Terms, policies & disclosures.

About these terms

Effective 18 July 2026

This Legal Center sets out the terms, policies and disclosures that apply to the eTrader platform and to this website, etraderweb.com (together, the "Services"). The Services are provided by SGHK Softwares Limited, a company incorporated in Hong Kong, whose registered office is Flat 5, 4/F, Won Hing Building, 74–78 Stanley Street, Central, Hong Kong ("SINGUARD", "we", "us" or "our").

By accessing the website, requesting a demonstration, subscribing to the platform, trading on it, publishing in the Community marketplace, or otherwise using the Services, you confirm that you have read, understood and agree to be bound by these terms and policies. If you are entering into these terms on behalf of a company or other legal entity, you represent that you have authority to bind that entity, and "you" refers to that entity.

If you do not agree with any part of these terms, you must not use the Services.

We may update this Legal Center from time to time. The "last updated" date at the top of the page shows when the most recent changes took effect. Material changes to the Terms of Service applicable to active Licensees will be notified in accordance with the "Changes" provisions in Section 3.

1.1 Who these terms apply to

These policies are for everyone who interacts with the Services — but not every section applies to every person. Use the guide below to find the parts that concern you. By using the Services in any of these capacities, you accept the sections that apply to you.

Where these terms say "you", they mean the person or entity in the capacity relevant to the section — the Licensee in the Terms of Service, and the End Trader, Provider or visitor in the sections addressed to them. Your relationship for opening an account, trading, deposits and withdrawals is with your Licensee (your broker or prop firm), not with SINGUARD; your relationship with SINGUARD is limited to your use of the software and, where you take part in them, the community-wide features SINGUARD operates.

Definitions

Terms of Service

Software licence & use of the Platform

3.1 Nature of the Services

SINGUARD provides software and hosting only. We license the Platform to Licensees as a managed, multi-tenant service. We do not provide, and the Services do not constitute, any regulated financial service, brokerage service, investment advice, market data, liquidity, custody of funds or payment service. Responsibility for how the Platform is configured and operated — including instrument selection, spreads, markup, commissions, swaps, leverage, routing decisions, and dealings with End Traders — rests entirely with the Licensee.

3.2 Licence grant

Subject to your continuous compliance with these terms and payment of applicable fees, SINGUARD grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to access and use the Platform during your subscription term, solely for your internal business purposes and in accordance with the documentation. All rights not expressly granted are reserved by SINGUARD.

3.3 Restrictions

You must not, and must not permit any third party to:

• copy, modify, translate, adapt or create derivative works of the Platform, except as expressly permitted;
• reverse engineer, decompile or disassemble the Platform, or attempt to derive its source code, save to the extent this restriction is prohibited by law;
• resell, rent, lease, sublicense, time-share or provide the Platform to third parties other than your own End Traders in the ordinary operation of your business;
• remove, obscure or alter any proprietary notices; or
• use the Platform in breach of the Acceptable Use Policy (Section 4) or any applicable law.

3.4 Licensee responsibilities

As a condition of using the Platform, each Licensee agrees that it is solely responsible for:

• obtaining and maintaining all licences, registrations and authorisations required to conduct its business in every jurisdiction in which it operates or solicits clients;
• its own regulatory compliance, including anti-money-laundering, counter-terrorist-financing, sanctions screening, KYC/onboarding, suitability, disclosure, marketing and record-keeping obligations;
• sourcing and licensing its own market data and liquidity, and for the accuracy, timeliness and legality of that data;
• all relationships with, obligations to, and communications with its End Traders, including the handling and safeguarding of client money and client assets;
• the configuration of the Platform (instruments, pricing, leverage, routing, challenge rules and risk parameters) and the commercial and legal consequences of those settings; and
• the security of its administrator credentials and the acts and omissions of its personnel and End Traders.

3.5 Fees, payment & no refunds

Fees for the Platform are as set out in your order or on the pricing section of the website (a flat monthly platform licence plus a one-time per-trading-account fee). Unless stated otherwise, fees are quoted in US dollars and are exclusive of taxes, duties and withholdings. Late or failed payments may result in suspension of the Services after reasonable notice.

How billing starts. The Platform is a configured, hosted software service that we provision specifically for each Licensee. You first pay the one-time setup fee; once that is received, we begin setting up your environment — provisioning your tenant, installing and configuring your broker/administrator environment, instrument set, account tiers and connections. Your monthly platform licence subscription does not begin at that point: it starts only once your environment has been set up and the Platform is made available for your use. The setup fee pays for the provisioning work itself; the monthly licence covers ongoing use once you are live.

All platform fees are non-refundable. Because the setup, installation and configuration work is carried out specifically for you and the software is then delivered and made accessible to you, every fee you pay — the one-time setup and per-trading-account fee, any onboarding, configuration, migration or professional-services fee, and the monthly platform licence — is non-refundable once paid, in whole or in part, whether or not you go on to use the Platform. The setup fee is non-refundable once we have begun provisioning your environment.

Once live, subscription fees are not pro-rated on cancellation, suspension or termination: if you cancel or we terminate part-way through a billing period, you remain liable for that period and no unused portion is refunded. The one-time per-trading-account fee is likewise non-refundable once the account has been provisioned, including if the account is later closed, suspended or unused. This no-refund position applies regardless of the reason for cancellation or termination, except that it does not remove any refund right that cannot lawfully be excluded under applicable mandatory law.

3.6 Intellectual property

The Platform, its source code, design, structure, trademarks and all related intellectual property are and remain the exclusive property of SINGUARD and its licensors. You retain ownership of your Content. You grant SINGUARD a limited licence to host, process and transmit your Content solely to provide and support the Services.

3.7 Term, suspension & termination

These terms apply for as long as you use the Services or hold an active subscription. We may suspend or terminate access immediately where you materially breach these terms, fail to pay, or where continued provision would expose SINGUARD to legal, regulatory or security risk. Either party may terminate a subscription in accordance with the order terms. On termination, your licence ends and you must cease using the Platform; we may delete Content after a reasonable retention period, subject to law.

3.8 Third-party services

The Platform may integrate with third-party services chosen by the Licensee (for example liquidity providers, market-data vendors, payment processors or KYC providers). SINGUARD is not responsible for those third parties, their availability, or their terms, and does not endorse or warrant them.

3.9 Changes to the Services or terms

We may modify, enhance or discontinue features of the Platform, and may amend these terms, to reflect changes in technology, law or our business. We will give active Licensees reasonable prior notice of material adverse changes to the Terms of Service. Continued use after changes take effect constitutes acceptance.

3.10 Marketplace & provider payments

Some Marketplace Offerings — signals, copytrading strategies, automated bots and other tools — are offered by Providers for a subscription or one-off fee. Where an End Trader buys paid access, the following apply:

• payment is collected and processed by a third-party payment processor under that processor's own terms; SINGUARD does not itself provide banking, payment, e-money or custody services, and does not hold client trading funds or operate digital-asset wallets;
• SINGUARD acts as a marketplace facilitator: it deducts its service fee (as published) and arranges for the balance to be remitted to the Provider, subject to the verification, minimum-payout, hold, reversal and schedule rules we publish;
• any amount shown as payable to a Provider is a record of what is owed and does not represent money held on deposit or in trust for the Provider;
• Providers are independent sellers, solely responsible for the Offerings they provide (including any automated bot or tool and how it behaves), for the accuracy of what they publish, and for their own consumer-protection, invoicing, tax and regulatory obligations arising from their sales;
• all sales are final — Marketplace Payments are made by crypto transfer and cannot be refunded, reversed or charged back, and the only avenue to raise a concern is the 24-hour contestation window in our Marketplace & Refund Policy (Section 11); SINGUARD may still withhold, delay, offset or claw back payouts to a Provider to cover fees, or suspected fraud or breach; and
• SINGUARD does not guarantee any Provider any level of sales, and does not guarantee any End Trader any result from a paid Offering.

3.11 End Traders & Providers

End Traders and Providers use the trader terminal, copytrading and the Community marketplace under these terms together with the terms of the Licensee whose services they use. By accessing the Platform you confirm that you are of legal age and have the capacity to enter into a binding agreement in your jurisdiction, that you are not resident in, or accessing the Platform from, a jurisdiction where doing so is prohibited, that you are not subject to sanctions, and that you will comply with the Acceptable Use Policy (Section 4).

Your trading account — and everything to do with deposits, withdrawals, order execution, leverage, pricing and the money or assets in it — is provided by, and is a matter between you and, your Licensee (your broker or prop firm), not SINGUARD. Any complaint about trading, execution, fees, deposits or withdrawals must be directed to your Licensee, who is responsible for handling it. Your direct relationship with SINGUARD is limited to your use of the software and any community-wide features (such as the Community marketplace and cross-Licensee copytrading) that SINGUARD operates, which are governed by these terms.

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Acceptable Use Policy

Prohibited conduct on the Platform

This Acceptable Use Policy ("AUP") applies to every Licensee, administrator and End Trader that accesses the Platform. Breach of this AUP is a material breach of the Terms of Service and may result in immediate suspension or termination, and in referral to competent authorities.

4.1 You must not use the Platform to

• violate any applicable law, regulation, sanctions regime or third-party right;
• operate a financial business without holding the licences and authorisations that business requires;
• facilitate money laundering, terrorist financing, fraud, market manipulation, insider dealing, "wash" or fictitious trading, or any other market abuse;
• onboard or serve any person or entity that is subject to sanctions, or that resides in a jurisdiction where your activity is prohibited;
• misrepresent SINGUARD as the provider of financial services, or state or imply that SINGUARD regulates, endorses, verifies, guarantees or is responsible for a Licensee's trading services, a Provider, a Marketplace Offering, or an End Trader's outcomes;
• publish, promote or operate any Marketplace Offering (including signals, copytrading, or automated bots and tools) without holding any licence or authorisation that activity requires, or make false, misleading or unsubstantiated performance claims to followers or End Traders;
• publish or distribute a bot, tool or other Offering that is malicious, defective, infringing, or that you do not have the right to distribute;
• guarantee, or create the impression of guaranteeing, trading profits or any particular trading result;
• circumvent, or induce others to circumvent, the marketplace payment process, or solicit or accept off-platform payment to avoid marketplace fees;
• upload or transmit malicious code, or attempt to gain unauthorised access to the Platform, other tenants, or underlying infrastructure;
• probe, scan, load-test, or circumvent the security or access controls of the Platform without our prior written consent;
• use the Platform to store or transmit unlawful, infringing, defamatory or harmful content; or
• interfere with or disrupt the integrity or performance of the Platform or the data of any other tenant.

4.2 Enforcement

We may investigate suspected breaches and cooperate with law-enforcement and regulators. We may remove content, restrict features, or suspend or terminate access where we reasonably believe this AUP has been breached, or to protect the Platform, our other customers, or third parties. Where practicable we will act proportionately and give notice, but we may act without prior notice where necessary to prevent harm or meet a legal obligation.

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Risk Disclosure & Disclaimer

Important information about trading risk

5.1 SINGUARD provides technology, not trading services

eTrader is software. SINGUARD does not offer, solicit or execute trades, does not provide investment advice or recommendations, does not manage money, and does not guarantee any trading result. Any trading activity conducted through the Platform is offered and operated by the relevant Licensee, under its own regulatory responsibility, and is between that Licensee and its End Traders.

5.2 Nature of the risks

• Leverage. Margin and leverage magnify both gains and losses. Small market movements can have a large impact on account equity, and losses may exceed initial deposits where permitted.
• Volatility & liquidity. Prices in forex, metals, indices, CFDs and crypto-assets can move rapidly. Gaps, slippage and low liquidity can prevent orders executing at expected prices.
• Market data & execution. Pricing, quotes and execution depend on the market data and liquidity that the Licensee sources and connects. SINGUARD does not supply or warrant that data.
• Technology. No software or internet-based system is free from the risk of interruption, delay or error. Outages, latency or connectivity issues may affect access or execution.
• Past performance. Past or simulated performance, including within any challenge or demo environment, is not a reliable indicator of future results.

5.3 No advice; independent decisions

Nothing on this website, in the Platform, or in any related material is a recommendation to buy, sell or hold any instrument, or advice that any strategy is suitable for any person. End Traders should assess their own circumstances and seek independent professional advice before trading, and should only trade with money they can afford to lose.

5.4 Copytrading, signals, bots & the Community marketplace

Copytrading, signal-following, automated bots and other Marketplace Offerings are software tools that mirror one account's trades to another, or let strategies and tools be published, followed or run. They are not investment advice, portfolio or asset management, or a recommendation, and no Offering, signal or track record is a promise or reliable indicator of future performance. Copied or automated trading can amplify losses as readily as gains, may execute at prices different from the Provider's, and a follower may lose more than the account being copied. Automated strategies, bots and expert advisors run without human supervision and can malfunction, behave unexpectedly, or fail during volatility, outages or connectivity loss; an End Trader who runs one remains responsible for monitoring it and for its results. Any track record or performance figure shown is a record of past activity on the Platform only; SINGUARD does not verify, endorse, rate, rank, supervise or guarantee any Provider, Offering, bot, track record or result. Providers, and any firm that operates copytrading or automated trading for its End Traders, are solely responsible for their own conduct and for holding any licence, registration or authorisation their activity requires in each relevant jurisdiction. Deciding to follow a signal, copy another trader or run a bot is the End Trader's own decision, made at the End Trader's own risk. The fact that an Offering is paid for, popular or highly ranked is not an endorsement by SINGUARD or an assurance of its quality or results.

5.5 Jurisdiction

The availability of trading services depends on the Licensee and applicable local law. The Platform and this website are not directed to any person in any jurisdiction where such distribution or use would be contrary to law or regulation.

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AML & Regulatory Compliance Notice

Responsibility for anti-money-laundering & licensing

SINGUARD takes financial crime seriously and provides tooling within the Platform (such as configurable risk monitoring, breach detection, audit trails and reporting) that Licensees may use to support their own compliance programmes. These are software features, not a compliance, monitoring or advisory service, and they do not discharge any legal or regulatory obligation of a Licensee.

6.1 The Licensee is the regulated party

Each operating firm is solely responsible for designing, implementing and maintaining its own compliance framework, including:

• obtaining and maintaining every licence, registration or authorisation required for its activities;
• customer due diligence, KYC and ongoing monitoring of its End Traders;
• anti-money-laundering (AML) and counter-terrorist-financing (CTF) controls, sanctions and PEP screening;
• transaction monitoring, suspicious-activity reporting and record-keeping under applicable law; and
• safeguarding of client money and client assets.

6.2 SINGUARD's role

SINGUARD does not onboard End Traders, does not hold or move client funds, and does not act as a regulated financial institution. We do not provide legal or regulatory advice. Licensees should obtain their own professional and legal advice on the requirements that apply to them.

6.3 Cooperation

SINGUARD may suspend Services and cooperate with law-enforcement or regulators, and may disclose information where required by law or valid legal process, or where we reasonably believe the Platform is being used for unlawful purposes.

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Privacy Policy

How we handle personal data

This Privacy Policy explains how SGHK Softwares Limited collects, uses and protects personal data in connection with this website and the provision of the Platform to Licensees. We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and, where applicable, other data-protection laws.

7.1 Our role

For personal data of website visitors and of the business contacts of prospective and actual Licensees, SINGUARD acts as a data controller. For personal data of End Traders processed within a Licensee's tenant, the Licensee is the controller and SINGUARD acts as a data processor / service provider that processes such data only on the Licensee's documented instructions to host and support the Platform.

Where SINGUARD operates community-wide features that span more than one Licensee (such as the Community marketplace and cross-Licensee copytrading), SINGUARD may act as a controller for the limited profile, subscription and performance data that an End Trader chooses to make available for those features. Information an End Trader publishes to the Community marketplace — such as a display name, a strategy and its on-platform track record — may be visible to other users of the Platform.

7.2 Data we collect

7.3 How we use personal data

We use personal data to provide, secure, support and improve the Services; to communicate with you about enquiries, contracts and service matters; to manage billing; to comply with legal obligations; and to protect our rights and the integrity of the Platform. We do not sell personal data.

7.4 Legal bases

Where a legal basis is required, we rely on: performance of a contract (or steps to enter one); our legitimate interests in operating and securing our business; your consent (for example non-essential cookies and marketing, which you may withdraw at any time); and compliance with legal obligations.

7.5 Sharing & sub-processors

We may share personal data with trusted service providers who help us run the Services (such as hosting, infrastructure, payment processors, analytics and support tools), each under appropriate confidentiality and data-protection terms; with professional advisers; and with authorities where required by law. We do not disclose Licensee tenant Content except on the Licensee's instructions or as required by law.

7.6 International transfers

Personal data may be processed or stored in jurisdictions outside your own. Where we transfer personal data internationally, we take steps to ensure a comparable level of protection through appropriate contractual and technical safeguards.

7.7 Retention

We keep personal data only for as long as necessary for the purposes described above, to comply with legal, accounting or reporting requirements, and to resolve disputes, after which it is deleted or anonymised.

7.8 Security

We use technical and organisational measures appropriate to the risk, including access controls, encryption in transit, multi-tenant isolation and monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7.9 Your rights

Subject to applicable law, you may request access to, correction of, or deletion of your personal data, object to or restrict certain processing, and withdraw consent. To exercise your rights, contact us at office@sghk.org. If your data is held within a Licensee's tenant, please contact that Licensee directly, as they are the controller. You may also have the right to complain to a data-protection authority, including the Office of the Privacy Commissioner for Personal Data, Hong Kong.

7.10 Children

The Services are intended for businesses and are not directed at children. We do not knowingly collect personal data from children.

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Cookie Policy

How this website uses cookies

Cookies are small text files placed on your device when you visit a website. We use them to make this site work and, with your consent, to understand how it is used. You can accept or decline non-essential cookies via the banner shown on your first visit, and you can change your browser settings at any time to block or delete cookies.

We do not use cookies for third-party advertising. If we introduce additional cookies in future, we will update this policy and, where required, ask for your consent. Declining non-essential cookies will not affect your ability to use the core parts of the site.

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Warranties, Liability & Indemnity

Please read this section carefully — it limits our liability

9.1 Disclaimer of warranties

To the maximum extent permitted by law, the Services are provided "as is" and "as available", without warranties of any kind, whether express, implied or statutory, including any implied warranties of merchantability, fitness for a particular purpose, title, accuracy and non-infringement. SINGUARD does not warrant that the Services will be uninterrupted, error-free, secure, or free from delay, or that they will meet your requirements or produce any particular commercial or trading outcome. We do not warrant any third-party market data, liquidity or integrations.

9.2 Exclusion of certain losses

To the maximum extent permitted by law, SINGUARD will not be liable for any indirect, incidental, special, consequential, punitive or exemplary damages, or for any loss of profits, revenue, goodwill, business, anticipated savings, trading losses, or loss or corruption of data, arising out of or in connection with the Services, even if advised of the possibility of such losses and regardless of the theory of liability.

9.3 Cap on liability

To the maximum extent permitted by law, SINGUARD's total aggregate liability arising out of or in connection with the Services, whether in contract, tort (including negligence) or otherwise, will not exceed the total fees paid by the Licensee to SINGUARD for the Services in the twelve (12) months immediately preceding the event giving rise to the liability. Where the person concerned is an End Trader or Provider rather than a Licensee, this cap is instead the total amounts (if any) that person paid to SINGUARD in respect of the Services in the twelve (12) months preceding the event, or USD 100, whichever is greater.

9.4 Matters not excluded

Nothing in these terms excludes or limits any liability that cannot lawfully be excluded or limited, including liability for death or personal injury caused by negligence or for fraud or fraudulent misrepresentation.

9.5 Indemnity

You agree to indemnify, defend and hold harmless SINGUARD, its affiliates, and their respective officers, directors, employees and agents from and against any claims, liabilities, damages, losses and expenses (including reasonable legal fees) arising out of or connected with: (a) your use or operation of the Platform; (b) your services to, and relationships with, your End Traders; (c) your breach of these terms, the AUP, or any law or regulation; (d) your regulatory, licensing, AML/KYC or client-money obligations; or (e) any Content you or your End Traders submit to the Platform.

9.6 Allocation of risk

You acknowledge that the fees reflect the allocation of risk in these terms and that these limitations are an essential basis of the bargain between you and SINGUARD.

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Governing Law & Disputes

Hong Kong SAR

These terms and any non-contractual obligations arising out of or in connection with them are governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region of the People's Republic of China.

The parties submit to the exclusive jurisdiction of the courts of Hong Kong to settle any dispute or claim arising out of or in connection with these terms or the Services, save that SINGUARD may seek injunctive or other equitable relief in any court of competent jurisdiction to protect its intellectual property or confidential information.

10.1 Severability & waiver

If any provision is held to be invalid or unenforceable, the remaining provisions continue in full force, and the invalid provision will be modified to the minimum extent necessary to make it enforceable. Our failure to enforce any right is not a waiver of it.

10.2 Entire agreement & assignment

These terms, together with any order or written agreement between you and SINGUARD, form the entire agreement regarding the Services and supersede prior discussions. You may not assign your rights without our written consent; we may assign to an affiliate or in connection with a merger, acquisition or sale of assets.

10.3 Force majeure

Neither party is liable for failure or delay caused by events beyond its reasonable control, including acts of God, outages, network or infrastructure failures, cyber-attacks, government action or civil disturbance.

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Marketplace & Refund Policy

Purchases from Providers in the Community Marketplace

This policy applies to purchases of paid Marketplace Offerings (signals, copytrading strategies, automated bots and other tools) from Providers. By buying a paid Offering, you accept this policy.

11.1 All sales are final

Every purchase of a Marketplace Offering is final and non-refundable. Marketplace Payments are made by crypto transfer only — we do not accept cards or any other reversible payment method — and crypto transfers cannot be reversed. Once a payment has been transferred to the Provider, SINGUARD has no ability to recover, reverse or return it. SINGUARD does not provide refunds, credits, cancellations, chargebacks or claw-backs to buyers, and no chargeback or payment-dispute process is available for marketplace purchases.

Marketplace Offerings are digital content and services that are supplied and made accessible immediately on purchase. By completing a purchase you expressly request that supply begin at once and acknowledge that you thereby lose any right to cancel, withdraw from or obtain a refund of the purchase — including the 14-day right of withdrawal that would otherwise apply to consumers under EU/EEA and UK law. This request and acknowledgement are confirmed to you at the point of purchase before payment is taken.

11.2 Providers are reviewed before they can sell

Before a Provider may list a paid Offering, SINGUARD carries out a basic onboarding review and approves the Provider only once it is satisfied the Provider is genuine. This is an eligibility check only. It is not an audit, endorsement, verification or guarantee of the Provider, its conduct, its track record, or the quality, safety, legality or results of any Offering. Buyers rely on Offerings entirely at their own risk (see Section 5.4).

11.3 Contestation window (24 hours)

If you believe something is genuinely wrong with a purchase, your only avenue is to email office@sghk.org within 24 hours of the purchase, describing the issue. Contestations raised after that 24-hour window will not be considered. Even within the window, any action is only ever possible while the payment has not yet been remitted to the Provider — once funds have been transferred to the Provider they cannot be recovered. Raising a contestation does not entitle you to a refund or reversal: SINGUARD will look into the matter and may, entirely at its own discretion, take whatever action it considers appropriate. Nothing in this policy creates a right to a refund.

11.4 Mandatory rights

Nothing in this policy removes or limits any right you may have under mandatory consumer-protection law that cannot lawfully be excluded. Where such rights apply, the rest of this policy applies only to the extent the law permits.

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Contact

For any questions about these terms, our policies, or to exercise a data-protection right, please contact:

SGHK Softwares Limited
Flat 5, 4/F, Won Hing Building,
74–78 Stanley Street, Central, Hong Kong.
Email: office@sghk.org

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