Agreement to Our Privacy Terms

This Privacy Notice for DL Software Inc ("we," "us," or "our"), is provided in our capacity as the data controller (or "controller") of your personal information under applicable data protection laws. It describes how and why we access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

■ Visit our website at https://www.godelterminal.com or any website of ours that links to this Privacy Notice
■ Use Godel Terminal. Godel Terminal is a professional web-based financial terminal software offering comprehensive financial and investment data.
■ Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We act as the controller for the processing described in this Policy. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@dl.software.

Controller details: DL Software Inc, 8 The Green, Dover, Ste 19028, DE 19901, USA. Email: contact@dl.software.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. See Section 1 (What information do we collect?).

What personal information do we process?
When you visit, use, or navigate our Services, we may process and/or share personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information?
Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process and/or share sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we collect any information from third parties?
We primarily collect information directly from you and from your devices. We may also receive limited data from third parties you authorize (e.g., social login providers, connected brokerage, trading, financial or third party accounts) and from service providers (e.g., payment processors) as needed to provide the Services.

How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. These may include rights of access, rectification, erasure, restriction, portability, objection, and to not be subject to solely automated decisions. See Sections 9 and 12.

How do you exercise your rights?
The easiest way to exercise your rights is by emailing privacy requests to contact@dl.software, or via http://www.godelterminal.com/contact. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
■ names
■ email addresses
■ mailing addresses
■ usernames
■ passwords

Sensitive Information. We do not intentionally collect special category data. If we process "student data" or other special categories of data, we will only do so on the basis of your explicit consent or another legal basis permitted by GDPR or other applicable laws, and only for clearly stated purposes.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy. Stripe acts as an independent controller for certain processing.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect the data that you have agreed to share via the social media site or third party platform in question, and certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Connected Account Data. By connecting any brokerage, trading, financial, or third-party account to the Services, you authorize us to collect, process, analyze, and store data from such accounts (“Connected Account Data”) for purposes of:
■ Operating and providing the Services;
■ Improving and training the Company’s data models and algorithms, as well as the Services;
■ Generating aggregated analytics, benchmarks, or insights;
■ Developing new or derivative products and features, and marketing the same to you or other parties.

We will not sell your Connected Account Data.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar tracking technologies when you interact with our services. You can find out more about this in our Cookie Notice: http://www.godelterminal.com/cookies and in Section 5, “Do We Use Cookies and Other Tracking Technologies?”, below.

The information we collect includes:
■ Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
■ Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
■ Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process personal information for the purposes listed below on the legal bases identified in Section 3. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

■ To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

■ To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

■ To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.

■ To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: http://www.godelterminal.com/cookies.

■ To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

■ To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

■ To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

■ To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

■ Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time via the methods in Section 9. Learn more about withdrawing your consent.

■ Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• Send users information about special offers and discounts on our products and services
• Develop and display personalized and relevant advertising content for our users
• Analyze how our Services are used so we can improve them to engage and retain users
• Support our marketing activities
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience

■ Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

■ Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

■ Performance of a Contract. We process your information where it is necessary to perform a contract with you or to take steps at your request before entering into a contract (e.g., account setup and provision of the Services).

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
■ If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
■ For investigations and fraud detection and prevention
■ For business transactions provided certain conditions are met
■ If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
■ For identifying injured, ill, or deceased persons and communicating with next of kin
■ If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
■ If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
■ If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
■ If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
■ If the collection is solely for journalistic, artistic, or literary purposes
■ If the information is publicly available and is specified by the regulations
■ We may disclose de-identified or anonymized information for research and statistical purposes, in accordance with applicable law.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

■ Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

■ Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

■ Service Providers/Subprocessors. We engage trusted vendors to process personal information on our behalf under data processing agreements that include GDPR-required terms. A list of key subprocessors is available on request.

■ Legal/Compliance. We may disclose information to comply with applicable law or respond to valid legal process.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, or to tailor advertisements to your interests (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: http://www.godelterminal.com/cookies. Where required by EEA/UK law, we obtain your consent before setting non-essential cookies and provide a mechanism to withdraw consent at any time.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps. Some social media providers may be outside the US or the EEA/UK; see Section 16 (International Data Transfers).

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user's account, unless tax or accounting obligations require that transaction records be kept for a longer period.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at contact@dl.software.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

We will consider and act upon any request in accordance with applicable data protection laws. We will respond within one month of receipt (extendable by two months where necessary) and will explain any extension.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

■ Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: http://www.godelterminal.com/cookies.

If you have questions or comments about your privacy rights, you may email us at contact@dl.software.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. However, the choices that we provide you concerning collection and use of your personal information will continue to operate as described in this Privacy Policy. For EEA/UK users, please use the cookie consent tools described in Section 5.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes. If you are a resident of one of the states listed below, you may have rights under your state’s consumer data privacy law to request access to or receive a copy of personal information we maintain about you, ask for correction of inaccuracies, request deletion of your personal information, and, where applicable under that law, withdraw any consent you have given for certain processing (for example, the sale or sharing of your data or profiling). These rights vary by state and may be subject to conditions, limitations and exceptions under state law.

The states currently include: California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

Category	Examples	Collected
A. Identifiers	Contact details such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our websites, applications, systems, and advertisements	YES
G. Geolocation data	Device location	YES (approximate - IP-based)
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	YES
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics	YES
L. Sensitive Personal Information	Account login information	YES

We only collect sensitive personal information, as defined by applicable privacy laws, for the purposes allowed by law or with your consent. Sensitive personal information may be used or disclosed to a service provider or contractor for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
■ Receiving help through our customer support channels
■ Participation in customer surveys or contests
■ Facilitation in the delivery of our Services and to respond to your inquiries

We will use and retain the collected personal information as needed to provide the Services or for:
■ Category A - life of account + 1 year
■ Category B - life of account + 1 year
■ Category F - 1 year
■ Category G - 1 year
■ Category J - as required by applicable education privacy laws or consent terms
■ Category K - 1 year
■ Category L - life of account + 1 year

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. If that changes, we will update this Notice and provide opt-out mechanisms as required by law. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers without providing required notices and opt-out/opt-in rights.

Your Rights

You have rights under certain US state data protection laws. These rights include:

■ Right to know whether or not we are processing your personal data

■ Right to access your personal data

■ Right to correct inaccuracies in your personal data

■ Right to request the deletion of your personal data

■ Right to obtain a copy of the personal data you previously shared with us

■ Right to non-discrimination for exercising your rights

■ Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

■ Right to access the categories of personal data being processed

■ Right to obtain a list of the categories of third parties to which we have disclosed personal data

■ Right to obtain a list of specific third parties to which we have disclosed personal data

■ Right to obtain a list of third parties to which we have sold personal data

■ Right to review, understand, question, and correct how personal data has been profiled

■ Right to limit use and disclosure of sensitive personal data

■ Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at contact@dl.software, by visiting http://www.godelterminal.com/contact, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.

If we cannot verify your identity from the information already maintained by us, we may request additional information for verification and for security or fraud-prevention purposes. If you submit the request through an authorized agent, we may collect additional information to verify your identity before processing your request, and the agent will need to provide written and signed permission from you.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at contact@dl.software. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
■ offer you the products or services that you want
■ respond to or help with your requests
■ manage your account with us
■ confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details provided in the section "

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner, and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information. If changes materially affect your rights, we will provide advance notice and, where required, obtain your consent.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contact@dl.software or contact us by post at:

DL Software Inc
8 The Green, Dover, Ste 19028, DE 19901, USA
Dover, DE 19901
United States

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please email us at contact@dl.software or submit a request via

16. INTERNATIONAL DATA TRANSFERS

We are based in the United States. If you access the Services from the EEA, UK, or Switzerland, your personal information may be transferred outside your jurisdiction (including to the U.S.).

Where we transfer personal information internationally, we rely on appropriate safeguards, such as: (a) adequacy decisions; (b) Standard Contractual Clauses (SCCs) approved by the European Commission and the UK International Data Transfer Addendum, as applicable; and (c) additional technical and organizational measures. Copies of relevant transfer safeguards are available on request.

PRIVACY POLICY