Scope of this Policy

Last Revised: September 6, 2023

 

Strategic Education, Inc. is the parent company of Capella University, LLC, Strayer University, LLC, Sophia Learning, LLC, Capella Learning Solutions, LLC, and Workforce Edge, LLC. Students and learners from each of these institutions shall be referred to collectively as “students.”

Strategic Education, Inc. or one of its wholly owned subsidiaries (collectively, “SEI”, “our”, “us”, or “we”) owns and operates this website. This Privacy Policy (“Policy”) describes our privacy practices with respect to Personal Information we collect from you, including through this website or any SEI-owned website or application that links to this Policy, when we provide academic products or services to you, or when we otherwise interact with you in other contexts (collectively, the “Services”).

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, to a particular individual or household.

This Privacy Policy is referenced in and is an integral part of the Terms of Use governing your use of our Services. Please take a few minutes to review our Terms of Use, if you have not already done so.

If you are a student (or are applying to become a student) at an educational institution that is wholly owned by SEI and your education records are protected under the Family Educational Rights and Privacy Act (“FERPA”), then provisions of FERPA and the institution’s FERPA policy supersede and govern over any contrary provisions in this Privacy Policy. To learn more about FERPA, click here for the Capella University FERPA policy, or click here for the Strayer University FERPA policy.

Where additional information is needed to explain our privacy practices with respect to a specific website, application, or activity, we may provide you with a supplemental privacy notice. These additional notices are collectively referred to as “Privacy Notices”. These Privacy Notices may advise you that different policies and practices apply to the information collected in that context, in which case those different policies and practices will supersede this Privacy Policy.

Note that we may be required by law to collect certain Personal Information about you, or as a consequence of our contractual relationship with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.

How We Collect Personal Information

We collect Personal Information when you contact us, interact with or use our Services (including online courses), and in some cases may obtain Personal Information from business partners and other third parties. 

Personal Information we collect directly from you

SEI collects Personal Information directly from you, such as when you contact us, fill out an information request form, submit an admissions application, respond to a job listing, make a purchase, register for an event, or otherwise directly interact with us online or through an app. For example, if you submit an application, we collect the information you provide as part of the online application process. Likewise, we collect the information you provide when you create an account, post text, photographs, images, illustrations, graphics, sounds, video and audio-video clips, and other content you and others post on or through our Services and that does not constitute “Feedback” as defined by our Terms of Use (collectively “User-Generated Content” or “UGC”). This may include collecting the following types of information:

• Personal details (e.g., your name, date of birth, place of birth)
• Contact details (e.g., email, phone number, postal address)
• Demographic details (e.g., age, gender, race, ethnic origin, languages spoken, nationality, status, military or veteran status)
• Identification numbers (e.g., SSN or other government-issued ID number)
• Authenticating information (e.g., usernames, passwords, security questions and answers)
• Admissions information (e.g., personal essay, writing sample, transcripts, test scores, letters of recommendation, evaluations, employment history, disciplinary records)
• Financial aid, scholarship, and tuition-related information (e.g., information collected via financial aid or scholarship applications, information about your or your family’s financial situation, payment information used for tuition, records of tuition payments or amounts due)
• Academic information (e.g., academic interests, preferences, course selections)
• Health and medical information (e.g., medical history, immunization records, disabilities and related accommodations, allergies, dietary restrictions, health insurance information)
• Insurance information (e.g., information necessary to secure and facilitate the provision of insurance)
• Preferences and recreational affiliations (e.g., communication preferences, extracurricular interests, membership with clubs or affinity groups)
• Family information (e.g., marital status, names of relatives who attended an SEI institution or are otherwise affiliated with SEI, emergency contacts, next of kin, information relating to spouses, children, and other family members)
• Photographs and videos (e.g., obtained during application or enrollment)
• Social media information (e.g., social media contact information)
• Communications you send us (e.g., emails, form feedback, or other communications you submit)
• Other information you may provide (e.g., how you heard about our Services)

Personal Information we may generate about you

Depending on our relationship with you, we may generate the following personal information about you:

• Student identification numbers (e.g., applicant number, Student ID)
• Academic and financial aid-related information (e.g., information from our institutional records; current degree program of interest, grades and test scores, credits earned or attempted, disciplinary records, transcripts, financial aid status, teacher feedback, or recommendations)
• Records of our interactions with you and internal notes (e.g., interview or meeting notes)
• Alumni-related information (e.g., alumni records, communication preferences)
• Photographs and videos (e.g., captured during participation in an SEI-sponsored activity or via security cameras at SEI facilities)
• Information about unlawful activity (e.g., details of incidents or allegations of unlawful activity)
• Information we generate as a result of your use of our websites or other online Services (e.g., our understanding of your interests and preferences, whether you are a regular or occasional user or visitor)
• Other information we may generate about you (e.g., event attendance records)

Personal Information we collect automatically

When you access our Services online, we may automatically collect Personal Information about your device or use of the Services over time and across different websites, including the use of “cookies” and similar technologies. Cookies are small text files that are saved onto your device using your web browser and which allow us to recognize your device when you return. We automatically collect the following types of information:

• Technical data collected from your computer or device (e.g., IP address, browser and device type, operating system, geographic location, internet service provider, profile demographics)
• Usage information (e.g., the websites you visit, search terms you enter, date and time of your visit, how often you visit our Services, URLs of sites you access before or after visiting our Services, the content you engage with on our Services, email clicks or other actions taken)

Personal Information we obtain from third parties

We may also obtain additional information about you from third-party sources, including publicly available information (e.g., information from public databases, User-Generated Content (provided by other individuals), social media platforms (e.g., if you choose to automatically populate requested data fields with information you previously provided to a third-party social media platform such as Facebook or Twitter), academic institutions, and service providers. These types of information may include:

• Personal, contact, or demographic details (as described above)
• Application or admissions-related information (e.g., application information as described above, transcripts, test scores, credential services, recommendations)
• Employment information (e.g., confirmation of prior employment, references)
• Financial information (e.g., financial aid eligibility, scholarship awards)
• Student conduct information (e.g., complaints brought by you, against you, or those to which you may be a witness, related reports, information, or evidence)
• Feedback and other information from third parties (e.g., information from internships, partner institutions, and others)

Sensitive Personal Information we collect

Some of the types of Personal Information we collect may be considered sensitive in certain jurisdictions. In particular, we may process the following types of sensitive Personal Information:

• Health and medical information
• Information about your racial or ethnic origin
• Criminal history information (where permitted by law)
• Citizenship or immigration status
• Social security number, state ID, passport number or other government issued ID

Account log-in credentials, passwords, security questions and answers

How We Use Personal Information

The categories of information we collect through our Services are listed below. We generally use the information we collect for the following purposes:

• To provide educational services, including through Courseroom (as described below)
• To provide the information, products and services you request
• To provide you with effective customer service
• To provide you with a personalized experience when you use our Services
• To help you connect with other students, such as if you use iGuide
• To contact you with information and notices related to your use of our Services
• To contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us)
• To invite you to participate in surveys and provide Feedback to us (in accordance with any privacy preferences you have expressed to us)
• To improve the content, functionality and usability of our Services
• To better understand your needs and interests
• To improve our products and Services
• To improve our marketing and promotional efforts
• For security, credit or fraud prevention purposes
• To identify and authenticate you, such as when you log into an account or access specific Services
• Exercising or defending our rights or the rights of a third party
• To detect, prevent, and respond to claims of violations of law or our stands of conduct, university policies, or our terms of use
• Complying with our legal and regulatory obligations
• Safety and security purposes, including protecting the security of our facilities, websites, information, Services, and other property; protecting the safety of students, faculty, staff, and others when visiting our facilities or using our Services
• Program planning, development, and administration purposes
• Keeping our records accurate and up to date
• Research purposes, including research relating to academic and learning outcomes and preferences
• Admissions purposes, including evaluating candidates and application materials, and making admissions decisions
• Academic program purposes, including registration and enrollment in connection with academic programs and program management, planning, development, and administration
• Financial aid and scholarship purposes, including determining financial aid and scholarship awards, considering financial aid and scholarship application materials, administering financial aid and scholarships

We may also deidentify Personal Information so that it cannot be used to identify you and is no longer considered Personal Information under applicable laws. We will maintain and use this data only in deidentified form and will not attempt to re-identify the data.

How we use sensitive Personal Information

We use sensitive Personal Information for the following purposes:

• Health and medical information. To the extent we process health and medical information, we do so to comply with obligations under social protection laws (e.g., to provide disability accommodations) or, where not required by law, to provide medical services under the responsibility of authorized medical professionals or when such processing is necessary to protect the vital interests of you or another person. Where applicable, this information may be processed with your consent.
• Information about sensitive demographics. To the extent we process information revealing racial or ethnic origin, religious or philosophical beliefs, or sexual orientation, such information is voluntarily disclosed during the application process for purposes of statistical reporting related to diversity. Where applicable, this information may be processed with your consent.
• Criminal history information. Where permitted by law, to the extent we process criminal history information, we do so to comply with our legal obligations or, where not required by law, to serve our legitimate interests in ensuring that applicants meet appropriate professional standards or requirements of third-party sites at which students wish to perform fieldwork.
• Citizenship or immigration status, social security number, passport, state ID, or other government-issued ID. To the extent we process such information, we do so in connection with our provision of the Services, for example, to determine eligibility to participate in academic programs or in connection with financial aid applications.
• Account log-in credentials, passwords, security questions and answers. To the extent we process such information, we do so to identify and authenticate individuals accessing the Services.

Legal basis for processing Personal Information

Where applicable, we rely on the following legal bases to process Personal Information:

• To comply with our contractual obligations to you
• To comply with legal obligations to which we are subject
• Where necessary to serve our legitimate interests, including our interests in providing and maintaining the Services; efficient management and administration of our Services and business; protecting the health and safety of our students, alumni, employees, and other third parties; improving our Services, including academic programs, websites, tools, and related content; communicating with you; targeting our marketing and outreach efforts; program planning and development; keeping our facilities, property, and Services safe and secure; supporting the health and wellbeing of our students; keeping our records up to date; customizing your experience with the Services
• Where applicable under local law, with your consent

Online Courseroom

Content You Submit to Courseroom. With respect to SEI online students, you will be expected to generate original content and submit that content for evaluation by your instructor through an online courseroom. The assignments you submit may be accessible to your classmates. For example, a particular course may require you to interact with your classmates through a discussion board in the courseroom, and your instructor may grade you on your participation. You should understand that if you post content in the courseroom in a manner accessible to your classmates, it may be more widely disseminated. For example, one of your classmates could re-post that content to another Web site.

As on any of our Services, the content you submit to the courseroom must comply with our Terms of Use and with any other applicable policies, such as the student code of conduct.

SEI’s Use of Content You Submit to Courseroom. SEI uses the content you submit to the courseroom primarily to evaluate your performance in a particular course and to assign you a grade. In addition, feedback you submit during the course and the instructor evaluation you submit at the end of a course may be used to improve the course and other SEI products, programs and services. SEI may also use information available through the courseroom for academic advising purposes and may contact you about services and products that may be of interest to you. For example, if you perform poorly in a particular course, SEI may use information available through the courseroom to identify a remediation course that may improve your performance, and it may contact you about enrolling in that course.

How We Disclose Personal Information

With Third-Party Service Providers. We may disclose information to third parties that perform certain functions on our behalf. For example, we may disclose information to companies that provide support services to us or that help us improve and/or market our products and services (such as third-party advertising companies). These service providers are permitted to use any Personal Information we provide to them only to perform services on our behalf and must treat it as strictly confidential.

With Other Users of Our Services. Information contained in certain User-Generated Content you post on the Services—such as UGC you post for social networking purposes—can be read, collected, or used by others. In addition, unless prohibited by FERPA or other applicable law, we may use UGC you submit for advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your further permission before using the content for such purposes. Therefore, you should have no expectation of privacy with respect to UGC you submit on or through our Services. If, at any time, you wish us to remove UGC that you posted, please contact us at the information below. Although we may not be able to honor every request to do so, we will consider reasonable requests and will remove UGC when applicable law requires us to do so. Please be aware, however, that if the UGC has already been distributed to other websites or published in other media, we will not be able to recapture and delete it.

Within the SEI Family of Businesses. When you upload information to one of our Services, the owner of that Site may share your information with other members of the SEI Family of Businesses. Before doing so, however, the owner of the Services may offer you the opportunity to “opt out” or “opt in,” as required by applicable law. Every member of the SEI Family of Businesses is required to handle information collected through our Services in accordance with this Policy and the privacy preferences you have expressed to us.

With Educational Institutions and/or Prospective Employers.  Unless prohibited by FERPA or other applicable law we may disclose: (1) to other educational institutions, information necessary for such institution to assess and/or honor your academic record for recognition of prior work toward academic credits or placement; and (2) to partners considering SEI students or graduates for potential employment opportunities, information for such partners to contact you.  Before doing so, however, the owner of the Services may offer you the opportunity to “opt out” or “opt in,” as required by applicable law.

With Third-Party Social Media Platforms. We may provide functionality on our Services that allows you to automatically post information to a third-party social media platform (such as Facebook, Twitter, or Pinterest). If you choose to take advantage of this functionality, people with access to your profile on the third-party platform will be able to see your post. Thus, you should have no expectation of privacy in those actions. Further, if you choose to link your profile on our Services with an account on a third-party social media platform, we may disclose the information in your profile with that third-party platform. We may also use third-party social media platforms to offer you interest-based ads, which may involve sharing certain Personal Information about you.

With Other, Carefully Selected Business Partners. From time to time, we may disclose your information to selected third parties for their own marketing purposes. For example, we may partner with third parties to sponsor contests or other promotions, and we may disclose to these third parties the information you submit to us to participate in the contest or take advantage of the promotion. Before doing so, however, we may offer you the opportunity to “opt out” or “opt in,” as required by applicable law. We may also allow disclose Personal Information relating to your usage of the Services and other basic demographic information (such as gender and age) to third parties, including through the use of third-party cookies or similar technologies on the Services.

As Part of a Business Transfer. Your information may be transferred in connection with a corporate sale, purchase, merger, reorganization, liquidation, dissolution, or similar event. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.

To Comply with Laws and Protect Our Rights and the Rights of Others. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the reporting requirements of accrediting bodies or state or federal government requirements, or to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Services; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

Selling/Sharing of Personal Information

SEI uses cookies, tags, and similar tracking technologies to perform analytics and for targeted advertising.  Under some privacy laws, this may be considered “sharing” or a “sale” when used for cross-context behavioral advertising.   You have the right to opt out of this type of “sharing” or “sale” of your personal information by use of the blue toggle button marked “Sales/Sharing/Targeted Advertising” in Your Privacy Choices.

How We Protect Personal Information

We maintain reasonable administrative, physical and technological measures to protect the confidentiality and security of Personal Information you submit on or through our Services. Unfortunately, no website, server or database is completely secure. We therefore cannot guarantee that your Personal Information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. Further, we cannot control dissemination of Personal Information you post on or through our Services using any social networking tools we may provide, and you should have no expectation of privacy in such information.

A Note on Children's Privacy

SEI does not knowingly collect Personal Information from children under the age of thirteen through our Services. If you are under thirteen, please do not give us any information that identifies you personally. If you have reason to believe that your child has provided Personal Information to us through our Services, please contact us, and we will use reasonable efforts to delete that information from our databases.

Privacy Rights

Where applicable under local law, you may have certain rights with respect to your Personal Information. Certain exceptions may apply, and we reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or an individual that you authorize to act on your behalf (as permitted under state law) may make a verifiable rights request related to your Personal Information. Depending on the jurisdiction in which you live, these may include the following rights:

• Request information about our processing of your Information
• Request a copy of your Personal information
• Rectify, correct, or update the Personal Information we hold about you
• Request deletion of your Personal Information
• Opt out of “sales” of Personal Information, “sharing” of Personal Information for cross-context behavioral advertising, and “targeted advertising” (as these terms are defined under applicable law)
• Opt out of certain profiling activities
• Restrict or limit our use of certain information (including to limit the use of your sensitive Personal Information)
• Object to our use of your Personal Information
• Ask that we transfer the Personal Information you provided us to another organization, or to you, in certain circumstances (referred to as data portability)
• Where you have provided consent to the processing of certain Personal Information, withdraw your consent to such processing at any time
• Not to be unlawfully discriminated against for exercising your rights
• Lodge a complaint with your local data protection authority

Submitting Requests

You can submit your request by calling us at 1-844-925-1256 or visiting our request website here. You may also submit a request via email at [email protected]. Where applicable under local law, you may also contact us via these methods to appeal any decision we make relating to your request to exercise your rights. 

Verifying Requests

SEI provides an online webform to submit requests, accessible here. As stated in the webform, SEI must verify that the person requesting information or deletion is the individual about whom the request relates in order to process the request. To verify your identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury that you are the individual whose Personal Information is the subject of the request. 

Making a verifiable rights request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. SEI reserves the right to take additional steps as necessary to verify the identity of individuals where we have reason to believe a request is fraudulent.

Authorized Agents

You may choose another person that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, SEI requires that you provide the Authorized Agent with written permission to allow them to submit your request and, in some cases, may require that you verify your identity directly with SEI. Failure to do so may result in SEI denying your request. Authorized Agents submitting requests on behalf of individuals should include a copy of the individual’s signed authorization when submitting any request on the individual’s behalf.

Your Choices

Depending on the nature of your choices and applicable law, we may provide you with choices about the ways we collect, use, and disclose your information as well as how we communicate with you. We generally ask you to indicate your choices at the time and on the page where you provide your information.

With respect to email preferences, where required under applicable law, we will obtain your consent to send you electronic marketing communications. You may also opt out of such communications by contacting us at the details above or clicking the unsubscribe button in the body of the email and following the instructions provided. However, you cannot opt out of transactional emails related, for example, to your enrollment or tuition. Please note that if you give us permission to disclose your information to our affiliates and later withdraw your permission, you may still receive e-mail from one of our affiliates, if we disclosed your information before you withdrew your permission.

Links to Third Party Sites

Some of our Services may include links to other SEI websites and other websites that are owned and operated by unrelated third parties. For example, our Services may link to government websites where you can apply for financial aid, as well as to third-party social networking sites such as Facebook, Twitter, and YouTube. In addition, our Services contain links to websites operated by third parties who provide services to SEI. For example, SEI uses a third-party service provider to process credit card transactions. This Privacy Policy applies only to information that we collect through SEI-owned Services that display a link to our Privacy Policy. It does not apply to information collected on any SEI-owned site that does not display a link to our Privacy Policy, nor does it apply to information collected on the websites of our service providers or other third parties.

When you access a website to which this Privacy Policy does not apply, please take a few minutes to review the terms of use and privacy statement posted on that site.

Retention of Personal Information

SEI retains Personal Information as long as we have a relationship with you (including throughout the duration of your studies and in many cases afterwards, as part of the alumni community). Once our relationship with you has come to an end, we will retain your Personal Information for a period of time that enables us to maintain academic records, comply with our legal and regulatory obligations, defend or bring any existing or potential legal claims, or resolve or otherwise address any complaints or queries relating to our Services.

International Transfers of Personal Information

SEI is a U.S. corporation headquartered in the United States. Our Services for entities utilizing this Privacy Policy are currently hosted on servers located in the United States, although we reserve the right to relocate our Services to other servers elsewhere in the world. Your Personal Information may be stored on servers located within the United States or in another country. In addition, we may transfer your Personal Information to our service providers and others located in the United States or another country for the purposes described in this Privacy Policy. Different countries have different privacy laws and requirements, and some provide less legal protection for your Personal Information than others. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to help ensure that your Personal Information is adequately protected.

Additional Disclosures for California Residents

The disclosures in this section apply only to California residents and are intended to supplement this Policy with information required by California law.

As described above, we collect Personal Information directly from you, automatically when you use or interact with the Services, and in some cases from third parties or public sources. We collect and disclose Personal Information for the purposes described above in the “How We Use Personal Information” section of this Policy.  These include disclosures made for business purposes, such as to service providers who process Personal Information on our behalf. We also disclose Personal Information to certain advertising partners; under California law, these disclosures may be considered “sharing” or “sales.” The table below describes the categories of Personal Information we collected in the past 12 months and the categories of recipients to whom we may disclose Personal Information. For more detail, please refer to the descriptions above in the body of this Policy.

Category of Information	Recipients of Disclosures for Business Purposes	Recipients of Disclosures That May Be Characterized as Sharing or Selling
Identifiers (e.g., name; email, phone number, address; applicant number, Student ID;  IP address)	Service providers	Advertising Partners
Protected Characteristics under State or Federal law (e.g., age, gender, marital status, military or veteran status)	Service Providers	Not Applicable
Commercial Information (e.g., information collected via financial aid or scholarship applications, information about your or your family’s financial situation; payment information used for tuition; records of tuition payments or amounts due)	Service Providers	Not Applicable
Internet or Other Similar Network Activity (e.g., technical data collected from your computer or device including browser and device type, operating system, geographic location, internet service provider, profile demographics; usage information about your use of the Services including the websites you visit, search terms you enter, date and time of your visit, how often you visit the Services, URLs of sites you visit before or after visiting our sites, the content you engage with on the Services, email clicks or other actions taken)	Service Providers	Not Applicable
Geolocation Data (e.g., approximate location based on your IP address)	Service Providers	Not Applicable
Professional or Employment-Related Information (e.g., resume or CV provided in connection with admissions application)	Service Providers	Not Applicable
Non-Public Education Information (e.g., information from education records; information submitted in connection with your application for admission, financial aid, or scholarships; grades; degree program; academic history; course selections; disciplinary records; transcripts; credits earned or attempted)	Service Providers	Advertising Partners (as to academic program of interest)
Audio and Visual Information (e.g., photographs and videos obtained during application or enrollment, captured during participation in an SEI-sponsored activity, or via security cameras at SEI facilities)	Service Providers	Not Applicable
Inferences (e.g., inferences drawn about you based on other Personal Information we collect, such as information about how you use the Services or information you submit in an admissions application)	Service Providers	Not Applicable
Sensitive Personal Information (e.g., health and medical information; information about religious or philosophical beliefs, race or ethnic origin, or sexual orientation; social security number, state ID, passport number or other government issued ID; account log-in credentials, passwords, security questions and answers)	Service Providers	Not Applicable

 

In the past 12 months, we have not sold or shared Personal Information about individuals known to be under age 16 as defined by California law.

Please note that we may also disclose any or all of the categories above in the event of a sale or transfer of all or part of our business, or where necessary to comply with applicable laws or protect our rights or the rights of others, as described in more detail in the “How We Disclose Personal Information” section above.

We use and disclose sensitive Personal Information only for purposes expressly permitted under California law.

SEI retains Personal Information as long as we have a relationship with you (including throughout the duration of your studies and in many cases afterwards, as part of the alumni community). Once our relationship with you has come to an end, we will retain your Personal Information for a period of time that enables us to maintain academic records, comply with our legal and regulatory obligations, defend or bring any existing or potential legal claims, or resolve or otherwise address any complaints or queries relating to our Services.

Changes To This Policy

We may modify or update this Policy from time to time. If we change this Policy, we will notify you of the changes. If we make any revisions that materially change the ways in which we process your Personal Information, we will notify you of these changes before applying them to that Personal Information.

Contact Us

If you have questions or concerns about this Privacy Policy, please e-mail us at [email protected] or send a letter to:

Strategic Education, Inc.

Office of the General Counsel
2303 Dulles Station Blvd.
Mail Stop 6C
Herndon, VA 20171

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