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VTech Privacy Policy 

LAST UPDATED June 30, 2023 

For specific information practices with respect to children, please see Section 7 below. 

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VTech Electronics North America, L.L.C. ("VTech") appreciates your interest in our company and your visit to our website, web-connected software applications or other online service (collectively, the "Web Services"). If you do not live in the U.S., please visit www.VTech.com to find the appropriate privacy policy for your use. By using our Sites and Services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to our collection, use, and disclosure of your information as described herein. 

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Remember that your use of the Web Services is also subject to the Terms and Conditions applicable to each service, which incorporate this Privacy Policy. When you visit or use our Web Services interact with customer service representatives, work with us, apply to work with us, or otherwise engage or interact with VTech or its employees, contractors, agents, or representatives, you consent to the collection, use, and disclosure of personal information that we may collect from or about you during your engagement or interaction with us, as described in this privacy policy. 

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Our Web Services may contain links to other websites or services operated by other organizations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal information on a website or service operated by another organization, as we do not accept any responsibility or liability for websites or services of other organizations.

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This Privacy Policy ("Policy") reflects VTech's commitment to protecting your and your children's privacy and personal information. In this Policy, VTech may be referred to as "VTech," "we," "us" or "our." Although VTech sells and promotes children's products, VTech collects information primarily from adults (with the exception of information collected from children—with the consent of their parent or guardian--through Kid Connect/KidiConnect/KidiCom Chat, VTech educational games and other software used by children, and children’s “Wish Lists,” discussed below). Therefore, unless otherwise specified, all references to "you" or "your" in this Policy refer to adult users. 

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DEFINITIONS OF TYPES OF INFORMATION REFERRED TO IN THIS PRIVACY POLICY

"Personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, is linked to, or could reasonably be linked, directly or indirectly, to a particular identified or identifiable individual or household. It does not include de-identified or aggregate data or data that is publicly available.

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“Sensitive personal information” means personal information that applicable privacy laws determine to be more sensitive and therefore warranting more protection. Sensitive personal information is defined as information that reveals: (a) an individual’s Social Security, driver’s license, passport, or other state identification number; (b) an individual’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) an individual’s precise geolocation; (d) an individual’s racial or ethnic origin, religious or philosophical beliefs, mental or physical health condition or diagnosis, medical treatment or diagnosis, sex life or sexual orientation, citizenship or immigration status, or union membership; (e) the contents of an individual’s mail, email, or text messages, unless the business is the intended recipient of the communication; (f) biometric or genetic information for purposes of uniquely identifying a an individual; or (g) information collected from a known child. Should VTech at any time collect sensitive personal information in our interactions with you, we will provide you clear notice of the type of data we collect, what it is used for, and we will obtain your consent before collecting this data. 

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1. Agreement; Modification. 

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Your use of the Web Services constitutes your acceptance of this Policy. If you do not accept this Policy, please do not visit or use the Web Services. VTech may change this Policy from time to time. Each time you visit or use the Web Services, the current version of this Policy will apply. Accordingly, when you visit or use any of the Web Services, you should check the date of this Policy (which appears at the beginning of this Policy) and review any changes since the last version. 

If VTech makes any material changes to this policy regarding the use or disclosure of previously collected information about you, we will notify you by email (if you have registered an account with us) and/or by means of posting a notice on the Web Services prior to the changes becoming effective, and seek your consent to those changes. In addition, if VTech makes any changes to its policy regarding the collection, use, or disclosure of personal information collected from your child, it will notify you and seek your consent.

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2. Information VTech Collects from Users of Web Services. 

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2.1 Information that You Provide. 

To access certain features of the Web Services, you may be asked to provide certain information about yourself and/or your child or children. The types of information that you would need to provide are described below. You may choose not to provide such information when requested. While VTech will not discriminate against you because you exercised the privacy options discussed herein (see Section 9), refusing to provide some information could limit or completely prevent you from being able to use or access certain features of the Web Services. 

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  • Purchases: When making purchases on our Web Services, you may be required to provide your first and last name, email address, billing address, shipping address, phone number, and credit card information. 

  • Learning Lodge: If you register for a Learning Lodge Parent Account, during registration we will collect certain information from you, the parent, including your email address, password, country, state, city, and zip code. During your use of Learning Lodge, we may also collect information about your recent firmware upgrades, purchased devices, downloads and purchases. You may also create a Learning Lodge Child Profile for your child. For this Learning Lodge Child Profile, we will ask you for your child’s name. 

Certain VTech devices may also allow your child to view applications that are available in our Learning Lodge library and create a “Wish List” of applications they like, which is then sent to you. As discussed in Section 7 below, the creation of a Wish List results in the transmission to VTech of the applications selected by your child for inclusion on the Wish List as well as identifying information about your child’s device and console, country and language information, and date and time. 

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  • Kid Connect/KidiConnect/KidiCom Chat: To sign up for Kid Connect/KidiConnect/KidiCom Chat as a parent of a child, you will first create a Learning Lodge Parent Account and Learning Lodge Child Profile, as described above. Then, through your Learning Lodge Account you can complete the Kid Connect/KidiConnect/KidiCom Chat registration. The Kid Connect/KidiConnect/KidiCom Chat registration will use your Learning Lodge username as your Kid Connect/KidiConnect/KidiCom Chat username. During your first use of the Kid Connect/KidiConnect/KidiCom Chat application (for example, on your smartphone), you will set up your Kid Connect/KidiConnect/KidiCom Chat profile by providing a “nickname” (which is the display name shown to other Kid Connect/KidiConnect/KidiCom Chat users), and a profile photo for Kid Connect/KidiConnect/KidiCom Chat (at your option). 

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Additionally, under your Learning Lodge Child Profile, you may create a Kid Connect/KidiConnect/KidiCom Chat Child Profile (for example, through the Kid Connect/KidiConnect/KidiCom Chat app on your smartphone). You can enter your child’s information, including the Kid Connect/KidiConnect/KidiCom Chat “nickname” for your child (which is the display name shown to other Kid Connect/KidiConnect/KidiCom Chat users) as well as provide a Kid Connect/KidiConnect/KidiCom Chat profile photo for your child (at your option). 

During your or your child’s use of Kid Connect/KidiConnect/KidiCom Chat, other limited forms of information may be collected by us, including text, chat, and voice messages, as well as photos and videos that you or your child send or receive. Information practices regarding information collected from children, and the processes for providing consent to your child’s use of Kid Connect/KidiConnect/KidiCom Chat, are discussed more fully in Section 7 below. 

Other activities: If you engage in other activities on our Web Services, including contacting VTech with questions, you may be required to submit certain identifying information to VTech, such as your name and email address. In addition, certain Web Services may ask for or collect additional information about you and/or your children. 

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Note for Login Information. As described above, to set up or access your user account through any of the Web Services, you will be required to enter your username and your password. This is considered "Login Information," which allows us to identify your account and authenticate you as the user of the account. 

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2.2 Information Passively Collected. 

VTech uses the web technologies described below to passively collect information about your visit to a Web Service. This information may include information about your computer, such as its operating system, internet protocol address ("IP Address"), and web browser. It may also include information about your VTech web-connected device and your browsing data. VTech may also collect information about your or your children's use of certain Web Services, as discussed in Section 2.4 and Section 7 below. 

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(a) Cookies. Some of the pages on the Web Services use "cookies" to help us better serve you and other visitors to the Web Services. Cookies are brief text files transmitted by websites to the hard drive of visitors' computers when they click on a website page. Should the visitor return to that page at a later time, the visitor's computer will transmit the text file back to the website server to permit the server to recall previous visits to that page or website or to keep track of a transaction in progress. Cookies retain the user preference like number of selected items per page, and payment gateway source to go to payment gateway and encrypted order ID. 

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(b) Action Tags. Some of the pages of the Web Services use "action tags," which are also known as "clear GIF" or "web beacons." An action tag is an invisible tag that may be placed on certain pages of a website but not the visitor's computer. When you access pages with action tags, those action tags generate a generic notice of that visit. Action tags are not linked to any personally identifiable information about your or your children but may be linked to your IP address. 

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(c) Google Analytics.  VTech uses Google Analytics to analyze trends, track user movement and gather other information. 

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(d) Log Files.  VTech uses log files for security monitoring.. The log files contain information such as your IP Address, visiting date/time, and the webpage visited. 

Do Not Track Signals: Our systems do not currently recognize or respond to browser “Do Not Track” signals. 

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Automated Decision-Making Tools: We use automated decision-making tools or processes in order to prevent misuse of our website and to prevent fraud when you purchase via our website. This may lead to a refusal of the transaction. Should you not agree with this refusal, please contact our customer service department. 

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2.3 When VTech Collects Information from Users of Web Services. 

VTech collects the passively collected information described in Section 2.2 while a user is visiting or using the Web Services. VTech may request or require the information described in Section 2.1 if you choose to participate in any of the following Web Services features: 

  • Create, log in to, use, or manage a Web Services account;

  • Purchase a product or download a software application;

  • Upload play or activity data from a VTech web-connected product (Note: additional details about this feature are provided below);

  • Register products;

  • Participate in promotions;

  • Contact VTech Customer Support; and/or

  • Send messages about VTech products or services. 

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2.4 More Information about Play or Activity Data from VTech Web-Connected Products and Learning Lodge. 

A parent or guardian must set up an account to access Learning Lodge, and the parent or guardian will be asked to provide certain information about his or her child or children that will be using the VTech web-connected product, such as the child's name. Certain VTech devices may also passively record information from children’s play on VTech’s educational games for parent or guardian reference. To access the Learning Lodge features, the parent or guardian must first be logged in to his or her account.

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3. VTech's Use of Information Collected from Users of Web Services. 

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3.1 General Use of Information. 

VTech uses the information collected through the Web Services to: (a) provide products, services, and information that you request; (b) manage user accounts; (c) improve our products and services; (d) enhance and customize the playing experience for users of our web-connected products; (e) provide you with a personalized assessment of your child's learning progress while using our web-connected products; (f) allow VTech to improve the Web Services' content; (g) analyze and monitor consumer activity; (h) promote VTech’s products and services, market updates, special offer through advertising; (i) support VTech's products and services; (j) verify product reviews; (k) to run promotions and special activities that enhance the Web Services experience. 

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3.2 Information about Other Products and Services. 

If you choose to provide the personal information described in Section 2.2, we may use it to identify our products or services that we think you may be interested in purchasing, and unless you opted-out of receiving communications about new products and special offers, we will send you information about those other products or services. 

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3.3 Communications with You. 

From time to time, VTech may use your personal information to send email messages to you regarding your account(s), to respond to any emails or other communications you send to us, and/or to advise you of any problems with the Web Services. We may also use your personal information to communicate with you if you registered for a Web Services account and did not opt-out of receiving promotional emails.

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4. Disclosure of Information Regarding Users of Web Services. 

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VTech may disclose your information to its affiliated companies and to third parties in the following circumstances: 

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4.1 Entities that Provide Services to VTech.

 (a) In responding to your inquiries or providing you with the products or services you request, we may rely on affiliates or other companies to perform functions on our behalf. These functions may include order fulfillment, package delivery, marketing assistance, postal and email delivery, customer service, data analysis, data storage, billing services and credit processing. The entities we contract for these purposes have limited access to your personally identifiable information in order to perform these functions on our behalf, and may not use or disclose it for other purposes. 

(b) VTech may use advertising companies to serve ads on our behalf. These companies may employ cookies and action tags to measure advertising effectiveness. Any information that these companies collect via cookies and action tags is not linked to any personally identifiable information about you or your children, as described in Section 2.1, but it may be linked to other passively collected information described in Section 2.2. 

(c) VTech ensures that any companies to which it discloses your information have adequate policies and procedures in place to protect that information, that they will securely handle, delete or destroy the information when it is no longer needed to serve the companies’ function for us, and that they do not use or disclose the information for any other purpose. 

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4.2 VTech Affiliates 

In order to provide the Web Services, VTech may disclose, transfer, or store your information to/with its affiliates located in the United States, the European Union (EU), the United Kingdom and Hong Kong. All companies in question will handle your information with the same care VTech does, will not disclose your information with other parties or use it for other purposes, and have privacy policies as strict as our own. 

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4.3 Investigations. 

VTech may disclose your information to third parties in the investigation of any actual or suspected: (a) breach of this Policy or our Terms and Conditions, (b) illegal activity, (c) fraud, (d) intellectual property infringement, or (e) threats of violence or other harm. 

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4.4 Merger and Acquisition Activity.

 If we are bought or acquired by another company, in whole or in part; merged with another company; or go through reorganization or bankruptcy, your information may be disclosed to prospective investors, buyers, or other acquirers or successors of VTech in connection with the applicable transaction (and in the case of an acquisition or merger, we may transfer the information collected through the Web Services to the purchaser or merged company as part of the sale). 

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4.5 Other Cases.

 VTech may disclose your information if we in good faith believe we are required to do so: (a) to comply with applicable law or legal proceedings, including court orders, subpoenas, statutes and regulations; (b) to protect, enforce and defend VTech's rights or property; or (c) in an emergency to protect the personal safety of VTech's customers, visitors or the public. 

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4.6 With Your Permission.

 VTech may disclose your information to third parties when you have given us permission to do so.

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5. Protection of Information of Users of Web Services. 

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5.1 Transmission and Storage of Your Information. 

The security of your and your child’s personal information is important to VTech, and VTech is committed to handling your personal information carefully. If you submit your information to VTech directly through the Web Services it will be transmitted over a secure HTTPS connection using TLS technology. Further, VTech stores your personal information, described in Section 2.1 and Section 2.2, in servers with restricted access. Voice messages, photos and videos are encrypted while in storage. The information that VTech collects from you will be transferred to, and stored at, servers in the United States and Hong Kong. 

VTech will retain your personal information only for as long as is reasonably necessary to fulfill the purposes for which it was collected unless a longer retention period is required by law (see Section 8 below). For example, VTech will usually store Learning Lodge and Kid Connect/KidiConnect/KidiCom Chat account and/or profile information only for as long as the parent maintains an active account. VTech does not store one-to-one text messages once the messages have been delivered. In addition, VTech will ordinarily store undelivered Kid Connect/KidiConnect/KidiCom Chat Idiom messages and delivered and undelivered voice messages, photos and videos sent through Kid Connect/KidiConnect/KidiCom Chat for only 30 days, to ensure they are delivered to their recipients. VTech also will store only the last three hundred (300) delivered and undelivered messages in a Group Chat for 30 days. 

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5.2 Login and Authentication. 

VTech also protects your information by requiring users of the Web Services to verify their identities with unique login information before they can access or edit their account information or settings. If you select and establish Login Information in connection with your use of the Web Services, or any other interaction with the Web Services, you are responsible for keeping that Login Information confidential. Do not share your Login Information with anyone else.

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6. Links to Other Websites. 

The Web Services may include access or links to other, third-party websites. If you choose to visit those other sites from the Web Services, VTech is not responsible for the privacy practices or content of those websites. Those third-party websites are beyond VTech's control and may not have privacy policies and security protections, or their privacy policies or security protections may not be as protective of your personal information as VTech's policies and protections. Those other websites may send their own cookies to visitors, collect data or solicit personal information. We recommend that you review and understand the privacy policies of the websites you visit, whether you visit those websites directly or through a link from a page on the Web Services. VTech does not have access to or control over information collected by third-party websites. 

Nonetheless, we seek to protect the integrity of our Web Services and the links placed upon them and therefore we request feedback not only for our own Web Services, but also for websites we link to as well (including if a specific link does not work).

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7. Information Practices Regarding Children. 

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VTech is concerned about the safety and privacy of children when they use the Internet. We encourage parents and guardians to spend time with their children online and to be familiar with the sites their children visit. We also urge children to check with their parents or guardians before entering information on any website, or on any VTech Web Services. Our information practices regarding the collection of information from children are in accordance with the U.S. Children's Online Privacy Protection Act ("COPPA") and are outlined below. 

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7.1 Web Purchases. 

Although VTech sells and promotes children's products, all of our products are intended to be purchased by adults. If you are under 18 years old and you want to buy something on the Web Services, you must have an adult buy it for you. 

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7.2 Operators Collecting Personal Information from Children 

VTech Electronics Limited, a Hong Kong company, and VTech Electronics North America, LLC collect personal information from children, as outlined below. For any inquiries about this Privacy Policy or the companies' information practices regarding children, contact VTech Electronics North America, LLC at: 

Address:

VTech Electronics North America, L.L.C.
1156 W Shure Drive, Suite 200
Arlington Heights, IL 60004
ATTN: Privacy Matters

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Phone:    
1-800-521-2010

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Email:        vtechkids@vtechkids.com

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7.3 Information VTech Collects from Children. 

VTech collects the following information from children as part of the Kid Connect/KidiConnect/KidiCom Chat service: chat and voice messages, photos and videos that the children send to their parents and other users approved by their parents. 

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Certain VTech services may collect information about the child’s device (for push notifications, such as to notify the child that his or her parent has purchased a new downloadable application from Learning Lodge). 

Certain VTech devices may also passively record information from children’s play on VTech’s educational games for parent or guardian reference. 

Certain VTech devices may also allow your child to view applications that are available in our Learning Lodge library and create a “Wish List” of applications they like. The creation of a Wish List results in the transmission to VTech of the applications selected by your child for inclusion on the Wish List, as well as identifying information about your child’s device and console, country and language information, and date and time. If your Learning Lodge Parent Account settings are set to receive notification emails when your child makes a “wish,” VTech will send your child’s Wish List to your contact email address. 

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7.4 Obtaining Verifiable Parental Consent Prior to Use of Kid Connect/KidiConnect/KidiCom Chat.

VTech will only collect, use, or disclose information from your child’s use of Kid Connect/KidiConnect/KidiCom Chat after receiving the verifiable consent of the child’s parent. Parental consent must be provided before a child profile can use Kid Connect/KidiConnect/KidiCom Chat. To provide this consent, you must have first created a Kid Connect/KidiConnect/KidiCom Chat Child Profile for your child, which in turn requires a Learning Lodge Parent Account. The process for creating these parent accounts and child profiles, and the information that will be collected from you, the parent, as part of the account creation process, is described above in Section 2.1. 

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Once you have created these accounts, through your Learning Lodge Parent Account, you can access the portal for managing COPPA consent. Access to this consent portal may be different for different devices. For example, while parents of KidiBuzz users will access this portal through the Learning Lodge web application on a computer, parents of KidiBuzz users may access this portal through the Parental Controls, Privacy Policy Content tab directly on the KidiBuzz or through the “Privacy Policy” consent link at the bottom of the parent’s “friends” list on the smartphone application. Once in that portal, you can select your child’s name from the list of child profiles associated with your account. Then, you can press the “Set COPPA Consent” (or similar) button. This will bring you to a payment gateway with one of our payment providers to make a 50-cent payment. In addition, at that time you will see a pop-up screen providing you with direct notice of VTech’s practices concerning information collected from children, as described in this Section. This process helps to ensure that a parent is in fact providing the consent to VTech’s collection of personal information from children, because the small payment will appear on the parent’s next account statement. After the payment is received, and VTech has confirmed that the payment has been successfully processed, you will receive a message on the screen that consent is complete. At this point, your child will be able to use the Kid Connect/KidiConnect/KidiCom Chat service. If VTech later determines the payment was not authorized by the parent, it will revoke the consent from the associated Child Profile, and that profile will not be able to use Kid Connect/KidiConnect/KidiCom Chat. 

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7.5 Use and Disclosure of Information Collected from Children. 

The information listed in Section 7.3 is generated by children when they use the Kid Connect/KidiConnect/KidiCom Chat service, which allows children to exchange messages with their parents and with other “friends” approved by their parents, or when they play VTech's educational games. In order to provide the Kid Connect/KidiConnect/KidiCom Chat Software and Services, VTech may disclose, transfer, or store the information from your child with its affiliates located in the European Union (EU) and Hong Kong. All companies in question will handle your information with the same care VTech does, will not disclose your information with other parties or use it for other purposes, and have privacy policies as strict as our own. VTech does not otherwise disclose this information to other parties (except when a child shares Kid Connect/KidiConnect/KidiCom Chat voice and chat messages, photos and videos with other Kid Connect/KidiConnect/KidiCom Chat users that have been approved by you) or make it publicly available. VTech also does not enable children to make their personal information publicly available. VTech does not otherwise use the information collected from children for any purpose other than to allow children to exchange messages on Kid Connect/KidiConnect/KidiCom Chat, and to allow children to create their “Wish Lists”. Except as otherwise described in this Section 7, any information we collect from you about your children is treated and handled in the same manner as the information we collect about you. 

Since Kid Connect/KidiConnect/KidiCom Chat allows children to exchange messages, information from your child will be disclosed to the Kid Connect/KidiConnect/KidiCom Chat “friends” with whom your child communicates. Before an individual can become a Kid Connect/KidiConnect/KidiCom Chat “friend” with whom your child can exchange messages, photos or videos, however, he or she must first be approved by you through your Kid Connect/KidiConnect/KidiCom Chat Parent Account. For example, your child cannot initiate a “friend” request on his or her own; only you can initiate a “friend” request on behalf of your child. Similarly, if you receive a “friend” request initiated by another Kid Connect/KidiConnect/KidiCom Chat user, only you can receive and approve that “friend” request to add that user as your child’s “friend.” Kid Connect/KidiConnect/KidiCom Chat users cannot contact your child until they have been placed on your child’s approved “friends” list. 

Once an individual is approved by you, and becomes your child’s Kid Connect/KidiConnect/KidiCom Chat “friend,” he or she will be placed on your child’s “friends” list. Then, when your child exchanges a voice or chat message, a photo or video with that Kid Connect/KidiConnect/KidiCom Chat “friend,” VTech will deliver that message, photo or video to the Kid Connect/KidiConnect/KidiCom Chat “friend,” along with your child’s nickname and profile photo (previously provided by you). 

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7.6 Your Parental Rights Regarding Children's Personal Information 

VTech does not require your child to disclose more information than reasonably necessary to participate in an activity. You have the right to review your child's personal information; direct VTech to delete it; revoke your consent for VTech to collect, use, and disclose information from your child; and refuse to allow any further collection, use, or disclosure of the child's information. Before processing a request to review or delete information collected from your child or to cease collecting, using, or disclosing that information, VTech will verify that you are the parent of the child. For example, to revoke consent, a parent must sign into their Learning Lodge Parent Account. 

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As noted above, VTech will not disclose information collected from your child to any other parties, except as is inherent in the Kid Connect/KidiConnect/KidiCom Chat service, such as when your child’s messages are shared with your child’s Kid Connect/KidiConnect/KidiCom Chat “friends” who have been pre-approved by you. However, even after you have approved a “friend,” you retain control over your child’s Kid Connect/KidiConnect/KidiCom Chat “friends” list. If you determine that you would no longer like your child to be able to share information with previously approved Kid Connect/KidiConnect/KidiCom Chat users, you can remove a user from your child’s “friend” list by accessing your child’s “friends” list through your Kid Connect/KidiConnect/KidiCom Chat Parent Account. 

Moreover, consent to VTech’s collection, use, and disclosure of your child’s information related to the Kid Connect/KidiConnect/KidiCom Chat service can be revoked through the portal for managing COPPA consent in your Learning Lodge Parent Account. However, revoking your consent will mean that your child will no longer be able to use the Kid Connect/KidiConnect/KidiCom Chat service, since the transmission of messages on Kid Connect/KidiConnect/KidiCom Chat requires VTech’s collection and disclosure of your child’s information to other approved Kid Connect/KidiConnect/KidiCom Chat users. 

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If you wish to exercise any of these parental rights, you may contact VTech as described in Section 9 below.

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8. Notices. 

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NOTICE OF COLLECTION 

In the preceding 12 months, we collected for a business purpose the following categories of personal information about you and/or your child(ren). We retain this information only for as long as is reasonably necessary to fulfill the purposes for which it was collected unless a longer retention period is required by law. Unless stated otherwise in the list below or Section 5.1, we determine how long to retain each category of personal information based on (1) the amount, nature and sensitivity of the information; (2) the manner in which the information is necessary to fulfill the purposes for which it was collected; and (3) the amount of time required to properly delete or otherwise cease retention of the information in accordance with data security laws and regulations.

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers. This category includes information such as real names, IP addresses, online identifiers, email addresses, postal addresses, and account and user names;

  • Categories of personal information, including names, telephone numbers, addresses, and credit card information, described in state laws such as subdivision (e) of Cal. Civ. Code Section 1798.80;

  • Characteristics of protected classifications under state or federal law. This category includes people’s age group;

  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category includes products purchased, obtained, or considered;

  • Internet or other electronic network activity information. This category includes analytic cookies, action tags, browsing and search histories, and logs of use of the Web Services;

  • Geolocation data;

  • Professional or employment information;

  • Education information;

  • Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. This category includes information about customers’ previous purchases and preferences; and

  • Sensitive personal information (see below for more information about what sensitive personal information we collect and the purposes for which we use it.)

We collect this personal information from the following categories of sources:

  • You;

  • Your child;

  • Other users of the Web Services (such as people on Kid Connect/Kidi Connect/KidiCom Chat who communicate with you or your child);

  • Customer service and call center;

  • Our affiliates;

  • Cookies, active tags, and tracking technology; and

  • Employees, applicants for employment, emergency contacts or beneficiaries of employees or applicants, or independent contractors who work with us (which include California employees, California applicants for employment, California emergency contacts or California beneficiaries of employees or applicants, or California independent contractors and California representatives of business partners who work with us).

We collect and disclose this personal information for the following business or commercial purposes:

  • Provide the services;

  • Marketing and advertising;

  • To communicate with you and provide customer service;

  • To improve the services and products;

  • To personalize your experience;

  • To complete a purchase; and/or

  • For employment and benefits purposes (including, but not limited to, processing job applications and maintaining employee information). 

In the preceding 12 months, we collected for a business purpose the following categories of sensitive personal information (these categories do not include information that is publicly available). Unless stated otherwise in the list below or Section 5.1, we determine how long to retain each category of personal information based on (1) the amount, nature and sensitivity of the information; (2) the manner in which the information is necessary to fulfill the purposes for which it was collected; and (3) the amount of time required to properly delete or otherwise cease retention of the information in accordance with data security laws and regulations. 

  • VTech account log-in information in combination with a password;

  • The content of messages exchanged by users of Kid Connect/KidiConnect/KidiCom Chat services;

  • Personal information collected from known children as described above;

  • Precise geolocation data. This category includes location cookies and IP addresses; 

  • Categories of the sensitive personal information collected from employees only:

    • Identifiers, such as, alias an individual’s Social Security, driver’s license, passport, or other state identification number; username and passwords;

    • Identifiers for health and financial accounts, including bank account number, credit card number, debit card number, or any other financial information or health insurance information needed for employment purposes;

    • Characteristics of protected classifications under state or federal law, This category includes  age, race, national origin, religion, sex/gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, military or veteran status,  request for all forms of protected leave such as family care, an employee’s own serious health condition, pregnancy or disability leave;

    • Biometric information, This category includes facial images and voice recordings;

    • Audio, electronic, visual, thermal, olfactory, or similar information. This category includes image and audio files;

    • Citizenship or immigration status, birth status of the employee’s beneficiaries, death status of an employee and/or an employee’s beneficiaries.

We collect this sensitive personal information from the following categories of sources:

  • You;

  • Your child;

  • Other users of the Web Services (such as people on Kid Connect/Kidi Connect/KidiCom Chat who communicate with you or your child);

  • Customer service and call center; and

  • Employees, applicants for employment, emergency contacts or beneficiaries of employees or applicants, or independent contractors who work with us (which include California employees, California applicants for employment, California emergency contacts or California beneficiaries of employees or applicants, or California independent contractors and California representatives of business partners who work with us).

We collect, use and disclose this sensitive personal information for the following purposes: 

  • To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;

  • To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;

  • To resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions;

  • To perform services on our behalf, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, etc.;

  • To verify or maintain the quality or safety of a product, service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us; and/or

  • To perform services on behalf of VTech, including but not limited to employment purposes (including, but not limited to, processing job applications and maintaining employee information). 

We do not use or disclose sensitive personal information for any purpose other than those described above or otherwise specified and permitted by law, including the California Consumer Privacy Act (as amended by the California Privacy Rights Act) and regulations issued thereunder. 

Should VTech at any time collect sensitive personal information in our interactions with you, we will provide you clear notice of the type of data we collect, what it is used for, and we will obtain your consent before collecting this data. 

SHARING AND SALE OF PERSONAL INFORMATION, PROCESSING FOR TARGETED ADVERTISING, AND PROFILING

For the purposes of this Section and Section 9, “sell” means disclosure of personal information to a third-party for monetary or other valuable consideration.  “Share” means disclosure of personal information to a third-party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.  “Cross-context behavioral advertising” means the targeting of advertising to a person based on the person’s personal information obtained from the person’s activity across businesses, distinctly-branded websites, applications, or services, other than VTech’s. “Targeted advertising” means displaying advertisements to a person where the advertisement is selected based on personal information obtained from that person’s activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests, but does not include advertisements based on activities within VTech’s own websites or online applications or in response to a person’s request for information or feedback, or processing personal information solely for measuring or reporting advertising performance, reach, or frequency.  “Profiling” means any form of automated processing performed on personal information to evaluate, analyze, or predict personal aspects related to an identified or identifiable natural person's economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. "Decisions that produce legal or similarly significant effects concerning the consumer" means decisions that result in the provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health care services or access to essential goods or services or basic necessities, such as food and water.

VTech does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.  

In the preceding 12 months, we have not knowingly disclosed personal information to third parties in exchange for money.  However, we have disclosed personal information to third parties for the purpose of web analytics, and this disclosure may constitute a “sale” under the broad meaning of some state laws and the definition above.  In addition, we have “shared” and processed personal information for “targeted advertising” within the meaning of those terms provided above.  However, we have not knowingly sold, shared, or processed for targeted advertising the personal information of minors under 16 years of age.   Accordingly, we permit residents of the U.S. to “opt-out” of the “sale,” “sharing,” and processing of personal information for “targeted advertising,” as set forth in Section 9 below. 

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding 12 months, we disclosed for the business purposes described above (to the extent only as necessary) the following categories of personal information to the following third parties.

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Information in this category was disclosed to payment processors, marketing agency, customer service and call centers, logistic services providers, data analysis providers, and other users of the Web Services (such as people with whom you or your child communicates on Kid Connect/Kidi Connect/KidiCom Chat).

  • Categories of personal information, including names, telephone numbers, addresses, and credit card information, described in state laws such as subdivision (e) of Cal. Civ. Code Section 1798.80. Information in this category was disclosed to logistic services providers and payment processors.

  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Information in this category was disclosed to payment processors and logistics services providers.

  • Internet or other electronic network activity information. Information in this category was disclosed to marketing providers and analytic providers.

  • Geolocation data. Information in this category was disclosed to payment processors, logistics services providers and data analytics providers. 

NON-DISCRIMINATION

We will not discriminate against a person because the person exercised a personal information request (as described below), including, but not limited to, by: 

  • Denying goods or services to the person;

  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

  • Providing a different level or quality of goods or services to the person;

  • Suggesting that the person will receive a different price or rate for goods or services or a different level or quality of goods or services; and/or

  • Retaliating against an employee, applicant for employment, or independent contractor for exercising any personal information requests. 

However, we may offer a person a different price or rate or provide a different level or quality or selection of goods or services if the offer is related to the person’s voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program and the difference is reasonably related to the value provided to us by that person’s personal information. In addition, we may offer financial incentives, including payments as compensation, for the collection of personal information, the sale or sharing of Personal information, or the retention of personal information. We will provide notice of the material terms of a financial incentive program before a person enrolls, and will enter a person into such a program only if the person gives us prior opt-in consent, which may be revoked by the person at any time. We will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.  We currently do not offer any financial incentive programs. 

9. Your Privacy Options. 

The purpose of this Section is to inform you of your privacy options. Some states provide these options to their residents as a right, but we want to provide all of our customers and users and others from whom we collect personal information these opportunities to better control how VTech interacts with your and your child(ren)’s personal information. VTech reserves the right to discontinue this policy at any time, and at its sole discretion, and to limit these privacy options to only those residents of those jurisdictions with privacy laws affording the applicable rights. 

REQUEST TO KNOW 

You may request that we confirm whether we process your personal information and that we disclose to you the following information: 

  • The categories of personal information we have collected about you;

  • The categories of sources from which the personal information was collected;

  • The business or commercial purpose for collecting or selling personal information;

  • The categories of third parties with which we share personal information;

  • The categories of personal information about you that we have sold and the categories of third parties to which the personal information was sold;

  • The categories of personal information about you that we have disclosed for a business purpose and the categories of third parties to which the personal information was disclosed; and/or

  • The specific pieces of personal information we have collected about you. 

Please note that all requested information includes information from a 12-month period preceding our receipt of your request. You may request information beyond this 12-month period, and we will provide the information as long as it is not impossible or involve a disproportionate effort for us to do so. 

You may submit a request to know by calling our toll-free number at 1-800-521-2010 or submitting a request at “Contact Us” (vtechkids.com/support/contact_us) or “Personal Information Request Form” (vtechkids.com/support/personal_info_form). Such a request may be referred to as a “request to know.” In the request, please specify whether you are seeking information about categories of personal information and/or specific pieces of personal information. We will verify your identity before complying with any such request. We will require you to provide personal information in order to verify your identity, such as your name, email address, and/or telephone number. For requests to know specific pieces of information that we have collected, we may also ask for information about a product you purchased, and we may ask you to submit a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

 

REQUEST TO DELETE 

You may request that we delete any personal information about you, and that we notify any service provider, contractor, or third-party to delete your personal information from its records. Such a request may be referred to as a request to delete. However, your personal information may not be deleted under certain circumstances allowed by law, including (but not limited to) where maintenance of your personal information is necessary to: complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, to provide a good or service that you requested or that is reasonably anticipated within the context of your ongoing business relationship with us, or to otherwise perform a contract between us and you; to detect security incidents, protect against or prosecute fraudulent or illegal activity; to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; to comply with a legal obligation; or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided that specific data. 

You may request the deletion of such person information by calling our toll-free number at 1-800-521-2010 or submitting a request at “Contact Us” (vtechkids.com/support/contact_us) or “Personal Information Request Form” (vtechkids.com/support/personal_info_form). In the request, please specify that you are requesting the deletion of personal information. Before deleting such personal information, we will verify your identity. We will require you to provide personal information in order to verify your identity, such as your name, email address, and telephone number. 

REQUEST TO CORRECT 

You may request that we correct any inaccurate personal information about you. You may request the correction of such personal information by calling our toll-free number at 1-800-521-2010 or submitting a request at “Contact Us” (vtechkids.com/support/contact_us) or “Personal Information Request Form” (vtechkids.com/support/personal_info_form). In the request, please specify that you are requesting a correction of personal information. Before correcting such personal information, we will verify your identity. We will require you to provide personal information in order to verify your identity, such as your name, email address, and telephone number. 

REQUEST TO OPT-OUT OF SALE, SHARING, AND/OR PROCESSING OF PERSONAL INFORMATION FOR TARGETED ADVERTISING

You may direct us not to use your personal information for targeted advertising by calling our toll-free number at 1-800-521-2010 or submitting a request at “Contact Us”  (vtechkids.com/support/contact_us) or “Personal Information Request Form” (vtechkids.com/support/personal_info_form).

You may also opt-out of targeted advertising by clicking “Cookie Control” button at the upper right-hand corner of our website and selecting “DISABLE ALL” cookies. Or, if your browser supports it, you can turn on the Global Privacy Control (“GPC”) for that particular browser. Please note that we respect GPC for cookies on our website and will automatically opt you out of all but “Cookies essential to the operation of the site” when a GPC setting is detected.  Please visit globalprivacycontrol.org for more information.  Appeal a Denial of a Personal information Request:

Should we deny your personal information request, you may appeal the denial within 60 days from receipt of our decision on your request.  You may submit an appeal by calling our toll-free number at 1-800-521-2010 or submitting a request at “Contact Us”  (vtechkids.com/support/contact_us) or “Personal Information Request Form” (vtechkids.com/support/personal_info_form).

If your appeal is denied, we will provide you with an online mechanism, if available, or other method through which you may contact the Attorney General of your state to submit a complaint or express your concerns.

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AUTHORIZED AGENT 

You may use an authorized agent to submit personal information requests. You may use an authorized agent to submit a request to know by calling our toll-free number at 1-800-521-2010 or submitting a request at “Contact Us” (vtechkids.com/support/contact_us) or “Personal Information Request Form” (vtechkids.com/support/personal_info_form). Authorized agent may submit a request to delete, to correct, or to opt-out, or may submit an appeal by calling our toll-free number at 1-800-521-2010 or submitting a request at “Contact Us” (vtechkids.com/support/contact_us) or “Personal Information Request Form” (vtechkids.com/support/personal_info_form). 

To use an authorized agent, you must provide the agent with signed permission, and the authorized agent must include proof of signed permission from the person on whose behalf the agent is submitting the request.  In addition, you may be required to verify your own identity directly with us . We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to applicable state law (though the agent will be required to submit proof of such power of attorney) or requests made by an opt-out preference signal. 

California Shine the Light Law. California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request please contact us by using “Contact Us” (vtechkids.com/support/contact_us) or “Personal Information Request Form” (vtechkids.com/support/personal_info_form). 

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10. Update or Edit Your Information. 

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If your name, email address, mailing address, or telephone number changes, you should update or correct the relevant information by logging into your Web Services account(s) and editing your information, or by contacting us as described in Section 9.

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11. How to Unsubscribe from Email

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You may opt out of receiving mailings from us by declining to receive such communications at the time of registration or at the time you otherwise provide the information to us. You may also opt-out of receiving mailings by following the instructions in those mailings or by sending an email by using "Contact Us" (vtechkids.com/support/contact_us) on our website. We will continue using your email address for other purposes for which we are not relying on your consent, for example, where we need it in order to fulfil an order. 

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12. Contact Us.

 

If you wish to contact VTech for any reason, including to ask questions or express concerns about our privacy policy or our information practices, please (a) email us by using "Contact Us" (vtechkids.com/support/contact_us); or (b) telephone VTech's Customer Services Department at 1-800-521-2010.

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13. Disputes; Choice of Law and Forum. 

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If you choose to visit the Web Services, your visit and any dispute over privacy are subject to this Policy and the relevant Terms and Conditions for that service (e.g., the Terms and Conditions for vtechkids.com, Learning Lodge, or Kid Connect/KidiConnect/KidiCom Chat). This Policy shall be governed and construed in accordance with the laws of the State of Illinois, excluding its conflicts of law rules. Any dispute arising out of or relating to this Policy or information VTech receives through the Web Services will be subject to the dispute resolution procedures and provisions set forth in our Terms and Conditions.

If you have any inquiries or complaints regarding this privacy policy you should first contact VTech at: 

Address:

VTech Electronics North America, L.L.C.
1156 W Shure Drive, Suite 200
Arlington Heights, IL 60004
ATTN: Privacy Matters

Phone:    
1-800-521-2010

Email:        vtechkids@vtechkids.com

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14. Separate Agreements. 

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If any provision of this Policy is held to be unlawful, void or unenforceable for any reason, then that provision will be deemed to be deleted from this Policy and that deletion will not affect in any way the remaining provisions in this Policy.

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15. Force Majeure. 

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VTech will not be liable in any way for its failure or delay to comply with this Policy if that performance becomes commercially impracticable as a result of any existing or future law, rule or regulation, whether valid or invalid, or any cause beyond VTech's reasonable control, including war, mobilization, insurrection, accident, natural disaster, explosion, rebellion, civil commotion, riot, act of an extremist, terrorist or public enemy, sabotage, labor dispute, lockout, strike, explosion, fire, flood, storm, accident, drought, power failure, inability to obtain suitable and sufficient energy, labor or material, delay of carriers or embargo. VTech also is not responsible for harm, damage, or injury caused by the actions of others.

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16. Entire Agreement. 

 

This Policy constitutes your entire understanding related to information we collect about you or your children, and it supersedes any prior agreements or understandings about that topic not incorporated in this Policy. If more than one version of this Policy applies to any dispute related to that information or the Web Services, the latest version of this Policy will control.

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