

We rely on our legitimate interest to contact corporate subscribers in relation to products and/or services that may be of interest.

We always provide the opportunity to object to receipt of future marketing at the time we send materials and provide the ability to change preferences at any time. We will not send materials to persons who have previously told us they do not want to receive marketing.

Trusted databases


Personal data that you have provided to us

To protect the security and resilience of our networks/applications and respond to technical and security incidents.

We rely on our legitimate interest to manage risk, security and crime prevention.

You

Personal data that you have provided to us

To enable us to provide legal and/or regulatory advice in line with our business activities.

We rely on our legitimate interest to satisfy our industry, regulatory and legal requirements and exercise our rights.

You

How we store your personal information

Data SecurityWe have put in place 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 those 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 personal data breach and will notify you and the relevant data protection regulator of a breach where we are legally required to do so.

Data RetentionWe have a data retention policy that ensures we don’t use or store your personal data for longer than necessary. We consider the following to determine retention periods:

Guidance from the UK Information Commissioner and other regulatory agencies, as well as industry best practice recommendations;

  • The use(s) of the personal data;
  • The business rationale for collection and expiry of the purpose for which personal data was collected;
  • Our ongoing ability to ensure the accuracy of the data; and
  • Legal and regulatory requirements.

We may occasionally need to keep personal data for either shorter or longer periods than specified in our retention policy. In such circumstances, application of the retention period to the data will be temporarily suspended. The suspension of any retention period will be carried out in a manner that respects the rights and interests of all persons concerned.

Our third parties

We use third parties to enable, perform or improve a range of our business processes. These may require us to share your data with third parties and/or they may share your data with us. These third parties may include (but are not limited to):

1. Third parties that enable us to understand, develop, improve and market our products and services;

2. Third parties that enable us to carry our regulatory checks – for example sanctions screening;

3. Third parties that work with us to help us fulfil on and service your products and services;

4. Third parties that support the running of our business processes;

5. Third parties that provide reporting, banking or tax management services and enable us to manage our business financials and performance;

6. Other third parties, bodies or institutions where we are required by regulation, law, industry practices or to detect/prevent fraud, crime, terrorist activity or business risks eg regulators, law enforcement bodies and crime prevention bodies.

Some of our third parties may be international. See ‘International transfers’ to understand how we manage our data internationally.

International transfers

Fastmarkets has offices around the world. Your data may be transferred to or accessed globally.

As well as other Fastmarkets operations, the service providers we share your data with may have operations in the UK, the EEA and elsewhere in the world.

While some countries - for example those in the European Economic Area (“EEA”), the Isle of Man, Andorra, Argentina, Guernsey, Israel, Jersey, New Zealand, Switzerland and Uruguay are recognised as having must have the same high standard of data protection as offered in the UK, other parts of the world may not guarantee that same level of protection. When we share your data with anyone outside of the UK and the EEA, where necessary, we always put in place the safeguards required by law to ensure that a consistent high level of protection travels with your data.

If you would like more specific details about the safeguards in place when transferring your data, please contact us.

How You Can Set Your Data & Privacy Preferences

You can use our Preference Centre to select the topics that are of interest to you so that we can send you publications and information about our products and services that are especially relevant to you. You can also choose the channels we use to contact you (email, phone, post, etc.) and can also opt-out of receiving communications.

For Individuals Who Are in The UK and European Economic Area: Your Rights

You have certain rights in relation to your personal data which include the following:

Your data protection rights

Under data protection law, you have rights including:

· Your right of access

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

· Your right to rectification

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

· Your right to erasure

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

· Your right to restriction of processing

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

· Your right to object to processing

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

· Your right to data portability

You have the right to ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances.

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

How to Exercise Your Rights

To exercise any of these rights, please contact us by post or email at the following addresses:

Data Protection
8 Bouverie Street, Temple, London EC4Y 8AX
Email: dataprotectionofficer@delinian.com

We may need to check your identity prior to processing a request. We will do our best to respond to any questions and address any of your concerns.

You also have the right to complain directly to the Regulator regarding the processing of your personal data - the Information Commissioner in the UK or the regulatory body of the country where you live. You can contact the UK Information Commissioner at the link provided or in writing to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

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

For other regulatory bodies, this information is readily available. But, you can contact us should you require assistance.

Additional Disclosures for California Residents

We have explained our privacy practices in full in the other sections of this Privacy Notice. In this section, we provide a list of the categories of personal information set out in the California Consumer Privacy Act (“CCPA”) that have been collected, the purposes for which those categories of information are collected or used, and the business purposes (as defined in the CCPA) for which those categories are disclosed. In the twelve months preceding the date this Privacy Notice took effect, we have not sold personal information although we do use standard Internet advertising and analytics tools provided by third parties that rely on cookies and other tracking technologies (see our Cookie Settings for more information), and we may disclose your information with your consent and for the business purposes described below.

Categories of personal information collected:

  • Internet or other electronic network activity information, e.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer’s interaction with a website, application, or advertisement.
  • Demographic and statistical information, including information regarding personal characteristics of protected classifications under California law like race and gender
  • Device information and other personal identifiers, e.g., name; alias; postal address; online identifiers; IP address; email address; account name.
  • Professional, education, or employment-related information, e.g., business name or job title.
  • Geolocation information
  • Commercial or transactions information, e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Inferences, e.g., inferences drawn from the information identified in this Privacy Notice to create a profile about a consumer reflecting the consumer’s preferences, predispositions, behavior, etc.

Purposes for which the categories of personal information are collected or used:

  • To provide online platforms.
  • To communicate with you.
  • To improve and develop online platforms.

Purposes for which the categories of personal information are disclosed for business purposes or sold:
We disclose these categories of personal information for business purposes. For example, we share this information:

  • To our service providers.
  • To protect our lawful interests.

Subject to certain limitations, you have the right to: request to know more about the categories and specific pieces of personal information we collect, use, and disclose; request deletion of your personal information; opt out of any “sales” of your personal information that may be occurring; and not to be discriminated against for exercising these rights.
To access any of your rights described in this section (for customers who are California Residents), please submit your request by submitting the CCPA Data Request form. When you exercise your rights, we may seek to verify your identity, for example by verifying purchases you have made with us. If we receive your request from an authorised agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorised agent seeking to make a request, please contact us. We will not discriminate against you for exercising your rights.

Additional Disclosures for Individuals in the People’s Republic of China

中华人民共和国境内个人额外披露事项

我们处理个人信息的法律依据

我们将依照合法、正当、必要、善意的原则处理您的个人信息。如有需要,我们将在处理您的个人信息之前取得您的同意。特别是,当我们处理您的敏感个人信息时,我们将按照法律、行政法规的规定,取得您的单独同意或书面同意。

如果我们对您的个人信息的处理超出本隐私声明的内容,我们将通过页面提示、互动流程、网站公告等方式向您单独说明处理的目的、方式和范围,并再次取得您的同意。

如果涉及直效营销,我们将征求您的同意。您始终有不作回应的自由,并可随时轻松撤回同意。

您完全知悉,在以下任一情形中,我们可以无需取得您的授权和同意而处理您的个人信息:

  • 为订立、履行您作为一方当事人的合同所必需,或者按照依法制定的劳动规章制度和依法签订的集体合同实施人力资源管理所必需;
  • 为履行法定职责或者法定义务所必需;
  • 为应对突发公共卫生事件,或者为保护自然人的生命健康和财产安全所必需;
  • 为公共利益实施新闻报道、舆论监督等行为,在合理的范围内处理个人信息;
  • 依照法律、行政法规的规定在合理的范围内处理您自行公开或者其他已经合法公开的个人信息;
  • 法律、行政法规规定的其他情形。

我们如何分享您的信息
我们不会与第三方分享您的个人信息,除非我们取得您的单独同意,或者按照法律法规的规定无需取得您的同意。

我们可能会与活动赞助商分享您的姓名、职务、公司、地址、电话号码和电子邮箱地址。由于活动赞助商不时变换,我们将在分享您的个人信息之前告知您赞助商的名称和联系方式以及处理的目的和方式,并取得您的单独同意。

如果我们因合并、分立、解散、被宣告破产等原因需要转移您的个人信息,我们将通知您接收方的名称或者姓名和联系方式,并敦促接收方继续根据本隐私声明处理您的个人信息。否则,我们将要求接收方在处理之前再次取得您的同意。

存储地点和国际转移

您的个人信息将被存储在中华人民共和国境外。Fastmarkets(https://www.fastmarkets.com)是一个全球性组织,其将接收您的个人信息(姓名、职务、公司、地址、电话号码和电子邮箱地址)。

我们还可能与公司的关联方分享您的个人信息,以便其向您发送营销材料。

我们将采取法律规定的必要措施,包括取得您的单独同意,与境外接收方签订标准合同条款以约定双方之间的权利和义务,确保外国接收方按照适用法律的规定对您的个人信息提供充分保护。

您可以通过本隐私声明中所列的联系方式与我们或海外接收方联系,以行使个人信息方面的权利。

您享有的额外隐私权利

根据《个人信息保护法》的规定,您享有以下权利:

  • 知情权:您有权知悉您的个人信息的处理情况。此外,您还有权要求我们解释本隐私声明以及我们处理个人信息的规则。
  • 查阅权和复制权:您可以要求查阅您的个人信息或者取得您的个人信息的副本。
  • 更正权和补充权:如果您发现您的个人信息不准确或不完整,可以要求我们予以更正或补充。
  • 删除权:在某些情形下(例如:您撤回了同意,或者处理个人信息的目的已经实现、无法实现或者为实现处理目的不再必要),您可以要求删除您的个人信息。
  • 转移权:当符合有关部门规定的条件时,您可以将您的个人信息转移至您指定的个人信息处理者。
  • 作出决定、限制和拒绝的权利:您可以对您的个人信息的处理作出决定,并限制或拒绝我们处理您的个人信息。
  • 撤回同意的权利:您可以撤回同意。请理解,每项服务均需要若干基本的个人信息来完成。在您撤回同意后,我们将不再处理相关的个人信息,并因此而无法向您提供相应的服务。但您撤回同意并不影响之前基于您的授权所进行的个人信息处理。

为安全起见,我们在处理您的请求之前可能会核实您的身份。我们将在核实您的身份后及时响应您的请求,并在核实您的身份后15天内作出答复和合理解释,或告知您解决纠纷的外部途径。
在以下情形中,我们将无法响应您的请求:

  • 与我们履行法律法规规定的义务相关的;
  • 与国家安全、国防安全直接相关的;
  • 与公共安全、公共卫生、重大公共利益直接相关的;
  • 与刑事侦查、起诉、审判和判决执行等直接相关的;
  • 我们有充分证据表明您存在主观恶意或滥用权利的;
  • 出于维护您或其他个人的生命、财产等重大合法权益但又很难得到本人同意的;
  • 响应您的请求将导致您或其他个人、组织的合法权益受到严重损害的;
  • 涉及商业秘密的。

如何联系我们
如果您对本隐私声明和您的个人信息的处理有任何疑问或疑虑,可以将您的问题发送至 dataprotectionofficer@delinian.com 或发送至以下地址:Fastmarkets,香港铜锣湾登龙街18号V-Point 12楼。

保护您的信息

我们将努力确保您的个人信息安全,并采取适当的技术和组织措施保护您的个人信息免遭丢失、未经授权的使用、披露或破坏。尽管我们会尽最大努力保护您的个人信息,但我们无法保证任何信息传输均无风险。

我们要求我们的所有员工、承包商和信息处理者(即代表我们处理个人信息的第三方)对上述信息保密,不将其用于除履行我们要求的服务之外的任何目的。

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN THE PEOPLE’S REPUBLIC OF CHINA

We also comply with specific requirements stipulated by PIPL (“Personal Information Protection Law of the People’s Republic of China”) and other relevant Chinese rules and regulations. This section of the Privacy Notice supplements the information in this rest of the Notice.

Our Legal Basis for Processing the Personal Information We will process your personal information in accordance with the principles of legality, legitimacy, necessity, and good faith. We will obtain your consent before processing your personal information, where required. Especially, when we want to process your sensitive personal information, we will obtain your separate consent or your written consent according to laws and administrative regulations.

If we process your personal information beyond the content in this Privacy Notice, we will separately explain the purpose, method, and scope of such processing to you through page tips, interactive processes, website announcements, etc., and obtain your consent again.

When it comes to directing marketing, we will request your consent. You will always be free not to respond. You could easily withdraw the consent at any time.

You’re fully aware that we may process your personal information outside the need to obtain the authority and consent from you, under any of the following circumstances:

  • where it is necessary for the conclusion or performance of a contract to which you are a party, or for the implementation of human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with the law;
  • where it is necessary for the performance of statutory duties or statutory obligations;
  • where it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person;
  • where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of personal information is within a reasonable scope;
  • where it is necessary to process the personal information disclosed by you or other personal information that has been legally disclosed within a reasonable scope in accordance with the provisions of this law; and
  • other circumstances prescribed by laws and administrative regulations.

How We Share Your InformationWe will not share your personal information with a third party unless we obtain your separate consent or in circumstances where your consent is not required according to laws and regulations.
We may share your name, job title, company, address, telephone number and email with event sponsors. Due to the fact that event sponsors will differ from time to time, we will inform you of the name and contact information of the sponsors, purpose and method of processing and obtain your separate consent before sharing your personal information.

Where we need to transfer your personal information due to merger, division, dissolution or declaration of bankruptcy, etc., we will notify you of the name and contact information of the recipient, as well as urge the recipient to continue to process your personal information based on this Privacy Notice. Otherwise, we will request the recipient to obtain your consent again before processing.

Storage Location and International Transfers Your personal information will be stored outside of the People’s Republic of China. Fastmarkets is a global organisation and will receive your personal information (name, job title, company, address, telephone number and email).

We may also share your personal information with our corporate affiliates, for them to send you marketing materials.

We will take necessary measures required by laws including obtaining your separate consent, concluding standard contractual clauses with the overseas recipient to stipulate the rights and obligations between us, and will ensure that the foreign receiving party provides adequate protection for your personal information under applicable laws.

You could contact us or the overseas recipient to exercise personal information rights through the contact information listed in this Privacy Notice.

Your Additional Privacy Rights Under the stipulations of PIPL, you have the following rights:

  • Right to be informed: You have the right to know the processing of your personal information. In addition, you have the right to ask us to explain this Privacy Notice and the rules governing our processing of personal information.
  • Right to access and copy: You can request access to your personal information or obtain a copy of your personal information.
  • Right to correct and supplement: You can request that we to make corrections or supplements where you find that your personal information is inaccurate or incomplete.
  • Right to delete: You can request the deletion of your personal information in certain circumstances (for example if you withdraw your consent, or the purpose of personal information processing has been achieved, it is impossible to achieve such purpose, or it is no longer necessary to achieve such purpose;)
  • Right to transfer: You can transfer your personal information to a personal information processor designated by you when it meets the conditions stipulated by the authorities.
  • Right to make decisions, restrict and refuse: You can make decisions on the processing of your personal information and restrict or refuse that we process your personal information.
  • Right to withdraw your consent: You can withdraw your consent. Please understand that each service needs some basic personal information to be completed. After you withdraw your consent, we will not process the relevant personal information, and cannot provide you with the corresponding services as a result. However, withdrawal of consent by you will not affect the previous personal information processing based on your authorization.

For security, we may verify your identity before handling your request. After verifying your identity, we will respond to your request in time, and give a reply and reasonable explanation within 15 days after verifying your identity, or inform you of the external ways to solve the dispute.
We will not be able to respond to your request under the following circumstances:

  • Related to our compliance with the obligations under the laws and regulations;
  • Directly related to national security or defense security;
  • Directly related to public security, public health or major public interests;
  • Directly related to criminal investigations, prosecutions, trials and enforcement of court decisions, etc.;
  • Where we have sufficient proof that you have subjective malice or abuse of rights;
  • For the purpose of safeguarding your life, property and other important legal rights and interests or those of other individuals but it is difficult to obtain consent;
  • Responding to your request will cause serious harm to your legitimate rights and interests, or those of other individuals or organizations.
  • Involving trade secrets.

How to Contact UsIf you have any questions or concerns regarding this Privacy Notice and the processing of your personal information, you can send your questions to or to the following address:.
Protecting Your Data We endeavor to keep your personal data secure and take appropriate technical and organizational measures to protect your personal data from loss, unauthorized use, disclosure or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk.

All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.

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