PrivacyCloud

USD Subscription Terms

RINDOGATAN LLC · Version 1.4 · 26 October 2026 · PrivacyCloud edition of 5 November 2026

1. Scope and seller

These terms supplement the PrivacyCloud Terms of Service for the USD Subscription (the "Subscription"). On the matters they cover, they prevail over the Terms of Service. The data processing agreement (privacycloud.com/legal/eu-cloud-plan-dpa, the "DPA") forms part of them. The US Privacy Addendum (privacycloud.com/legal/us-privacy-addendum) forms part of the DPA.

The seller of the Subscription, which also collects payment for it, is RINDOGATAN LLC, a Wyoming limited liability company with US employer identification number (EIN) 92-1306337, its registered office at 2120 Carey Avenue, Cheyenne, WY 82001, USA ("Rindogatan" or "we").

Once you become a Subscription customer, these Terms, the DPA and the privacy information they contain prevail, on the matters they cover, over the website Privacy Policy, which continues to apply to what you do on the website.

2. Who may subscribe

The Subscription is only for businesses and professionals subscribing for their business or professional activity. By subscribing you declare that you are not acting as a consumer and that the person subscribing can bind the organization.

We need your organization's legal name, address and, where one applies, its tax identification number. If it turns out that the subscriber is not a business or professional, we may cancel the Subscription and refund what was paid.

3. What the Subscription includes

Per organization: the PrivacyCloud privacy program, AI governance program and vendor catalog, with the data stored in European Union data centers (Annex III of the DPA), with no limit on the number of users. Your pilot organization and its records carry over when you subscribe.

AI is off by default and only your organization's administrator can switch it on. For now, AI features cannot be switched on for an organization that declares in the Services that a US state privacy law applies to it; we will tell you when that changes. When it is on, only the details of the record being drafted are sent to the AI provider, never your whole program; the provider, its location and the transfer safeguard are listed in Annex III of the DPA. On PrivacyCloud, AI features run on the AI engine we provide, at our cost, within reasonable usage limits that we may set and show in the Services. Your administrator may instead add your organization's own API inference key; the content is then sent to your provider under your own agreement with it, and that provider is not our sub-processor. The Subscription includes the rights-request module (clause 11). It does not include legal advice: the Services are tools (clause 3 of the Terms of Service).

We may improve or change features. If we withdraw a significant feature, we will give you thirty (30) days' notice and you may cancel with a refund of the unused part.

4. Price and payment

The Subscription costs US$179 a month or US$1,800 a year per organization (for taxes, see clause 5). It is paid in advance at the start of each period, by card, through our payment processor. We send you an electronic invoice in US dollars for each payment. The price is paid without any deduction; if the law requires you to withhold tax, you will increase the payment so that we receive the full amount.

5. Taxes

Prices do not include sales, use, value added, goods and services or similar taxes. Where the law requires us to collect such a tax on your purchase, we add it to the invoice at the applicable rate and show it separately. Where we do not collect it, you are responsible for any tax due where you are established, including by self-assessment or reverse charge. If your organization is exempt, send us a valid exemption certificate before the invoice is issued; we apply the exemption from the next invoice after we receive it. If the tax details you give us are wrong and a tax is claimed from us as a result, we may recover it from you.

6. Term, renewal and cancellation

The monthly Subscription renews each month and the yearly Subscription each year, automatically, until you cancel. We will remind you of the yearly renewal at least thirty (30) days before.

You may cancel at any time from the billing portal we link to from your receipt or by writing to us. Cancellation takes effect at the end of the period already paid and the unused part is not refunded, except in the cases in clauses 3 and 7 of these terms and clauses 8 and 17 of the DPA, or if you end the Subscription for our material breach not cured within thirty (30) days of your notice.

We may end the Subscription at the end of a period on sixty (60) days' notice, or immediately for your material breach not cured within thirty (30) days of our notice. In that last case there is no refund.

7. Price changes

We may change the price on at least thirty (30) days' notice by e-mail. The new price applies from the next renewal, never to a period already paid. If you do not accept it, you may cancel before that renewal.

8. Service level and support

We provide the Services with reasonable care and aim for continuous availability, but we do not guarantee an availability percentage and there are no service credits. Availability also depends on our providers. We announce scheduled maintenance in advance where possible.

Support by e-mail, in English or Spanish, on business days. We aim to reply within two (2) business days, which is a target and not a guarantee; problems that prevent use of the Services or affect security take priority. If you need a service level agreement with commitments, we can agree one separately for an additional fee.

9. Your data

Your data remains yours. We process it as processor under the DPA, store it in European Union data centers (with the exceptions in clause 9 of the DPA) and do not use it to train AI models. On the base subscription, we do not receive or hold data subjects' requests, nor their data or identity documents; the only exception is the rights-request module (clause 11), when your organization uses it, under Annex IV of the DPA, and even then never identity documents. We hold the data of the people who use the service and what your team records, as a processor.

The contact and billing data of your account is processed by the seller of the Subscription as controller, to manage the Subscription and meet its legal obligations.

You may export it at any time. When the Subscription ends you have thirty (30) days to export it; afterwards we delete it (clause 13 of the DPA). For this Subscription, this clause replaces the audit-log retention period in the AI governance program's product terms.

We keep backups of your data as described in Annex II of the DPA and, at your request, recover your organization's records as they stood at an earlier moment within the periods stated there, at no charge.

10. Non-payment and suspension

If a payment fails, we will retry it and tell you. If it remains unpaid ten (10) days after our notice, we may suspend access until you pay; your data is kept during the suspension. If the debt is still unpaid thirty (30) days after suspension, we may end the Subscription, and clause 9 then applies (thirty days to export). While the suspension lasts, you may ask us for an export of your data, which we will give you free of charge.

11. Rights-request module

The rights-request module is included in the Subscription, with up to one hundred (100) requests a calendar month (Spain time) per organization. Only requests received through the module's public form count; requests your staff enter in the module do not. We tell your organization's administrators by e-mail when it reaches fifty percent (50%), seventy-five percent (75%) and ninety percent (90%) of its monthly limit: fifty (50), seventy-five (75) and ninety (90) requests, or five hundred (500), seven hundred and fifty (750) and nine hundred (900) with the increase.

You may raise the limit to one thousand (1,000) requests a calendar month for US$45 a month per organization (for taxes, see clause 5): the increase is subscribed, renewed and cancelled separately, month to month, cancelling it does not affect the Subscription, and it ends when the Subscription ends. When the limit is reached, the form stops accepting requests until the next month and shows your organization's privacy contact instead, so that nobody is left unable to exercise their rights. The same applies during the free pilot.

Its processing terms are in Annex IV of the DPA: no identity documents, personal data removed thirty (30) days after each request is closed, access limited to your privacy staff and logged, no AI, and requests stored in the EU only (the e-mails the module sends go through the e-mail provider in Annex III of the DPA). Answering requests on time remains your responsibility.

12. Liability

The warranty disclaimer and limitation of liability in clauses 9 and 10 of the Terms of Service apply: our total liability will not exceed the greater of one hundred US dollars (US$100) or what you paid us for the Subscription and the module in the twelve (12) months before the claim, and we are not liable for indirect damages. These limits do not apply to willful misconduct or gross negligence or to what the law does not allow to be limited.

13. Governing law and disputes

These terms follow clause 11 of the Terms of Service: for customers established in the United States, the laws of the State of California and binding arbitration in California under the Commercial Arbitration Rules of the American Arbitration Association; for all other customers, Spanish law and the courts of Madrid (Spain). The DPA follows this clause on governing law and disputes (clause 17 of the DPA), except for the standard contractual clauses it incorporates, which keep their own (clause 9(a) of the DPA).

14. Language and notices

These terms are published in English only. We send notices by e-mail to your account's administrative address; you may send yours to info@rindogatan.com.