Privacy Policy

This Privacy Policy sets out the privacy policies and practices for Soft Protocol and its subsidiaries and affiliates (collectively "Company", "we" or "us") with respect to the collection, use, and disclosure of your personal and non-personal information through any tool, websites, applications, products or services we provide (collectively, the "Services"). For purposes of clarity, when we refer to a "device" in this Privacy Policy, we mean any device, including desktop, laptop, PC or Mac computers, smartphones, tablets, or any other device that is used to access or interact with the Services.

By accessing or using our Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your personal and non-personal information in accordance with this Privacy Policy as a condition of your use. This Privacy Policy is subject to and governed by our Terms of Service (the "Terms"), available at softprotocol.site. Your use of the Services is subject to your continued compliance with, and agreement to, the Terms.

Collection of Personal Information

Company generally collects your personal information through:

1. your access to and use of Company software applications for devices ("Company Applications"),
2. your access to and use of any tools developed by Company,
3. your access to and use of Company's website (softprotocol.site) (the "Website"),
4. any interactions that you have with Company (for example, by contacting or submitting information to Company for any purpose), and
5. third-party organizations, including those that distribute Company Applications or who process payments for in-app purchases within the Company Applications (including, without limitation, Apple, Google and Amazon), our advertising partners (including, without limitation, advertising networks, many of which are specifically listed below), and credential management partners (including, without limitation, Facebook). The type of information that we collect in these circumstances will vary depending on the third party and the type of Company Application, but will generally include contact and demographic information such as your name and email address, age, user ID, account or registration information and location information. When you use a social media credential to log in, additional information we receive may include your public profile (including photo) and friends list.

Personal information is any information that relates to an identified or identifiable natural person. This might include your name, address, email address or phone number, and sign-in information for third-party social networking services. The personal information that Company collects will vary depending on the Services that you are using, including the Website or Company Applications, and how you access and use those Services, but may include your name, contact information (such as email address, mailing address, fax number, and telephone number), demographic information (such as gender, age, and occupation), your device's IP address, unique device identifier, MAC address, billing, financial account info or other transactional or identifier information regarding your device or systems, geolocation information, "cookies", social media information, and personal preferences.

Company may also collect and analyze non-personal information to evaluate how users use the Website or Company Applications. Such non-personal information may include general technical information about your computer, device, hardware, or software that you use to access the Website or Company Applications, requested pages, referring pages, or any of the information described above in circumstances where that information does not relate to an identified or identifiable natural person.

We may also obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

Cookies

Company and third parties working on Company's behalf may employ cookies and related technologies to store information on or read information from your browser or device. The technologies used for these purposes may include: (i) cookies; (ii) web beacons; (iii) tracking pixels; and/or (iv) local shared objects (also known as Flash cookies). Some of these cookies may lead to us collecting personal information about you and we may collect information to provide personalized ads. Third-party advertisers (and the ad networks they use) who place ads within the Services may use cookies or related technologies to deliver ads.

What Technologies We Use

Cookies

• A cookie is a small file stored on your computer or other device. A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions. By storing such information, cookies can, among other things, remember your preferences and settings for the Services and help us analyze how you use the Services.

Web Beacon / Pixel Tags

• Web beacons or pixel tags and similar technologies are small bits of code, which are embedded in web pages, ads, and e-mail, that communicate with third parties. Pixel tags can collect information such as the IP address of the computer that downloaded the page on which the web beacon appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie previously placed by that server. We may use web beacons to count the number of users who have visited a particular web page, to deliver or communicate with cookies, and to understand usage patterns. We also may include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Other Technologies

• There are other local storage and Internet technologies, such as Local Shared Objects (also referred to as "Flash cookies") and HTML5 local storage that operate similarly to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences across different services and sessions.
• Please note that these technologies are distinct from cookies, and you may not be able to control them using standard browser tools and settings. For information about disabling or deleting information contained in Flash cookies, please click here.

Purpose for Processing Personal Information

Company may process information, including personal information, in the following ways:

• to develop, deliver, maintain and improve Company Applications, the Website and other Company products and services and to better tailor them to meet the needs of Company's users, customers and potential customers (including for analytics purposes);
• to develop, deliver, maintain and improve Company's marketing and promotional efforts and manage its relationship with you; for third parties to provide Company and you with their products and services including, without limitation, advertising, making ad targeting decisions, conducting audience segmentation and targeting in connection with online behavioral advertising, providing monetization services, maintaining their services, improving their services, and analyzing the marketplace for their services as well as for the performance of their services, researching and developing new services, fraud prevention, bot detection, quality rating, analytics, and enhancements. If you are interested in who we share your information with and what information is shared with them, you may request further information from our Privacy Officer at privacy@softprotocol.site;
• optimization, viewability, geolocation services, ad security, ad verification services, and service misuse prevention;
• to create and share statistics and reports regarding aggregate usage of Company Applications;
• to enable user-to-user communications;
• to credit or accept payments;
• to provide technical support and respond to inquiries or feedback;
• to communicate with you in connection with Company Applications or the Website;
• to assist law enforcement agencies with the investigation of actual or potential fraud or other offences as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain;
• for any other purpose in connection with Company's or a third party's legitimate business interests;
• to establish or exercise legal rights or defend against legal claims; and
• as otherwise required or permitted by law.

Any of the foregoing may involve our combining the personal information we collect with personal information collected by third parties, such as our advertising partners, business partners and services providers.

Social Activities

By using the Services, you may elect to disclose Personal Information on or within Company Applications, message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our social media pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of such shared information will be governed by the social media provider's privacy policy.

Information Sharing

In certain circumstances, we provide your information to other companies that perform Services on our behalf, or third parties may collect your personal information in connection with your access to and use of the Company Applications or the Website. For example, we may employ service providers to process payments; host or store our data; deliver email messages or analyze data. We also work with advertising partners, who may collect the personal information or use tracking technology to process personal information in accordance with its privacy policy, as it exists and may be amended from time to time.

We may further share your information for:

(a) Safety, security, and legal compliance:

• When we have a good faith belief that we are required to disclose the information in response to legal process (e.g., if we receive a court order, search warrant, subpoena, or similar legal process);
• To satisfy any applicable laws or regulations;
• If we believe that any of our Services is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• When we have a good faith belief that there is a meaningful risk that poses a threat to the safety of you, another person or the public generally; and
• In order to protect the rights or property of Company, including to enforce the terms and licenses that govern the use of the Services.

(b) Sale or merger: In the event that Company explores or undergoes a business transition, such as a merger, acquisition by another company, transfer of control, or sale of all or a portion of its assets, we may share or transfer all of your information, including personal information.

(c) De-identified and/or aggregated information: Some of the information we collect does not directly identify you or your device. We may modify other information that can identify you or your device to limit or prevent such identification by de-identifying it or aggregating it. We can share de-identified and/or aggregated information with any third party without restriction and use it for any purpose.

Legal Basis for Processing Personal Information

We rely on your consent to serve as the legal basis for our processing of your personal information in accordance with this Privacy Policy. We may occasionally rely on other legal bases in order to process your personal information in certain ways, for example where the processing is necessary in order to comply with a legal obligation to which Company is subject. Where consent serves as the legal basis for our processing of your personal information, you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent prior to that withdrawal, by notifying Company's privacy officer (contact at the bottom of this Privacy Policy).

Retention of Personal Information

Company will retain personal information:

• in relation to a Company Application, until we permanently discontinue the Company Application (we assume you want to be able to restore your activity with respect to the Company Application at any time, so we only delete information where we are discontinuing the Company Application and have decided to never restore it); and
• otherwise, only as long as necessary for the purposes outlined in this Privacy Policy or as required or permitted by law.

Disclosure of Personal Information

Company may disclose your personal information to the following organizations or types of organizations:

• third party service providers and Company's affiliated entities who carry out work on behalf of, or provide products and services to, Company,
• law enforcement agencies,
• legal, financial, insurance, and other advisors, and
• as otherwise required or permitted by law.

Company will not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required or permitted by law. Company acts as the controller in relation to your personal information, but there may be some circumstances in which a third-party recipient of that information may also act as the controller of that information.

Your Rights

When appropriate, you may request to (i) opt-out of receiving communications from Company, (ii) remove your personal information from Company's records, or (iii) elect to no longer receive information from Company. If you wish to opt-out in the manner as listed above, please contact Company's privacy officer (contact at the bottom of this Privacy Policy). You may also be able to opt out of the collection and use of your information by third parties for ad targeting purposes through avenues such as http://www.aboutads.info/choices.

However,

• we reserve the right to send a message confirming your opt-out, whether it applies to email or SMS messages; and
• if you opt-out of marketing messages you may still receive administrative, relationship, or transactional messages (including, without limitation, notices about changes to our Terms or changes to the functionality of a product or Service).

In addition, you may have the right in certain circumstances under privacy laws to request from Company:

• access to,
• rectification or erasure of,
• restrictions in relation to the processing of (including in relation to direct marketing), and
• data portability in relation to, the personal information that we hold about you.

Please contact Company's privacy officer in order to make such a request.

Privacy of Children

Company does not knowingly collect personal information from children under 16 without appropriate parental notice and consent. If you are under 16, please do not attempt to use the Company Applications or the Website or send any information about yourself to Company, including your name, address, telephone number, or email address. No one under age 16 may provide any personal information to Company. In the event that Company learns that it has collected personal information from a child under age 16 without verification of parental consent, Company will delete that information as quickly as possible. If you believe that Company might have any information from or about a child under 16, please contact Company's privacy officer.

Security

Company takes steps to protect the loss, misuse, and alteration of the personal information that it holds. Company seeks to limit access to personal information to individuals who Company reasonably believes need to access the information to utilize the information as set out in this Privacy Policy. However, it is possible that any information transmitted via the Internet may be intercepted by unknown third parties. Please note that no system can be guaranteed to be 100% secure. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee or warrant the security of the information you share with us and we cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your information.

Complaints

You may direct a written complaint regarding compliance with this Privacy Policy to the Privacy Officer at privacy@softprotocol.site and, within a reasonable time upon receiving the written complaint, the Privacy Officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, the Privacy Officer will inform you whether the complaint will be allowed or denied. If the Privacy Officer allows the complaint, Company will take appropriate measures necessary to rectify the source of the complaint. Separately, you may also be able to lodge a complaint with a supervisory authority or privacy commissioner of your applicable jurisdiction.

"Do Not Track"

We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide information in our Cookie Policy about how to prevent the delivery of targeted ads, and information in this policy about how to prevent Google Analytics and Twitter from collecting information. We do not, however, recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions. To learn more about Do Not Track signals, you can visit allaboutdnt.com.

International Data Transfer

Under the General Data Protection Regulation (GDPR) and other data protection laws, information about you may only be transferred from the European Economic Area (EEA) to outside the EEA if adequate data protections are in place. Our Services are managed by Company's headquarters in Canada. As the European Commission considers Canada to be a country which provides adequate data protection, information about you may be transferred from the EEA to Canada.

Company also uses third-party service providers, such as managed hosting providers, credit card processors, and technology partners to provide the software, networking, infrastructure and other services required to operate the Services. These third-party providers may process or store personal data on servers outside of the EEA and Switzerland, including in Canada or the US. We rely on adequacy (if sent to Canada), the service provider's registration in the EU-US Privacy Shield and Swiss-US Privacy Shield (if sent to the US), and/or standard contractual clauses (if sent to the US or onward to other countries) to ensure that information about you is lawfully transferred under EU law.

By visiting our Website or using our Services, you acknowledge and agree that your personal information may be collected, used, disclosed and otherwise processed for the purposes identified in this Privacy Policy. In addition, your personal information may be maintained and processed by Company and our third-party service providers and affiliates in the country in which it was collected and in other countries, including the United States, where laws regarding the processing of personal information may be less protective than the laws in your country.

Links

Company is not responsible for the privacy practices of other websites, games or applications, including those that you access via a link provided in the Company Applications or on the Website. Company encourages you to read the privacy policy of websites, games or applications operated by third parties. This Privacy Policy applies solely to information collected by Company in accordance with the section above entitled "Collection of Personal Information".

Changes to This Privacy Policy

Company may update this Privacy Policy from time to time. It is your responsibility to periodically review this Privacy Policy to remain informed of Company's current privacy practices. Your continued access to or use of the Website and Company Applications after such update constitutes your acceptance of this Privacy Policy as amended.

Contact

If you have any questions about this Privacy Policy, Company's privacy practices in connection with the Website or Company Applications, please contact Company's Privacy Officer as follows:
privacy@softprotocol.site
Version 4.0
Last updated: 2026-04-20