I. GENERAL

This privacy notice sets out how Sabio Inc. ("Sabio" or "we") uses and protects any information that we may collect about you when you visit our website https://sabio.inc/ (the “Website”), correspond with us, or when you interact with our Platforms and/or Services (as described below). 

Sabio operates a set of advertising platforms (the “Platforms”) that facilitate the delivery of digital advertising on connected TVs and mobile devices. The Platforms include: (1) the Sabio Demand Side Platform (“Sabio DSP”) which enables advertisers to manage their campaigns, (2) The Vidillion Supply Side Platform (“Vidillion SSP”) which enables connected TV streaming apps to manage their ad inventory on their respective digital media networks and platforms (“Digital Platforms”), and (3) the AppScience s(“AppScience”) which  offers data analytics, attribution, measurement for connected TV solutions and mobile advertising products and services and is covered under a different privacy policy available here.

The Platforms enables Sabio to provide advertising products and services (the "Services") to its customers. The Platforms and Services rely on the analysis of behavior the users of mobile applications, CTV solutions and other forms of digital media (collectively, “Digital Properties”). In order to provide the Services, the Platforms collect pseudonymous personal information from the Digital Properties which have enabled our Platforms and Services. Our Platforms and Services involve digital advertising and include measurement, attribution, and ad targeting to Internet users as they visit Digital Properties which have enabled our Platforms and Services. We consider companies seeking to advertise on Digital Properties our “Customers” and the owners and operators of those Digital Properties as our “Partners.”

II. WHAT WE MEAN BY "PERSONAL DATA" AND “PERSONAL INFORMATION”

The definition of personal data and/or personal information varies by jurisdiction. Sabio thinks about the personal data we process in terms of whether or not the data may be used by Sabio to identify a data subject. Accordingly, we place the personal data we process into two categories: identifiable personal data and pseudonymous personal data. We recognize that identifiable personal data and pseudonymous personal data are considered personal data under the applicable privacy and/or data protection laws in many places. For this privacy notice, we will use the term “Personal Information” to describe both pseudonymous and identifiable personal data. We also believe that data that may not be used to identify an individual is inherently less risky. Accordingly, Sabio endeavors to use pseudonymous Personal Information via our Platforms and Services.

III. HOW DO WE COLLECT AND USE YOUR PERSONAL INFORMATION VIA THE WEBSITE

 (1) Data You Provide to Us via the Website

When you use the Website or otherwise communicate with us, we collect identifying Personal Information that you provide to us directly, including: Name, e-mail, physical address, and telephone number. We collect such data in the following circumstances: when you sign up for a newsletter, when you contact us via the Website; and when you otherwise communicate with us. Such sources include: (a) Information you provide through our ‘Contact Us’ section; (b) Information provided via email; (c) If you are one of our customers, suppliers, or prospects, we may process limited Personal Information in the course of our business relation with you, for example when you place an order, request a demo, or vice versa; (d) Transaction and limited (non-PCI) payment data; and (e) We may also collect any other information you may want to share with us, such as Personal Information related to recruitment / job applications. We may also receive information collected from current and prospective employees includes: Name, e-mail, physical address, telephone number, demographic information, job titles, work history, school attended, employment history, references, interviews.

Moreover, if you contact us, a record of this correspondence may be kept.  We use this information for the purpose intended. For example, if you ask us a question via the Website, we’ll use the information provided to answer your question.

We use the identifying Personal Information you provide to us when you contact us in relation to enquiries, orders, comments, or complaints made by you for conducting business with you and for our legitimate interest of communicating with you about our products and services. With your consent (unless otherwise permitted by applicable law) we use the identifying Personal Information you provide us via our Website to send you information on our products and services, special offers and other information based on the interests that you have indicated to us. If you do not wish to receive such information, you can indicate so via the details directly below or the links provided in our emails. If you are one of our current or prospective Customers, suppliers, or Partners, we use Personal Information about you to communicate with you, to establish advertiser and publisher accounts on our platform, and otherwise as necessary to conduct our business. This may include verifying your identity, communicating with you, and arranging the provision of products and services. We also use such Personal Information about you for our legitimate interests of documenting and managing our internal administration.

In addition to the above, we use Personal Information in order to comply with applicable laws and for our legitimate purposes of protection our legal rights and the data we process, in connection with legal claims, and for compliance, regulatory, and investigative purposes. This may include sharing the Personal Information with third parties, such as governmental authorities or law enforcement officials subject to applicable law.

      (2) Data Collected Automatically via the Website

Sabio automatically collects pseudonymous Personal Information from visitors to this Website, including your IP address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system.

We use the pseudonymous Personal Information we obtain from the use of the Website to better understand how you interact with the Website, to monitor aggregate usage by our users and web traffic routing on the Website, and to operate and improve the Website and services offered via the Website. We may also collect pseudonymous Personal Information from this Website to serve targeted ads on other websites about our products and services as described below.

     (3) Cookies and other Tracking Technologies via the Website – Ad Choices

Sabio and our partners use cookies or similar technologies to analyze trends, administer the Website, and track users’ movements around the website. Users can control the use of cookies at the individual browser level. For more information about cookies, please visit: http://www.allaboutcookies.org/cookies/.

We partner with a third party to collect pseudonymous Personal Information on this Website, conduct analytics on this Website, or to manage our advertising on other sites. Because we enable these third parties on the Website, we may be considered to have sold data to these third parties over the past 12 months. You can opt-out from these sales via the “Do Not Sell My Personal Information” link at the footer of the Website. Some of our third-party partners that use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests offer you the ability to opt-out. If you wish to opt out of interest-based advertising from those partners, click here.

Sabio also uses Google Analytics as an element of the Website. Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Website, the Internet Protocol address, and the type of operating system used in the devices used to access the Website. For more information about Google Analytics and privacy, click here. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.

Sabio also uses LinkedIn as an element of the Website. LinkedIn collects and stores data such as time of visit, pages visited, time spent on each page of the Website, the Internet Protocol address, and the type of operating system used in the devices used to access the Website. For more information about LinkedIn and privacy, click here.

Sabio also uses Hubspot as an element of the Website. Hubspot collects and stores data such as time of visit, pages visited, time spent on each page of the Website, the Internet Protocol address, and the type of operating system used in the devices used to access the Website. For more information about Hubspot and privacy, click here.

IV. HOW DO WE COLLECT AND USE YOUR PERSONAL INFORMATION VIA THE SERVICES

     (1) Overview of the Platforms and Services

As noted above, the Sabio DSP enables advertisers to manage their campaigns and the Vidillion SSP enables connected TV streaming apps to manage their ad inventory on their respective digital media networks and platforms (“Digital Platforms”).

In order to provide the Services, our Platforms collect pseudonymous Personal Information about your computer or device as you visit third-party website, mobile applications, CTV and other forms of digital media (collectively, “Digital Properties”) which have enabled our Platforms and Services. Our Platforms and Services involve digital advertising and include measurement, attribution, and ad targeting to Internet users as they visit Digital Properties. We consider companies seeking to advertise on Digital Properties our “Customers” and the owners and operators of those Digital Properties as our “Partners.”

     (2) Data Collected via the Platforms and Services

We collect and process pseudonymous Personal Information, including:

• Device Data: We collect data from the device you are using, including: pseudonymous advertising ID’s, IP addresses, click stream data, operating systems of that device and similar hardware qualifiers.
• Digital Property Data: We collect information about the nature of the mobile applications, websites and other Digital Properties that you may visit where our Platforms and Services are enabled which enables us to infer certain characteristics about you that we use for ad targeting via the Platforms and Services; and
• Demographic information including Age and income.

      (3) Data Received from third parties data brokers in connection with the Platforms and Services

In connection with the Platforms and Services, we may receive similar data as described above from third parties in accordance with their privacy policies. For example, we receive pseudonymous Personal Information from data partners that enable us to better understand more about the visitors to Digital Properties via our Platforms and Services.
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The data processed in connection with the Platforms and Services is used for the following purposes:

• Targeted advertising;
• Building audience profile segments for advertising;
• Predicting user preferences to deliver advertising;
• Analytics and/or market research;
• Improving the relevance of advertising;
• Identifying possible relationships among different browsers and devices, including linking multiple computers and devices together via a device graph;
• Limiting the number of times a specific advertisement is presented to the same device (frequency capping);
• Providing an advertisement to only certain types of devices; and
• Providing a report to a client on the number of its advertisements that were clicked.

V. ONWARD TRANSFER - WHO DO WE SHARE PERSONAL INFORMATION WITH?

We may disclose Personal Information you provide to us or that we collect automatically on the Website and in and through the Platforms and Services with the following categories of third parties:

• Our Customers;
• Service providers, such as data storage service providers, marketing service providers, and communications service providers. Such service providers may not sell or share such information by contract, are only allowed to use Personal Information disclosed to them for the purpose of providing the services we request and for no other purposes;
• Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
• Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Website, Platforms and/or the Services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Notice.

VI. THE PRIVACY CHOICES AVAILABLE TO YOU VIA THE SERVICES / OPTING OUT

Sabio engages in profiling, targeted advertising and the sale/sharing of Personal Information. Different jurisdictions offer different privacy choices to data subjects. When Sabio is able to detect that a User has exercised an opt-out choice, we stop processing data for the opted out device. We may see an opt-out signal: (a) via one of the Digital Properties on which we operate the Platforms and Services, (b) via the mobile operating system used by a particular mobile device, (c) via the CTV operating system operated by a SmartTV, or (d) when a data subject opts out of the Sabio Platforms and Services directly via the Do Not Sell My Info link. To the extent that we obtain data via a browser, we honor opt-out preference and/or Do Not Track signals as required by law.

An industry trade group called the NAI provides a helpful overview of many of the Mobile O/S and CTV opt-out choices available and specific instructions regarding how you may opt-out most mobile application and CTV environments.

VII. CHILDREN

Neither the Website, the Platforms nor the Services are intended for children under the age of 18. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years of age. We do not intentionally collect, sell, or process the Personal Information of individuals under 18 years of age. We ask Digital Properties directed to children not to provide Personal Information to us via the Platforms or Services. If you are under 18, please do not provide us with any of your information unless you have the permission of your parent or guardian.

VIII. DATA SUBJECT RIGHTS

Where we process Personal Information, individuals have the right to ask us for an overview of the Personal Information we have about them and also to access, correct, port, or delete certain Personal Information. These rights are not absolute and different jurisdictions offer different rights. As such, we are not legally obligated to agree to such requests in all circumstances, and in certain circumstances, agreeing to a request may be infeasible.  For example, a deletion request may contradict our legal obligations when we are required by law to maintain the Personal Information. Please also note that we are not able to act on any of the above requests if we are not in a position to identify an individual filing such request.

Where applicable, these rights can be exercised by sending us an email through the contact details further below. Depending on where you live, you may have a right to appeal our decision and/or lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at privacy@sabio.inc so we have an opportunity to address your concerns directly before you do so.

U.S. Data Subjects

In addition to the opt-out rights described above, certain U.S. States (e.g., California, Colorado, Connecticut, Nevada, Virginia and Utah) provide specific rights to data subjects located in those States. Sabio will make a good faith effort to honor the below rights to data subjects located throughout the U.S., including the:

• Right to delete Personal Information
• Right to correct inaccurate Personal Information
• Right to know what Personal Information is being collected
• Right to know what Personal Information is sold or shared and to whom
• Right of no retaliation following opt out or exercise of other rights.
• Where required by law, the right to appeal our decisions in terms of how we honor your rights.

We collect the categories of personal information about California consumers identified in the chart below. The below is designed more as a summary. More information regarding the personal information we collect can be found throughout our privacy policy.

Categories of Personal Information

Examples

Collected in Prior 12 Months:

A. Personal and online identifiers.

A real name, alias, unique personal identifier, online identifier Internet Protocol address, email address, account name, or other similar identifiers.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, telephone number, education, employment, or employment history. Some personal information included in this category may overlap with other categories.

Yes. Employment information covered under a separate policy.

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, sex (including gender, gender identity, or gender expression), veteran or military status, or genetic information.

No, although our customers may direct us to indicate that a particular user is male or female.

D. Commercial or transactions information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Yes, via our Website. The Platforms and Services collect similar data in the mobile and CTV environments.

G. Geolocation data.

Physical location.

No

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

I. Professional or employment-related information.

Current or past job history.

Yes. Employment information covered in a separate policy.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

To exercise your rights, please refer to the How to Exercise Your Rights section below.

EU, Swiss and UK Data Subjects

In addition to the opt-out rights described above, Data subjects located in the European Economic Area (EEA), the United Kingdom and Switzerland enjoy certain additional data protection rights. The General Data Protection Regulation (GDPR) governs our processing in the EEA, and Switzerland and the United Kingdom have similar data protection laws. Under the definitions of “Controller” and “Processor” under these laws, Sabio is processing data pursuant to the Platforms and Services as a Controller of Personal Information.

Legal Basis for Processing Personal Information

Our services do not currently engage in targeted advertising in the EEA, UK or Switzerland and we only retain data for a limited period. When we process Personal Information pursuant to the Platforms and Services as described above, we reserve the right to engage in such processing under our legitimate interest after having conducted an assessment ensuring that such interest is not outweighed by the rights or freedoms of individual data subjects.

Cross-Border Data Transfers

When we transfer your information outside of the EEA, the UK, or Switzerland (e.g., into the United States), we take steps to ensure it benefits from an adequate level of data protection and may rely on standard contractual clauses. The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies that collect Personal Information from data subjects located in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We may rely on standard contractual clauses to transfer information as described above to Customers in countries without an adequacy decision (e.g., the United States).

Data Protection Officer and EU and UK Representative

Our data Protection Officer may be contacted at dataprivacyofficer@sabio.io.

Our EU Representative is Verasafe and they may be contacted at EURep@Sabio.inc.

Our UK Representative is Verasafe and they may be contacted at UKRep@Sabio.inc.

IX. HOW TO EXERCISE YOUR DATA SUBJECT RIGHTS

      (i) Requests to Delete
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You have the right to request that we delete any Personal Information about you that we have collected. Upon receiving a verified request to delete Personal Information, we will do so unless otherwise authorized by law. You may submit a request to delete Personal Information via You may submit a request to rectify data by email at privacy@sabio.inc.

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      (ii) Right to Rectification

You have the right to obtain the rectification or inaccurate Personal Information . Taking into account the purposes of processing, you have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement. You may submit a request to rectify data by email at privacy@sabio.inc. 

      (iii) Requests to Know

You have the right to request that we disclose:

• The categories of Personal Information we have collected about you;
• The categories of Personal Information about you we have sold or disclosed for a business purpose;
• The categories of sources from which we have collected Personal Information about you;
• The business or commercial purposes for selling or collecting Personal Information about you;
• The categories of Personal Information sold or shared about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
• The specific pieces of Personal Information collected.

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You may submit a request to know via email at privacy@sabio.inc.
The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.
You have the right to request that we disclose:

      (iv) Right to Opt Out of the Sale of Personal Information

You have a right to opt out of the sale of Personal Information. You may, at any time, direct us to not sell Personal Information about you to third parties.  If you exercise your right to opt out of the sale of Personal Information about you, we will not sell Personal Information about you. Any Personal Information collected in connection with your request to opt-out of the sale of Personal Information about you will be used only to facilitate that request. You may opt out of the sale, sharing of Personal Information about you via the Services as well as any profiling and/or ad targeted via the Service at https://www.sabio.inc/do-not-sell-my-info.   You may also submit opt-out requests by emailing us at privacy@sabio.inc. 
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      (v) Right to Data Portability
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You have the right to receive personal data in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from us where the processing is based on consent and the processing is carried out by automated means. You may submit a request to know by email at privacy@sabio.inc.   You have the right not to be discriminated against for the exercise of your privacy rights described above.

      (vi) The Right to Non-Discrimination
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You have the right not to be discriminated against for the exercise of your privacy rights described above.
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      (vii) Authorized Agents
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You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us.

      (viii) Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request via:

E-mail: privacy@sabio.inc. 
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Toll Free Number: +1.844.974.2662

Mailing Address:
Sabio, Inc
16350 Ventura Blvd, Suite D827, Encino, CA 91436
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You may also submit opt out requests via https://www.sabio.inc/do-not-sell-my-info.

Upon receipt of a request, we may ask you for additional information to verify your identity in order to prevent fraudulent requests from being submitted. Any additional information you provide will be used only to verify your identity and not for any other purpose. A copy of the request will be retained as allowed / required under applicable law.

We will confirm your request within 5 days where required under applicable law. Subject to our ability to verify your identity, we will respond to your request within 15 days of receipt.

If your identity cannot be verified or identify your request as fraudulent, we may deny your request. You may appeal the decision by contacting us using the methods above.

·         The number of CCPA requests to know that Sabio received, compiled with whole or part and denied in 2023: 11, 11 and 0.

·         The number of CCPA requests to delete that Sabio received, compiled with whole or part and denied in 2023: 1,590,436, 1,590,436 and 0.

·         The number of CCPA requests to opt-out that Sabio received, compiled with whole or part and denied in 2023: 17, 17 and 0.

·         The median number of days within which Sabio substantively responded to requests to know, requests to delete and requests to opt-out in 2023: 3, 3 and 1. 

(ix) Categories of Personal Information the We Have Sold in the Last 12 Months

We have sold / shared the following categories of Personal Information during the last 12 months:

(A) Mobile device identifiers;
(B) Commercial information, including products or services purchased, obtained, or considered, ads you have clicked or viewed, or other purchasing or consumption histories or tendencies; and
(C) Internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with a web site, mobile application, or advertisement.

X. SECURITY - HOW WE KEEP YOUR PERSONAL INFORMATION SAFE

We maintain commercially reasonable risk-based security and data protection measures, which include, for example, end-to-end encryption for Personal Information in transit. We follow generally accepted industry standards to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information we process, we cannot guarantee its absolute security.

XI. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION

We retain Personal Information processed via the Platforms and Services for as long as needed for the purposes for which it was collected. The amount of personal data collected is commensurate to the specific purpose. Personal Information is limited to use for our legitimate business purposes, after which it is scrubbed, de-identified, anonymized or obfuscated as soon as possible unless otherwise required by applicable legislation. When operating the Platforms and Services in the EEA, UK or Switzerland, we store Personal Information for less than seven days after which the pseudonymous identifiers are removed.

Once data has been de-identified, Sabio commits to taking reasonable measures to ensure that data cannot be associated with a natural person and commit to maintaining and using de-identified data without attempting to re-identify the data.

If you are a customer or supplier of Sabio, we will retain Personal Information about you for the duration of the contractual relationship you or your company has with us and after the end of that relationship for as long as necessary to perform the purposes set out above or to comply with other legal obligations.

XII. LINKS TO OTHER WEBSITES

Our Website may contain links to other websites of interest. However, once you have used these links to leave our Website, we do not have any control over third party websites. We cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and review the privacy notice applicable to the website in question.

XIII. CHANGES TO THE PRIVACY NOTICE

This Privacy Notice is reviewed and updated annually and may change from time to time, effective from the date mentioned in the updated version of the Privacy Notice. Please check the Website periodically to review such changes in the Privacy Notice. We may email periodic reminders of our agreements and policies in the event of a change.

XIV. CONTACT US

If you have any questions or concerns about this Privacy Notice or about Sabio’s privacy or data security practices, please contact us via the following:

E-mail: privacy@sabio.inc

‍Toll Free Privacy Hotline: +1.844.974.2662

Mailing Address:
Sabio, Inc.

16350 Ventura Blvd, Suite D827, Encino, CA 91436

If you have questions in relation to our use of your Personal Information you should contact the relevant Data Privacy Officer:

Data Privacy and Data Protection Officer
Sabio,Inc.

dataprivacyofficer@sabio.inc.
  

VeraSafe has been appointed as Sabio’s representative in the EU for data protection matters, pursuant to Article 27 of the EU GDPR. VeraSafe can be contacted in addition to Sabio only on matters related to the processing of personal data under the EU GDPR. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd

Unit 3D North Point House

North Point Business Park

New Mallow Road

Cork T23AT2P

Ireland

UK REPRESENTATIVE

VeraSafe has been appointed as Sabio’s representative in the UK for data protection matters, pursuant to Article 27 of the UK GDPR. VeraSafe can be contacted in addition to Sabio only on matters related to the processing of personal data under the UK GDPR. To make such an inquiry, please contact VeraSafe using this contact form:

https://verasafe.com/public-resources/contact-data-protection-representative

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.

37 Albert Embankment

London SE1 7TL

United Kingdom

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