Privacy policy – Tin Can

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Privacy policy

Tin Can Privacy Policy

Last Updated: May 21, 2026

This Privacy Policy describes how Tin Can Untechnologies, Inc. (" Tin Can," " we," or " us") collects, uses, discloses, and otherwise processes information about you. This Privacy Policy applies to information we collect when you access or use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our " Services"), use our VOIP phones (" Phones"), and when you otherwise interact with us, such as through our customer support channels or on social media. We may provide different or additional notices of our privacy practices for certain offerings, in which case those notices will supplement or replace the disclosures in this Privacy Policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the " Last Updated" date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Collection of Information

The information we collect about you depends on how you interact with us. In this section, we describe the categories of information we collect and the sources of this information. We want to make clear that the whole family, including children, can use Phones but only adults can use our Services.

Information Adults Provide to Us

We collect information adults provide directly to us. For example, we collect information directly from you when you create an account, make a purchase, fill out a form, communicate with us via third-party platforms, sign up for marketing communications from us, request customer support, or otherwise communicate with us.

The types of information that we collect directly from you include:

●Your Contact Information: We collect your name, email address, mailing/billing address, emergency address, phone number.

●Financial Information: If you make a purchase from us, we work with a third-party payment processor to process your payment information.

●Call Contact Information: We collect the names and phone numbers of contacts that you allow to call or receive calls from your Phone. You can enter this information manually or grant us permission to your contacts through your device.

We may also collect any other information you choose to provide, but please note that we will never require you to provide us with personal information of children (see Children’s Privacy below for more information). We do not collect sensitive personal information, and we ask that you do not affirmatively provide us with sensitive personal information (such as information related to your health, racial or ethnic origin, political opinions, religious beliefs, or criminal history).

Information We Collect Automatically through the Services

We automatically collect information from adults through the Services, including:

●Transactional Information: When you make, exchange, or return a purchase, we collect information about the transaction, such as product or plan details (e.g., whether you buy a Tin Can Flashback or Tin Can Phone and whether you select a Can 2 Can Plan or a Party Line Plan), purchase price, and the date and location of the transaction.

●Device, Usage, and Activity Information: We collect information about how you access our Services, including data about the device and network you use (such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version). We also collect information about your activity on our Services, including the route by which you access our Services, access dates and times, and browsing behavior (such as pages viewed and links clicked).

●Phone Configuration Information: We collect information about your Phone settings, such as quiet hours and other preferences. This information may be CPNI.

●Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies, pixels, and SDKs, to collect information about your interactions with the Services and our marketing communications. These technologies help us improve our Services and marketing communications, personalize your experience, and analyze your interactions with us, including to see which areas and features of our Services are popular and count visits. For more information about the cookies and similar tracking technologies we use, and the choices available to you, see the Targeted Advertising and Analytics and the Your Choices sections below.

Information We Collect Automatically Through Phones

We also collect information automatically from any users of Phones, which could include children if their parents consent to such use (see Children’s Privacy below for more information). This information includes:

●Phone Information: We collect the IP address, hardware model, MAC address, serial number, and phone number associated with your Phone. We also collect information about your Phone's status, including connectivity and operational status.

●Call Logs: We collect information about calls made using Phones, including the phone numbers you call or receive calls from, the date/time of the calls, and the length of the calls. We also collect network quality metrics and other technical data related to call performance. We do not record calls made using Phones.

●Voicemails: We do record and store outbound voicemail greetings and inbound voicemail messages.

Information We Collect from Other Sources

We obtain information from other sources. For example, we may collect contact and device or usage information from advertising networks and data analytics providers. We also collect any information you share with us on social media platforms like Instagram.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.

No obligation to provide Personal Information

You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Services, and you fail to do so where required, we may not be able to provide some or all parts of our Services. We will notify you if this is the case at the time.

Use of Information

We use the information we collect to facilitate voice-to-voice communication via our Phones and to allow parents and guardians to manage their children's access to Phones and contacts.

We also use the information we collect to:

●Process and fulfill your orders and facilitate returns and exchanges;

●Provide, maintain, and improve our Phones and Services;

●Develop new products and services;

●Personalize your experience with us;

●Send you technical notices, security alerts, support messages, and other transactional or relationship messages;

●Send you marketing communications (see below for information about how to opt out of these communications at any time);

●Monitor and analyze trends, usage, and activities in connection with our Phones and Services, including to generate de-identified, anonymized, or aggregated data;

●Target advertisements to you on third-party platforms and websites (for more information and to opt out, see the Targeted Advertising and Analytics section below);

●Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of Tin Can and others; and

●Comply with our legal and financial obligations.

If you are located in the United Kingdom, please see below for the legal bases we rely on for the processing purposes described here.

Targeted Advertising and Analytics

We engage others to provide analytics services, serve advertisements, and perform related services across the web and in mobile applications. To do this, Tin Can and these partners may use cookies, pixels, SDKs, and similar technologies to collect information about your use of our Services and other websites and mobile apps, including your device identifiers, IP address, web browser and mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, order information, items added to cart, and conversion information. We refer to this information as Targeted Advertising Information. Targeted Advertising Information is used to deliver advertising targeted to you on other companies' websites and mobile apps, understand the effectiveness of this advertising, analyze and track data, determine the popularity of certain content, and better understand your activity. We do not permit information collected from Phones or children to be used for targeted advertising.

In addition to ad targeting activities that rely on cookies and similar technologies, we work with advertising partners to translate other identifiers, such as adults' email addresses or phone numbers, into a unique identifier (called a hashed value) that such partners can then use to show ads that promote Tin Can that are more relevant to you across the web and in mobile apps.

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting https://optout.aboutads.info if you are a resident of the US or Canada, or YourOnlineChoices.eu - Your ad choices if you are located in the UK. Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes. If you are located in the UK, you can also opt-out of targeted advertising and other non-essential cookies altogether by making the appropriate selections in our cookie management tool.

Disclosure of Information

We disclose information as described in the Targeted Advertising and Analytics section above and as follows:

●Vendors and Service Providers: We make personal information available to our vendors, service providers, contractors and consultants who perform services on our behalf, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, analytics, and marketing.

●Law Enforcement Authorities and Individuals Involved in Legal Proceedings: We disclose personal information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

●To Protect the Rights of Tin Can and Others: We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Tin Can, our users, the public, or others.

●Professional Advisors: We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

●Corporate Transactions: We disclose personal information in connection with, or during negotiations of, certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

●Corporate Affiliates: We may disclose information between and among Tin Can and any existing and future parents, affiliates, subsidiaries, and other companies under common control and ownership.

●With Your Consent or at Your Direction: We make personal information available to other third parties when we have your consent or you intentionally direct us to do so.

We also may disclose aggregated or de-identified information that cannot reasonably be used to identify you. Other than as described in this Privacy Policy, we do not share your personal information with (and we never sell your personal information to) third parties.

Protection of information

We are committed to protecting your personal information. We take appropriate technical, organisational and physicalsecurity measures designed to protect your personal information (including to prevent your personal information from misuse, interference or loss, and from unauthorised access, modification or disclosure). For example, we limit access to your personal information to only those employees and other staff who have a business need to have such access. All such people are subject to a duty of confidentiality. We also use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information.

Please note that despite the efforts described above, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.

Retention of Information

We are committed to only keeping your personal information for so long as we reasonably need to use it for the purposes set out above. This general rule applies unless a longer retention period is required by law.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information that we have collected about you, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Third-party Links

The Services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your personal information. We do not control these third-party websites, plug-ins, and applications and are not responsible for their privacy statements or practices. We encourage you to read the privacy policy of every third-party site you visit.

International Transfers

We may transfer your personal information out of Australia, New Zealand, Quebec, and/or Canada to the United States and other countries from time to time in the ordinary course of our business, functions or activities. Once transferred, your personal information may be subject to laws that have different standards of protection and may allow for foreign law enforcement and governmental access.

If you are located in the United Kingdom, please see the Transfers Outside the UK section below.

Your Choices

Account Information

You can access, correct, and delete certain information stored within your Tin Can account at any time by logging into the mobile app and navigating to the settings menu.

If you are a resident of Quebec, we will inform you if we exclusively use automated processing to render a decision about you. You also have the right to request information about the personal information used to make that decision, and to request that the information be corrected.

Cookies and Similar Tracking Technologies

Tin Can uses cookies and similar tracking technologies, as described above.

You can usually adjust your browser settings to remove or reject browser cookies. If you are located in the UK, you can control or limit how cookies and similar technologies are used by managing your preferences (including by opting-out) at any time by using our cookie management tool. Please note that removing or rejecting cookies could affect some of the functionality of our Services. For example, we may not be able to recognize your device and you may lose items that you previously placed in your online shopping cart.

Communications Preferences

We obtain your consent to send marketing and promotional emails where we are required to do so by law. You may opt out of receiving promotional emails from Tin Can by making the appropriate selection when you purchase a Phone from us, or by following the instructions in any promotional emails we send to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders.

If you are a resident of Canada, New Zealand, or Australia, we will only send you commercial electronic messages ("CEMs") where we have your express or implied/inferred consent to do so. Your consent to receive CEMs may be implied or inferred where we have an existing business relationship with you. You may unsubscribe from receiving CEMs at any time by clicking the “Unsubscribe” link in a promotional email.

Mobile Push Notifications

With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Your New Zealand and Australian Privacy Rights

If you are located in New Zealand or Australia, you have a right to request access to or correction of your personal information held by us. If you wish to access, correct or update any personal information we may hold about you, please contact us using the contact details below. We will provide access to your personal information in accordance with applicable law, subject to certain exceptions which may apply. For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.

Your UK Privacy Rights

If you are located in the UK, please refer to the subsection entitled Your UK Privacy Rights below.

Children's Privacy

Collection of Children's Information: If parents consent when creating an account or paying for Phones or Phone service, we may collect limited information about their children as described below. You are not required to provide us with any affirmative information about children to use the Phones or the Services. However,

●if you choose to enter a child’s name on your Phone’s caller ID or in your Phone’s list of contacts, we will collect that information;

●if you choose to allow a child to record an outbound voicemail greeting or leave a voicemail for another Phone, we do record and store those messages; and

●if you allow your child to make calls using the Phone, we will collect the information under “Device Information” and “Call Logs” noted in the section entitled Information We Collect Automatically Through Phones above.

If you have provided us with any of the above children’s information, note that we will never share it publicly.Please also see the “Parents’ Rights” subsection below.

Use of Children's Information: To the extent we collect or store information about children as disclosed in this Privacy Policy, we use such children's information for internal reasons like delivering voicemails and for customer support. We do not create profiles about children, and we never show them targeted ads.

Disclosure of Children's Information: To the extent we collect or store information about children as disclosed in this Privacy Policy, we may disclose such children's information to companies that provide services to us, to law enforcement, courts, and others if the law requires, to protect the rights of Tin Can and others, to any future corporate affiliates, in the event of a corporate transaction, or to others with parental consent (as described in the "Disclosure of Information" section above).

Parents’ Rights: Parents can

●Review: See the information we have, if any, about their children; or

●Delete: Ask us to erase the information we can associate with their children.

If you or your child is located in the UK, you can also exercise additional rights with respect to children’s personal information as described in the Your UK Privacy Rights subsection below.

For Individuals Located in the United Kingdom

GDPR

When we use the term “GDPR” in this Privacy Policy, we are referring to the so-called UK Data Protection Regulation. Under the General Data Protection Regulation, we are a ‘controller’ for the activities covered by this Privacy Policy.

When we refer to “information” or “personal information” in this Privacy Policy, we mean any information which identifies you as an individual or which otherwise renders you identifiable.

Transfers of personal information outside the UK

We are located in the United States. Your personal information will consequently be processed by us in the United States. We may also share your personal information with third parties who are based in the United States and/or in other countries outside the UK. Where we share your personal information with third parties who are based outside the UK, we try to ensure a similar degree of protection is afforded to it as it would have had it remained in the UK, by implementing one of the following mechanisms:

●Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the UK Government (from time to time) or under specific adequacy frameworks approved by the UK Government (from time to time), such as the UK Extension to the EU-U.S. Data Privacy Framework.

●Transfers to territories without an adequacy decision. We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (including to recipients in United States, who are not certified under the UK Extension to the EU-U.S. Data Privacy Framework noted above).However, in these cases:

owe may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in the UK – for example, standard-form contracts approved by relevant authorities for this purpose; or

oin limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us using the details above if you want further information on the specific mechanism used by us when transferring your personal information outside of the UK.

Your UK privacy rights

The GDPR may give you certain rights regarding your personal information and how we process it in certain circumstances, meaning you may ask us to take the following actions in relation to your personal information:

●Access. Provide you with information about our processing of your personal information and give you access to your personal information.

●Correct. Update or correct inaccuracies in personal information.

●Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

●Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.

●Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.

●Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.

●Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

To exercise any of the rights described above, please contact us using the contact details shown above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfil any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Legal Bases

We use your personal information for the purposes listed above (see the 'Use of Information’ section) and any associated sharing of personal information (see the ‘Disclosure of Information’ section).

In respect of each of the purposes for which we use your personal information, the GDPR requires us to establish a ‘legal basis’ for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below.

●Where we need to perform a contract we have entered into with you or are about to enter into with you (“Contractual Necessity”).

●Where it is necessary for our pursuit of legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”).

●Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

●Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).


ORDER FULFILMENT
Purpose: To process and fulfil your orders and facilitate returns and exchanges. Categories of personal information: ●Contact Information ●Financial Information ●Transactional Information Legal basis: ●Contractual Necessity
SERVICE OPERATION AND MAINTENANCE
Purpose: To provide, operate and secure the Services – including: managing access and use of the Services, allowing us to perform our agreements with you, and securing the operation of and access to the Services. Categories of personal information: ●Contact Information ●Subscription Information ●Device, Usage and Activity Information ●Information Collected by Cookies and Similar Tracking Technologies Legal basis: ●Legitimate Interests. We have a legitimate interest in managing access to the Services and ensuring the ongoing security and proper operation of our Services our business and associated IT services, systems and networks. ●Contractual Necessity
PHONE OPERATION AND MAINTENANCE
Purpose: To provide, operate and secure the operation of Phones. Categories of personal information: ●Call Contact information ●Phone Configuration Information ●Phone Information ●Call Logs ●Voicemails Legal basis: ●Contractual necessity.
IMPROVEMENT AND ANALYTICS; NEW PRODUCTS AND SERVICES
Purpose: To analyse your usage of our Services and Phones, understand user activity, improve the Services and Phones and to develop new products and services. Categories of personal information: ●Device, Usage and Activity Information ●Information Collected by Cookies and Similar Tracking Technologies Legal basis: ●Legitimate Interests. We have a legitimate interest in improving our Services and Phones and in developing new products and services. ●Consent. Applicable in respect of any optional cookies used for this purpose.
PERSONALISATION
Purpose: To personalise your experience with the Services (including remembering your selections and preferences as you navigate). Categories of personal information: ●Contact Information ●Device, Usage and Activity Information ●Information Collected by Cookies and Similar Tracking Technologies Legal basis: ●Legitimate Interests. We have a legitimate interest in providing you with a good service which is personalised to you and that remembers your selections and preferences. ●Consent. Applicable in respect of any optional processing relevant to such personalisation (including in respect of any optional cookies used for this purpose).
DEALING WITH YOUR CONTACTS WITH US
Purpose: To deal with any contact you might make with us using any 'Contact us' or similar function on the Services or via any other method of communication (e.g., by email), as well as any issues arising from such contacts (including replying to you). Categories of personal information: ●Contact Information ●Any and all other data types relevant in the circumstances. Legal basis: ●Legitimate Interests. We have a legitimate interest in communicating with you and dealing with your contacts with us, as well as handling any issues that may arise from such contacts.
MARKETING AND RELATIONSHIP MANAGEMENT
Purpose: To communicate with you (including to provide updates on our activities, the Site, the Platform and any other products or services), including as part of our marketing activities and/or for customer, vendor or partner relationship management purposes. Categories of personal information: ●Contact Information Any and all other data types relevant in the circumstances. Legal basis: ●Legitimate Interests. We have a legitimate interest in promoting our business and sending marketing and in administering our relationship with our actual and prospective commercial counterparties. ●Consent. Where consent is required by law for the sending of promotional or marketing communications.
TARGETED ADVERTISING
Purpose: To serve you with advertisements on third-party platforms and websites which we think will be of interest to you. Categories of personal information: ●Device, Usage and Activity Information ●Information Collected by Cookies and Similar Tracking Technologies, including Targeted Advertising Information Legal basis: ●Consent. We only serve targeted advertising where you have consented to such advertising.
PRIVACY PROTECTIVE STEPS
Purpose: We may aggregate, deidentify or anonymise certain personal information for our legitimate business purposes. If we aggregate, deidentify or anonymise your personal information such that it is no longer personal information (i.e., it can no longer be associated with you), we may use this information as non- personal information indefinitely without further notice to you. Categories of personal information: Any and all data types relevant in the circumstances. Legal basis: ●Legitimate Interests. We have a legitimate interest in taking steps to ensure that how we use personal information is as un-privacy intrusive as possible. We believe it is also in your interests that we take these privacy protective steps.
COMPLIANCE AND PROTECTION
Purpose: To comply with applicable laws, lawful requests, and legal process (such as to respond to disclosure orders or similar, as well as investigations or requests from government authorities); to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); to audit our internal processes for compliance with legal and contractual requirements or our internal policies; to enforce the terms of agreements that govern access to the Services (including our agreements with enterprise customers); and to prevent, identify, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft. Categories of personal information: Any and all data types relevant in the circumstances. Legal basis: ●Compliance with Law. ●Legitimate Interests. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
CORPORATE EVENTS
Purpose: To facilitate or carry out any corporate events (including providing personal information to allow third parties to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). Categories of personal information: Any and all data types relevant in the circumstances. Legal basis: ●Legitimate interests. We and any relevant third parties have a legitimate interest in us providing information to certain third parties who are involved in or assisting with actual or prospective corporate events for these purposes.
FURTHER USES
Purpose: We may use your personal information for further uses beyond those described above, we only do this with your consent or whether those further purposes are compatible with the initial purpose for which personal information was collected. Categories of personal information: Any and all data types relevant in the circumstances. Legal basis: ●The original legal basis, for ‘compatible further uses’. ●Consent. Applicable for ‘non-compatible further uses’.

Contact Us

If you have questions about this Privacy Policy, please contact us at:

Tin Can Untechnologies, Inc.

Attn: Privacy Requests

300 Lenora Street

PMB 820

Seattle, WA 98121

legal@tincan.kids

If you are located in New Zealand or Australia, you can contact us at legal@tincan.kids.

If you are based in the United Kingdom, you can contact us using the contact details above, or you can contact EDPO UK Ltd, who we have appointed in accordance with our obligations under the GDPR by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/ or by writing to EDPO UK at Unit 33, Waterside, Schooner Court, 44-48 Wharf Road, London, N1 7UX, United Kingdom.

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your personal information, please contact us using the contact details shown above. We will reply to your complaint as soon as we can. If you make a complaint to us, we will investigate your complaint and determine what action to take. When contacting us, please provide as much detail as possible in relation to the query, issue or complaint. If you are not satisfied with the outcome of your inquiry, data protection laws give you the right to contact the relevant regulator directly:

●For users in Australia – the Office of the Australian Information Commissioner (http://www.oaic.gov.au/);

●For users in New Zealand- the Office of the Privacy Commissioner (https://www.privacy.corg.nz); and

●For users in the UK – the UK Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/)

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