Debt Freedom Today — Privacy Policy

1. Introduction & who we are

Dantes Creative Labs LLC ("DCL," "we," "us," or "our") is an Arizona limited liability company (Arizona Corporation Commission Business ID 25089047) and independent software studio based in Phoenix, Arizona, United States. This policy describes our privacy practices for the Debt Freedom Today mobile application (the "App") and for our website at dantescreativelabs.com (together with the App, the "Services").

This Privacy Policy is published at https://dantescreativelabs.com/products/debt-freedom-today/ and applies to the Debt Freedom Today app. That page is the canonical location of this policy and is the privacy-policy URL we provide to the Apple App Store and Google Play for the App.

Debt Freedom Today is an informational payoff planning and calculator tool. It helps you organize the debts you enter and see a single, dated path to zero. It is not debt relief, debt settlement, debt management, credit counseling, or credit repair, it does not provide financial, legal, or tax advice, and it does not contact your creditors or any third party on your behalf.

For the purposes of the EU and UK General Data Protection Regulation (together, "GDPR"), DCL is the "controller" of the personal information described in this policy. For the purposes of U.S. state privacy laws such as the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), DCL is the "business" that determines the purposes and means of processing.

EU/UK representative (Article 27). DCL has not appointed a representative in the European Union or the United Kingdom under Article 27 of the GDPR. If a representative is later appointed, that representative's name and address will appear here and in the How to contact us section. Until then, individuals in the EEA or UK may contact us directly at contact@dantescreativelabs.com.

You can reach us at any time at contact@dantescreativelabs.com. Full contact details are in the How to contact us section below.

2. Scope of this policy

This policy applies to personal information we handle through the Services and to visitors, App users, and other individuals worldwide who interact with us. It does not apply to:

• The practices of Apple, Google, or other third parties that operate the app stores and payment systems through which the App is distributed and purchases are billed. Those companies have their own privacy policies that govern their handling of your information.
• Third-party websites, products, or services that we link to or that integrate with our Services. See Third-party links & services.

Where this policy and any App-specific notice presented inside the App conflict, the App-specific notice controls for that feature.

3. Information we collect

We design the App to collect as little personal information as reasonably possible. The most sensitive information you provide — your debt figures — is, by default, processed and stored on your device and is not transmitted to our servers.

3.1 The debt information you enter

To build your payoff plan, the App lets you enter details about your debts, such as:

• Account balances;
• Interest rates (APRs);
• Minimum payments; and
• The labels or nicknames you give your debts (for example, "Car loan" or "Store card").

The App uses these inputs to calculate and display a payoff plan and a single, dated path to zero. This information stays on your device by default. We do not transmit it to DCL servers, we do not receive it, and we do not use it to build any profile of you. It remains on your device until you edit or delete it in the App or uninstall the App. If a future version of the App offers an optional feature that syncs or backs up this data (for example, to your own cloud account or across your devices), we will describe that feature and its handling in the App before you turn it on, and any such transmission will happen only at your direction.

Because you enter this information yourself and it is stored locally, you should protect access to your device. Anyone with access to your unlocked device may be able to view the debt information saved in the App.

3.2 Information common to the Services

In addition to the debt information above, we (and our service providers acting on our behalf) may collect the following:

Purchase and subscription records

When you start an auto-renewing subscription (or make any in-app purchase), the transaction is processed and billed by the Apple App Store or Google Play, not by DCL. We do not receive or store your full payment card number. We may receive confirmation of your purchase or subscription status, transaction identifiers, and aggregated or anonymized sales data from the stores so we can deliver and support what you bought.

Usage analytics

Information about how you interact with the App — such as screens viewed, features used, session length, and general in-app events. We use this in aggregate to understand and improve the App. This analytics data does not include the specific debt figures you enter.

Crash and diagnostics data

Technical information generated when the App encounters an error or crash, such as error logs, the App version, and the state of the App at the time, so we can find and fix problems.

Device and technical information

Basic device information such as device model, operating-system version, language and region settings, and app-instance or device identifiers used for analytics, diagnostics, and fraud/security purposes. For our website, our hosting provider may also process standard server log information such as IP address, browser type, and pages requested.

Sources of information. We collect information directly from you (for example, the debt figures you type into the App), automatically from your device or browser (for example, analytics and diagnostics), and from the app stores and our service providers (for example, purchase confirmations and aggregated reports).

Sensitive information. We do not ask you to provide, and we do not intentionally collect, special categories of sensitive personal information. Where the App inputs could be considered sensitive by you — such as your financial figures — those inputs are handled on your device by default as described above and are not transmitted to us.

4. How we use information

We use the information described above to:

• Provide, operate, and maintain the App, and deliver the payoff-planning features you request;
• Process and deliver your auto-renewing subscriptions and any in-app purchases through the app stores, and provide related customer support;
• Understand how the App is used so we can debug, maintain, and improve it and develop new features;
• Detect, investigate, and prevent security incidents, fraud, abuse, and other harmful or unlawful activity, and protect the rights, property, and safety of DCL, our users, and others;
• Respond to your inquiries and communicate with you about the App, including service-related notices; and
• Comply with our legal obligations and enforce our terms and agreements.

We do not use your information to build advertising profiles, and we do not use third-party ad networks in the App. See How we share information.

5. Legal bases for processing (EU/UK)

If you are in the European Economic Area, the United Kingdom, or another jurisdiction with similar requirements, we process your personal information only where we have a valid legal basis to do so. Depending on the context, our legal bases are:

Performance of a contract

To provide the App you request and to deliver and support the subscriptions and purchases you buy (GDPR Article 6(1)(b)).

Legitimate interests

To operate, secure, debug, and improve the App, understand aggregate usage, and prevent fraud and abuse, where those interests are not overridden by your rights and freedoms (GDPR Article 6(1)(f)).

Consent

Where required — for example, for certain analytics or diagnostics on your device. You may withdraw consent at any time, including through your device settings, without affecting processing already carried out (GDPR Article 6(1)(a)).

Legal obligation

To comply with applicable laws, regulations, and lawful requests (GDPR Article 6(1)(c)).

6. How we share information

We are not in the business of selling data. We share personal information only in the limited circumstances described here.

6.1 Service providers (processors)

We use a small number of service providers that process information on our behalf and under our instructions, including:

• Apple and Google, which operate the app stores through which the App is distributed and which process all payments for our subscriptions and in-app purchases; we do not receive your full payment card details;
• Our analytics provider(s), which help us understand aggregate usage of the App; and
• Our crash and diagnostics provider(s) and website hosting provider, which help us detect, diagnose, and fix problems and deliver the website.

These providers are contractually limited to using the information only to provide services to us. We do not share the debt figures you enter with these or any other third parties, because that information stays on your device by default.

6.2 Legal, safety, and business transfers

We may disclose information if we believe in good faith that doing so is necessary to comply with a law, regulation, legal process, or governmental request; to enforce our terms; or to protect the rights, property, or safety of DCL, our users, or the public. If we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this policy.

6.3 What we do not do

We do not sell your personal information, and we do not share your personal information for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA and similar U.S. state laws. We do not use third-party advertising networks in the App, and we do not permit third parties to track you across apps or websites for advertising. In the preceding twelve (12) months, we have not sold or shared personal information for cross-context behavioral advertising.

7. International data transfers

We are based in the United States, and the service providers we use may process information in the United States and other countries. If you access the Services from outside the United States, any information that reaches our servers or our providers will be transferred to and processed in countries that may have data-protection laws different from those in your country. Your debt figures, however, stay on your device by default and are not part of any such transfer.

Where we transfer personal information out of the European Economic Area or the United Kingdom, we rely on appropriate safeguards recognized under applicable law, such as the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum), or another lawful transfer mechanism. You may contact us at contact@dantescreativelabs.com for more information about these safeguards.

8. Data retention

The debt information that stays on your device remains for as long as you keep it in the App; you can delete it at any time by clearing the relevant data in the App or by uninstalling the App.

For information we or our providers do process off-device — such as aggregated usage analytics, crash logs, and purchase/subscription records — we retain it only for as long as necessary for the purposes described in this policy, and then delete or anonymize it, unless a longer period is required to comply with our legal, tax, accounting, or reporting obligations, resolve disputes, or enforce our agreements. Analytics and diagnostics data are generally retained on a rolling basis and in aggregate rather than tied to your identity.

9. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, misuse, and alteration — including keeping your debt figures on your device by default, limiting the data we collect, and relying on the app stores' secure payment processing. Encryption in transit is used where information is transmitted to our providers.

No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping your device and any account credentials secure.

10. Children's privacy

The App is intended for a general audience and is not directed to children under 13 (or the equivalent minimum age in your jurisdiction). We do not knowingly collect personal information from children under 13 in a manner that would require verifiable parental consent under the U.S. Children's Online Privacy Protection Act ("COPPA") or similar laws.

In the European Economic Area and the United Kingdom, the minimum age at which a child can consent to the processing of personal information (the "digital age of consent") is set by local law and ranges from 13 to 16 depending on the country. Where you are in the EEA or UK, we do not knowingly collect personal information from anyone below the applicable local minimum age without the consent or authorization of a parent or guardian as required by that local law.

If you believe a child has provided us with personal information, please contact us at contact@dantescreativelabs.com and we will take appropriate steps to delete it.

11. Your privacy rights & choices

You have choices about your information, and depending on where you live, you may have specific legal rights. Because your debt figures stay on your device, you can exercise many of these choices directly — for example, by editing or deleting your data in the App, uninstalling the App, or adjusting your device's tracking and analytics permissions.

11.1 California residents (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know / access the categories and specific pieces of personal information we have collected about you, the sources, purposes, and categories of recipients;
• Delete personal information we have collected from you, subject to legal exceptions;
• Correct inaccurate personal information we maintain about you;
• Opt out of sale or sharing of your personal information for cross-context behavioral advertising — note that we do not sell or share personal information, so there is nothing to opt out of;
• Limit the use and disclosure of sensitive personal information — to the extent the financial figures you enter could be considered sensitive personal information, they are processed and stored on your device by default and are not transmitted to or collected by DCL; we therefore do not use sensitive personal information for any purpose that would trigger a right to limit, so there is nothing to limit; and
• Not be discriminated against for exercising your privacy rights. We will not deny you services, charge different prices, or provide a different level of quality because you exercised your rights.

Categories of personal information. The table below maps the information described in Information we collect to the categories of personal information enumerated under the CCPA/CPRA, together with the sources, business or commercial purposes, and categories of third parties to whom the information may be disclosed. We do not "sell" or "share" (for cross-context behavioral advertising) any category of personal information.

You may exercise these rights by emailing contact@dantescreativelabs.com. You may use an authorized agent to submit a request on your behalf; we may ask the agent to provide proof of authorization and may ask you to verify your identity directly. We will verify your request using information reasonably available to us before responding. Note that because your debt figures are stored only on your device and not on our servers, we may be unable to access, provide, correct, or delete that on-device information for you — but you can do so yourself at any time within the App.

11.2 EU, UK, and other regions (GDPR and similar laws)

If you are in the EEA, the UK, or a jurisdiction with comparable laws, you may have the right to request access to, correction of, or deletion of your personal information; to restrict or object to certain processing; to data portability; and to withdraw consent where processing is based on consent. You also have the right to lodge a complaint with your local data-protection or supervisory authority.

11.3 How to exercise your rights

To make any privacy request, email us at contact@dantescreativelabs.com and tell us what you would like to do. We will respond within the timeframes required by applicable law. There is no charge to make a request in most cases, and we will not discriminate against you for making one.

12. Do Not Track & Global Privacy Control

Some browsers offer a "Do Not Track" ("DNT") setting. Because there is no common industry standard for how to respond to DNT signals, our website does not currently respond to them. We do, however, honor the Global Privacy Control ("GPC") and similar opt-out preference signals where legally required. Because we do not sell or share personal information for cross-context behavioral advertising, a GPC signal will not change how we handle your information — there is nothing for it to opt out of.

13. Third-party links & services

The Services may contain links to third-party websites or services, and the App is distributed through and relies on the Apple App Store and Google Play. We do not control these third parties, and this policy does not apply to their practices. We encourage you to review the privacy policies of any third-party site or service you use, including Apple's and Google's.

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the App, or applicable law. When we do, we will revise the "Effective" date shown above and post the updated policy at its canonical location, https://dantescreativelabs.com/products/debt-freedom-today/. If we make material changes, we will take additional steps to notify you where required by law. Your continued use of the App after an update takes effect means you have reviewed the current policy.

15. How to contact us

If you have any questions, requests, or concerns about this Privacy Policy or our privacy practices, please contact us:

Email

contact@dantescreativelabs.com

Mail

Dantes Creative Labs LLC
4539 N 22nd St, Ste R
Phoenix, AZ 85016
USA

EU/UK representative (Article 27). DCL has not appointed a representative in the European Union or the United Kingdom under Article 27 of the GDPR. If a representative is appointed, that representative's name and address will be listed here. In the meantime, individuals in the EEA or UK, and supervisory authorities, may contact us directly using the email and mailing address above.

We will do our best to resolve any concern you bring to us directly.