DATA PRIVACY POLICY

Last Updated: June 4, 2026

This Data Privacy Policy defines the protocols by which Donaus Technology Company (operating under the registered assumed name Donaus Co.) processes technical and administrative data in connection with its corporate website, software applications, hosting infrastructure, and customer-facing interfaces. This policy applies to all business clients, administrative users, and visitors who interact with the services of the Company.

1. Architectural Privacy Standards and Zero-Tracking Commitment

The Company designs and hosts digital business tools, software applications, and websites according to a strict "Privacy by Default" model. The applications built and hosted by the Company are designed to operate without collecting or tracking consumer data.

• No Consumer Tracking: The applications do not use cookies, web beacons, tracking pixels, or local storage to monitor or analyze user behavior.
• No Cross-Context Profiling: The software does not build, store, or share consumer profiles, preventing any cross-context behavioral advertising.
• No Sale or Sharing of Data: Because the Company does not collect consumer personal data, the Company does not sell or share consumer information.

2. Categories of Information Processed

2.1 Server Security and Performance Logs

When a user accesses a website or application hosted on the Company's servers, the system automatically processes and logs technical metadata. This processing is necessary to support the Company’s legitimate interests in maintaining network security, preventing cyberattacks, and ensuring stable hosting performance.

• Data Fields: This metadata includes IP addresses, request timestamps, operating system types, browser user-agent strings, and accessed URL paths.
• Retention: This metadata is kept in secure logs and is automatically purged within one year, unless a specific security incident requires longer retention for legal or investigative purposes.
• Legal Basis: This processing is based on the legitimate interest of the Company to secure and manage its web hosting infrastructure.

2.2 Client Account and Billing Data

The Company processes personal information provided by corporate representatives during onboarding, account setup, and invoicing.

• Data Fields: This information includes corporate contact names, business email addresses, phone numbers, physical business locations, and billing details.
• Retention: This client account data is retained for the duration of the active contract, and for up to three years after termination to resolve billing disputes, support tax reporting, and defend against potential legal claims.
• Legal Basis: This processing is necessary to execute and manage the contract between the Company and the Client.

3. Allocation of Roles: Controller vs. Processor

Under applicable state and federal privacy statutes, the legal relationship between the Company and its business clients is defined as follows:

• The Client as Controller: The business client remains the Data Controller for any user data processed within their own application environment. The Client is responsible for maintaining their own privacy notices, managing user consents, and handling consumer rights requests.
• The Company as Processor: The Company acts strictly as a Data Processor, hosting the software and providing technical infrastructure as instructed by the Client. The Company’s hosting environments do not collect or store consumer data for its own business purposes.

4. Children’s Privacy Protection

The software services, websites, and digital tools developed by the Company are designed strictly for adult audiences and commercial business operations. The Company does not knowingly collect, process, or store personal information from children under the age of thirteen. If it is discovered that a child has provided personal data to the Company's hosting servers, that information will be immediately and permanently deleted from all active storage.

5. Technical and Organizational Security Measures

The Company implements appropriate technical security protocols to protect client files, metadata, and communications from unauthorized access, loss, or alteration. These measures include:

• Enforcing secure encryption in transit using Transport Layer Security (TLS) and Secure Sockets Layer (SSL) protocols.
• Configuring server-level firewalls, maintaining access controls, and running security monitoring.
• Restricting access to hosting environments and client account records to authorized technical staff who have a verified business need.

6. Modifications to this Privacy Policy

The Company reserves the right to modify this Data Privacy Policy to reflect technical updates, operational adjustments, or changes in regulatory compliance mandates. Any updates will be posted directly to this webpage with the modified date at the top of the document updated accordingly. Continual use of the software, websites, or hosting services after updates are posted constitutes acknowledgement of the modified policy.

7. Administrative and Contact Inquiries

For questions regarding this Data Privacy Policy or the data processing practices of the Company, contact the legal department at:

Donaus Co. Legal Department

Email: legal@donaus.co