Effective Date: September 01, 2026
Last Updated: September 01, 2026These General Terms and Conditions ("General Terms") govern your access to and use of the SperX platform ("SperX", "Platform", "we", "us", or "our").SperX is a web-based digital loyalty platform that enables merchants to create and manage loyalty programs and enables customers to join participating loyalty programs, including through QR codes.These General Terms apply to all users of SperX. Additional terms may apply depending on whether you use SperX as a customer or merchant.By accessing or using SperX, you agree to these General Terms and any applicable additional terms.

1. SperX Platform

SperX provides technology that allows merchants to create and operate digital loyalty programs and allows customers to participate in those programs.SperX does not itself operate every loyalty program available through the Platform. Unless expressly stated otherwise, the merchant offering a loyalty program is responsible for establishing its rules, issuing rewards, and fulfilling those rewards.

2. Additional Terms

If you use SperX as a customer, the SperX Customer Terms and Conditions also apply to you.If you use SperX as a merchant, the SperX Merchant Terms and Conditions also apply to you.If there is a conflict between these General Terms and applicable additional terms, the applicable additional terms will govern the specific subject matter addressed by those terms.

3. Eligibility

You may use SperX only if you are legally capable of entering into these Terms and are otherwise eligible to use the Platform under applicable law.Additional eligibility requirements may apply to particular features or loyalty programs.

4. Accounts

You are responsible for providing accurate information and maintaining the security of your account credentials.You must not use another person's account without authorization or allow unauthorized persons to access your account.We may suspend or terminate accounts that violate these Terms or are involved in fraud, abuse, security incidents, or unlawful activity.

5. Acceptable Use

You must not:* Use SperX for unlawful, fraudulent, or abusive purposes;
* Manipulate loyalty points, rewards, transactions, or other platform features;
* Attempt unauthorized access to SperX or another user's account;
* Interfere with the operation or security of the Platform;
* Introduce malicious software or harmful code;
* Impersonate another person or business;
* Scrape or systematically extract platform data without authorization;
* Reverse engineer SperX except where permitted by applicable law; or
* Use SperX in a way that could harm the platform or other users.

6. Intellectual Property

SperX and its software, platform design, interfaces, branding, logos, graphics, text, and other proprietary materials are owned by or licensed to SperX.Except as permitted by these Terms or applicable law, you may not copy, modify, reproduce, distribute, sell, license, or create derivative works from SperX's intellectual property.

7. Third-Party Services

SperX may use or integrate with third-party services, including hosting, authentication, analytics, communications, payment, and other technology providers.Third-party services may have their own terms and privacy policies. SperX is not responsible for the independent acts or omissions of third-party providers.

8. Platform Availability

We will make reasonable efforts to maintain SperX, but we do not guarantee that the Platform will always be available, uninterrupted, secure, or error-free.SperX may be temporarily unavailable because of maintenance, technical issues, internet failures, third-party service interruptions, or circumstances beyond our reasonable control.

9. Changes to SperX

We may modify, add, suspend, or discontinue features of SperX at any time.We may also update these Terms from time to time. Where appropriate, we will provide notice of material changes.Your continued use of SperX after updated Terms become effective constitutes acceptance of the revised Terms, to the extent permitted by applicable law.

10. Privacy

Our collection and use of personal information is governed by our Privacy Policy.Merchants may have separate obligations concerning personal information they collect or process through their loyalty programs.

11. Disclaimers

To the maximum extent permitted by applicable law, SperX is provided on an "as is" and "as available" basis.We do not guarantee that the Platform will:* Meet every user's requirements;
* Be continuously available;
* Be free from errors or interruptions; or
* Contain complete or accurate information at all times.Nothing in these Terms excludes rights or remedies that cannot lawfully be excluded.

12. Limitation of Liability

To the maximum extent permitted by applicable law, SperX and its owners, officers, employees, affiliates, contractors, and service providers will not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages arising from your use of the Platform.To the extent permitted by law, SperX's aggregate liability arising from your use of the Platform will be limited to [insert appropriate limitation].Nothing in these Terms limits liability that cannot legally be limited.

13. Suspension and Termination

We may suspend or terminate access to SperX if we reasonably believe that a user has violated these Terms, engaged in fraud or abuse, created a security risk, or used the Platform unlawfully.You may stop using SperX at any time.Provisions that by their nature should survive termination will remain effective after termination.

14. Governing Law

These Terms shall be governed by the laws of the Republic of the Philippines, subject to any mandatory rights or remedies available under applicable law.

15. Severability

If any provision of these Terms is determined to be invalid or unenforceable, the remaining provisions will continue in effect.

Effective Date: September 01, 2026
Last Updated: September 01, 2026These Customer Terms and Conditions ("Customer Terms") apply when you use SperX as a customer or loyalty-program member.You must also comply with the SperX General Terms and Conditions and Privacy Policy.

1. Joining Loyalty Programs

SperX allows customers to join participating merchant loyalty programs, including by scanning a QR code provided by a merchant.When you join a loyalty program, you may become eligible to earn points, stamps, discounts, vouchers, rewards, or other benefits according to that merchant's program rules.

2. Merchant Program Rules

Each merchant is responsible for establishing the rules of its own loyalty program.Before participating, you should review the applicable program rules, including:• How rewards are earned;
• How rewards are redeemed;
• Any purchase requirements;
• Reward expiration dates;
• Program eligibility;
• Restrictions or exclusions; and
• Any other conditions established by the merchant.Merchant program rules may differ from one loyalty program to another.

3. Loyalty Points and Rewards

Unless otherwise stated by the merchant:• Points and rewards have no cash value;
• Points and rewards cannot be exchanged for cash;
• Points and rewards are not transferable;
• Rewards may expire;
• Rewards may be subject to availability; and
• Rewards may only be used according to the applicable merchant's rules.SperX does not guarantee the availability, value, or continued existence of any particular merchant reward.

4. Merchant Responsibility

The merchant, rather than SperX, is generally responsible for:• Providing the products or services associated with its business;
• Operating its loyalty program;
• Providing accurate program information;
• Issuing and honoring valid rewards;
• Handling disputes concerning its products or services; and
• Complying with laws applicable to its business and loyalty program.If you have a dispute concerning a merchant's products, services, purchase, or reward, you should first contact the applicable merchant.

5. QR Codes

You may join a loyalty program by scanning a QR code associated with the program.You should exercise reasonable care when scanning QR codes and should not knowingly use QR codes that appear to have been tampered with or are associated with unauthorized sources.

6. Fraud and Misuse

You must not manipulate or abuse a loyalty program.Examples include:• Creating fraudulent accounts;
• Falsifying transactions;
• Exploiting technical errors;
• Using unauthorized methods to obtain rewards;
• Sharing accounts in violation of program rules; or
• Attempting to obtain points or rewards to which you are not entitled.SperX or the applicable merchant may cancel improperly obtained benefits and may suspend or terminate access where appropriate.

7. Customer Information

You agree to provide accurate information when creating or maintaining your SperX account.Your personal information will be handled according to the SperX Privacy Policy and applicable law.A merchant may separately collect or process information in connection with its loyalty program.

8. Communications

SperX may send you service-related communications concerning your account, loyalty-program membership, points, rewards, security, and Platform operations.Where required by law, promotional communications will be subject to appropriate consent and communication preferences.

9. Account Termination

You may stop using SperX at any time.SperX or a merchant may restrict or terminate access to an account or loyalty program where permitted under the applicable terms, including in cases of fraud, abuse, or violation of the rules.Termination may result in the loss of access to points or rewards where permitted by the applicable loyalty-program terms and law.

Effective Date: September 01, 2026
Last Updated: September 01, 2026These Merchant Terms and Conditions ("Merchant Terms") apply to businesses and other organizations that use SperX to create, manage, or operate loyalty programs.By registering as a merchant or using merchant features, you agree to these Merchant Terms, the SperX General Terms and Conditions, and the SperX Privacy Policy.

1. Merchant Account

You must provide accurate and complete information when registering your business with SperX.You represent that you have authority to act on behalf of the business or organization you register.You are responsible for:• Maintaining accurate business information;
• Protecting your account credentials;
• Restricting access to authorized personnel; and
• All activity conducted through your merchant account.

2. Creating Loyalty Programs

SperX allows merchants to create and manage digital loyalty programs.You are responsible for defining the rules and conditions of your loyalty programs, including:• How customers earn points or benefits;
• Redemption requirements;
• Rewards;
• Reward values;
• Expiration periods;
• Eligibility requirements;
• Promotional conditions; and
• Program exclusions.You must ensure that information displayed to customers is accurate, clear, and not misleading.

3. Merchant Responsibility for Rewards

You are solely responsible for fulfilling valid rewards and benefits offered through your loyalty programs.SperX does not assume responsibility for providing your products, services, discounts, rewards, or other benefits.You must honor valid loyalty benefits according to the terms you communicate to customers, subject to applicable law.

4. Changes to Loyalty Programs

You may modify your loyalty program through SperX where the Platform allows.You are responsible for communicating material changes to customers and ensuring that changes comply with applicable law.You should not retroactively remove benefits that customers have already validly earned except where permitted by your published program terms and applicable law.

5. QR Codes

SperX may provide QR codes associated with your loyalty program.You are responsible for using and displaying your QR codes appropriately and taking reasonable steps to prevent unauthorized replacement, alteration, or misuse.You must promptly notify SperX if you believe a QR code associated with your business has been compromised.

6. Merchant Content

You may provide SperX with business names, logos, photographs, descriptions, promotional materials, reward descriptions, and other content ("Merchant Content").You retain ownership of your Merchant Content.You grant SperX a non-exclusive, worldwide, royalty-free license to host, reproduce, display, distribute, and otherwise use your Merchant Content as reasonably necessary to provide, operate, maintain, promote, and improve SperX and your loyalty program.You represent that you have the necessary rights and permissions to provide the Merchant Content.

7. Compliance With Law

You are responsible for ensuring that your business and loyalty programs comply with all laws and regulations applicable to you.This may include laws and regulations concerning:• Consumer protection;
• Advertising and promotions;
• Pricing;
• Taxes;
• Business licensing;
• Privacy and personal data;
• Intellectual property;
• Electronic transactions; and
• Other laws applicable to your business.SperX does not provide legal, tax, accounting, or regulatory advice to merchants.

8. Customer Data

You may receive or process customer information through your use of SperX.You agree to use customer information only for legitimate purposes and in accordance with applicable privacy and data-protection laws.You must not sell, misuse, unlawfully disclose, or otherwise process customer information contrary to applicable law or the permissions under which the information was collected.Where applicable, you are responsible for maintaining appropriate privacy notices, obtaining required consents, and responding to customer requests relating to your processing activities.

9. Merchant Promotions and Marketing

You are responsible for the accuracy and legality of promotions, discounts, rewards, advertisements, and other offers associated with your loyalty programs.You must not create promotions that are deceptive, misleading, unlawful, discriminatory, or otherwise prohibited by applicable law.

10. Fees and Payments

If SperX charges fees for merchant services, those fees will be communicated through the applicable pricing page, order form, subscription agreement, or other commercial terms.Pricing: [Insert Pricing Page/Terms]
You agree to pay applicable fees when due.SperX may change its pricing upon reasonable notice, subject to any applicable subscription or commercial agreement.

11. Fraud and Abuse

You must not manipulate your loyalty program or use SperX to facilitate fraudulent transactions, false reviews, unauthorized rewards, or other deceptive activity.SperX may investigate suspected abuse and may suspend or restrict your account or loyalty program where reasonably necessary.

12. Merchant Support and Disputes

You are primarily responsible for handling customer complaints concerning:• Your products or services;
• Purchases;
• Loyalty rewards;
• Points;
• Promotions;
• Discounts; and
• Your loyalty-program rules.SperX may provide technical support relating to the Platform but does not become a party to transactions between you and your customers merely by providing the Platform.

13. Suspension or Removal

SperX may suspend, restrict, or remove your loyalty program or merchant account if we reasonably believe that:• You violated these Terms;
• Your program violates applicable law;
• Your program creates a security or fraud risk;
• You misuse customer information;
• You engage in deceptive or abusive conduct;
• You fail to pay applicable fees; or
• Your use of SperX may harm the Platform, customers, or other merchants.Where reasonably practicable, we may provide notice and an opportunity to address the issue before suspension.

14. Indemnification

To the extent permitted by applicable law, you agree to indemnify and hold harmless SperX and its owners, officers, employees, affiliates, contractors, and service providers from claims, liabilities, damages, losses, and expenses arising from:• Your loyalty program;
• Your products or services;
• Your violation of these Terms;
• Your violation of applicable law;
• Your Merchant Content;
• Your processing or misuse of customer information; or
• Claims that your conduct or content infringes another person's rights.

15. No Agency

Your use of SperX does not create a partnership, joint venture, agency, employment, franchise, or other legal relationship between you and SperX unless expressly agreed in writing.You remain an independent business.

16. Termination

You may terminate your merchant account in accordance with any applicable commercial or subscription terms.SperX may terminate or suspend your merchant account as permitted by these Terms.Termination does not automatically eliminate obligations or liabilities that arose before termination.

17. Effect on Customers

If you terminate a loyalty program, you remain responsible for handling valid customer rewards and benefits according to your published program terms and applicable law.You should provide customers with reasonable notice of material program termination where required or appropriate.

18. Governing Law

These Merchant Terms shall be governed by the laws of the Republic of the Philippines, subject to any mandatory rights or remedies available under applicable law.

Effective Date: September 01, 2026
Last Updated: September 01, 2026SperX ("SperX," "we," "us," or "our") respects your privacy and is committed to protecting the personal information that we process through the SperX platform.This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, when it may be shared, and the rights you may have over your personal information.SperX is a web-based digital loyalty platform that allows participating stores and businesses ("Merchants") to create loyalty programs and allows customers ("Customers") to join and participate in those programs, including by scanning a QR code.This Privacy Policy applies to Customers and other individuals who use SperX's customer-facing services. Merchant-specific information and processing may be covered by separate terms, agreements, or notices.

1. Our Role in Processing Personal Information

For purposes of applicable Philippine data protection laws, SperX may act as a personal information controller with respect to personal information that it collects and determines the purposes and means of processing.In certain circumstances, SperX may also process information on behalf of a Merchant or another party.Where another party determines the purposes and means of processing, that party may have its own privacy responsibilities and obligations.

2. Information We Collect

We collect only information that is reasonably necessary for the purposes described in this Privacy Policy.2.1 Registered Customer AccountsWhen you create or use a registered Customer account, SperX may collect:• Name
• Email address
• Date of birth
• Gender
• Account and authentication information
• Loyalty-program membership information
• Points and rewards information
• Redemption and other loyalty activity
• Information relating to your interactions with SperXName, email address, date of birth, and gender are currently optional.You may therefore be able to use certain SperX functionality without providing some or all of these details.Where you voluntarily provide optional information, SperX may use that information for the purposes described in this Privacy Policy and for functionality associated with your account or participation in loyalty programs.2.2 Guest AccountsSperX may allow Customers to participate in loyalty programs without creating a fully registered account.When you use a guest account, SperX may generate a unique guest identifier and associate that identifier with information relating to your loyalty-program participation.The guest identifier may be stored in your browser using cookies or similar technologies.The guest identifier is used to recognize your guest account and maintain your participation in applicable loyalty programs.Because guest accounts rely on browser-based identifiers, clearing cookies or browser storage, changing browsers, using a different device, or otherwise removing stored browser information may affect your ability to access or continue using a guest account.2.3 Loyalty and Program Activity*SperX may collect and store information associated with your participation in loyalty programs, including:• Loyalty programs you have joined
• Your unique member identifier
• Points earned
• Points redeemed
• Rewards claimed
• Relevant loyalty activity
• Dates and times associated with loyalty activity
• Other information necessary to administer the applicable loyalty program

3. Information We Collect Automatically

When you access or use SperX, certain technical information may be collected automatically.Depending on how you use the platform, this may include information relating to:• Browser type and version
• Device and operating environment
• Session information
• Cookies and browser storage
• Security and authentication events
• Basic usage and performance information
• Information necessary to maintain the availability and security of the platformSperX does not currently collect precise GPS or other direct location information from Customers.

4. Cookies and Similar Technologies

SperX uses cookies, browser storage, session technologies, and similar technologies that are necessary or useful for operating the platform.These technologies may be used to:
• Maintain authentication sessions
• Recognize guest accounts
• Maintain loyalty-program sessions
• Preserve necessary information between requests
• Maintain security
• Prevent unauthorized access or abuse
• Understand basic platform usage and performanceSome cookies and similar technologies are necessary for SperX to function. Disabling or deleting them may cause certain features, including guest-account functionality, to stop working properly.SperX may also use basic analytics and performance-monitoring technologies provided by its hosting or infrastructure providers.We do not currently use cookies or similar technologies for behavioral advertising or targeted advertising.

5. How We Use Personal Information

SperX may process personal information for the following purposes:Providing SperXWe use information to:• Create and maintain Customer accounts
• Provide guest-account functionality
• Authenticate Customers
• Maintain sessions
• Allow Customers to join loyalty programs
• Maintain loyalty-program memberships
• Track points and rewards
• Process reward redemptions
• Maintain loyalty history
• Provide other features of the SperX platformOperating and Improving SperX
We may use information to:• Monitor platform performance
• Diagnose technical problems
• Improve reliability and functionality
• Understand basic usage patterns
• Maintain platform security
• Detect and prevent abuse, fraud, or unauthorized activityLegal and Compliance Purposes
We may process information when necessary to:
• Comply with applicable laws and regulations
• Respond to lawful requests from government authorities
• Establish, exercise, or defend legal claims
• Protect the rights, property, and safety of SperX, our users, Merchants, or others

6. Lawful Bases for Processing

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), personal information may be processed when a lawful basis exists.Depending on the specific processing activity, SperX may rely on one or more lawful bases, including:• Your consent, where consent is required or appropriate
• Processing that is necessary to provide or administer the services you request
• Compliance with a legal obligation
• Protection of vitally important interests where applicable
• Legitimate interests, where permitted by law and where those interests do not override your fundamental rights and freedomsThe particular lawful basis may depend on the nature and circumstances of the processing.Where we rely on consent, you may withdraw your consent subject to applicable law. Withdrawal of consent does not necessarily affect the lawfulness of processing carried out before the withdrawal.

7. Information Available to Merchants

SperX is designed to limit the personal information that a Merchant can access about a Customer.A Merchant will generally receive or have access to the Customer's unique member identifier for purposes of identifying the Customer's membership in that Merchant's loyalty program.Where a registered Customer has voluntarily provided a name, SperX may make that name available to the applicable Merchant where the relevant functionality permits it.SperX does not currently provide Merchants with a Customer's:• Precise location information
• Password
• Authentication credentials
• Other information that is not necessary for the applicable loyalty-program functionalityThe information available to a Merchant may depend on the features and configuration of its loyalty program.SperX may also process information relating to a Customer's participation in a Merchant's loyalty program, including points, rewards, and redemption activity, in order to operate that program.

8. Sharing of Personal Information

SperX does not sell or rent Customer personal information.We may share or disclose information where reasonably necessary to operate SperX or fulfill the purposes described in this Privacy Policy.This may include sharing information with:• Participating Merchants, as necessary to operate their loyalty programs
• Authentication providers
• Hosting and infrastructure providers
• Analytics and performance providers
• Security and fraud-prevention providers
• Other service providers that support SperX's operations
• Government authorities or other parties where required or permitted by lawWe seek to limit disclosures to information that is appropriate and necessary for the relevant purpose.

9. Third-Party Service Providers

SperX relies on third-party providers to operate certain parts of the platform.ClerkSperX uses Clerk for authentication and account-related functionality.Clerk may process information such as email addresses, usernames, authentication information, and other account-related information as necessary to provide its services to SperX.Third-party providers may process information in accordance with their own terms and privacy practices.Hosting, Infrastructure, and AnalyticsSperX uses hosting, infrastructure, and related technical services to operate the platform.These providers may process technical information, session information, and basic usage or performance information as necessary to provide their services.SperX may update the third-party services it uses from time to time as the platform develops.

10. Payments

SperX does not currently process payments.If payment functionality is introduced in the future, including potential cash-in functionality through a third-party payment provider such as PayMongo, we may update this Privacy Policy to explain the applicable information processing and payment-related services.

11. Marketing

SperX does not currently use Customer personal information for direct marketing, promotional email, SMS marketing, or targeted advertising.If this changes, SperX will provide appropriate notice and obtain consent where required by applicable law.

12. Data Retention

SperX retains personal information only for as long as reasonably necessary for the purposes for which it was collected or processed, including:
• Providing and maintaining SperX
• Administering loyalty programs
• Maintaining necessary account and loyalty records
• Maintaining security
• Resolving disputes
• Establishing, exercising, or defending legal claims
• Complying with legal obligations
• Other legitimate business purposes permitted by applicable lawSperX does not currently provide an automated account-deletion feature.An account may instead be deactivated or disabled. Deactivation or disabling does not necessarily result in the immediate deletion of associated information.Where information is no longer necessary for its original purpose or another lawful purpose, SperX may delete, anonymize, or otherwise dispose of the information in accordance with applicable law and our retention practices.

13. Data Security

SperX implements reasonable and appropriate organizational, physical, and technical measures intended to protect personal information against unauthorized access, alteration, disclosure, loss, destruction, or other unlawful processing.These measures may include access controls, authentication mechanisms, security practices, monitoring, and other safeguards appropriate to the nature of the information and the risks associated with its processing.However, no internet-based service can guarantee absolute security.If we become aware of a personal data breach that requires notification under applicable law, we will take appropriate steps in accordance with applicable legal and regulatory requirements.

14. Accuracy of Personal Information

We seek to maintain personal information that is accurate, relevant, and reasonably up to date for the purposes for which it is processed.You may contact us if you believe that information associated with your account is inaccurate or incomplete.Where appropriate, we may correct, update, restrict, or otherwise address inaccurate information.

15. Your Rights

Subject to applicable law and any lawful limitations, you may have rights concerning your personal information, including the right to:• Be informed about the processing of your personal information
• Request access to personal information we hold about you
• Request correction or rectification of inaccurate or incomplete information
• Object to certain processing
• Request erasure or blocking of personal information in circumstances permitted by law
• Request data portability where applicable
• Withdraw consent where processing is based on consent
• File a complaint concerning the processing of your personal information
• Seek damages where provided by applicable lawThese rights are not absolute and may be subject to conditions, exceptions, or limitations under applicable law.For example, SperX may retain certain information when retention is necessary for a lawful purpose, including the administration of loyalty programs, legal compliance, security, or the establishment, exercise, or defense of legal claims.The Philippine National Privacy Commission recognizes these and other data-subject rights under the Data Privacy Act.

16. How to Exercise Your Privacy Rights

To exercise a privacy right or raise a privacy-related concern, you may contact SperX using the privacy contact information provided below.We may need to verify your identity or request additional information before processing certain requests in order to protect your account and personal information.We will evaluate and respond to requests in accordance with applicable law.

17. Children's and Minors' Privacy

SperX is not specifically designed or directed toward children.SperX is intended primarily for general use and is not marketed as a children's service.Minors may only use SperX where their use is appropriate and permitted under applicable law and, where required, with appropriate parental or legal guardian involvement or consent.If we become aware that personal information has been collected from a minor in circumstances where processing is not permitted, we may take appropriate steps to address the situation.

18. Philippine Data Privacy Act

SperX intends to process personal information in accordance with applicable Philippine privacy and data-protection laws, including Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its implementing rules and regulations.The Data Privacy Act requires personal information processing to observe the principles of transparency, legitimate purpose, and proportionality. Personal information should be collected for specified and legitimate purposes, processed fairly and lawfully, limited to what is necessary, and retained only for as long as necessary for the applicable purpose or another lawful basis for retention.

19. International Processing

Some of SperX's third-party service providers may process or store information outside the Philippines.Where personal information is processed or stored outside the Philippines, SperX will take reasonable measures to ensure that the processing is subject to appropriate safeguards and is consistent with applicable privacy and data-protection requirements.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:• SperX and its features
• Our information-processing practices
• Third-party service providers
• Applicable laws or regulations
• Security or operational requirementsWhen appropriate, we may notify users of material changes through the SperX platform or other reasonable means.The updated Privacy Policy will indicate its effective date.

21. Privacy and Your Use of SperX

This Privacy Policy is intended to provide clear information about how SperX processes personal information.Your use of SperX may also be subject to SperX's Terms & Conditions and other applicable notices or agreements.Where the Terms & Conditions and this Privacy Policy address different subjects, the Terms & Conditions govern the contractual terms of your use of SperX, while this Privacy Policy describes our processing of personal information.

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