The fine print, in plain view.

# Arksa End User Licence Agreement
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**Last updated:** 2026-10-14

This End User Licence Agreement ("**Agreement**") is between **Ashforde OÜ**, registry code 17321180, Ahtri tn 12,
15551 Tallinn, Estonia ("**Arksa**", "**we**", "**us**") and the person or organisation accepting it ("**Customer**",
"**you**"). It governs your use of the Arksa web application and, when available, the desktop and mobile
applications, command-line tools and APIs, and related documentation (together, the "**Software**"), and the hosted Arksa services (the "**Services**"). "**Arksa**" also
names the product, which is how we use it in "the Arksa platform".

By creating an account, installing the Software, or clicking to accept, you agree to this Agreement. If you accept
on behalf of an organisation, you confirm you have authority to bind it, and "you" means that organisation. If you
do not agree, do not use the Software.

Arksa is a business product. If you use it as a consumer (for example as a student on your own account), the
consumer rules in §20.3 apply to you.

## 1. Definitions

- **Plan**: the subscription tier you select (currently Pro, Team, Mission and Sovereign), or an Academic
  partnership, a pilot or other access we grant in writing, as described in the plan catalogue on our website or in
  an Order Form. Plan names, limits and prices may change as set out in §17.
- **Order Form**: a written or online order that references this Agreement and states the Plan, number of Seats,
  term and fees. Pilot terms are an Order Form.
- **Seat**: a licence for one named individual ("**Authorised User**") to use the Software under your account.
- **Customer Data**: scenarios, mission files, documents and other content you or your Authorised Users create,
  upload or store with the Software or Services.
- **Output**: the results, reports, plots, exports and files the Software produces from your Customer Data.
- **Third-Party Data**: data that comes from someone other than you or us, such as satellite catalogues,
  space-weather data, Earth orientation data and ephemerides.
- **Licence File**: a digitally signed file or token we issue that enables features of a Plan, including on
  air-gapped Sovereign sites.
- **Confidential Information**: non-public information one party gives the other that is marked confidential or
  that a reasonable person would treat as confidential. Your Customer Data is your Confidential Information. The
  Software's non-public parts, our non-public features and our pricing are ours.

## 2. Licence grant

2.1 Subject to this Agreement and payment of applicable fees, we grant you a non-exclusive, non-transferable,
non-sublicensable licence during the subscription term to install and use the Software, and to access the
Services, for your internal business, research or educational purposes, within the limits of your Plan.

2.2 **Academic partnerships and granted access.** An Academic partnership licenses non-commercial teaching and
research only, under its partnership agreement; exports carry the watermark "Arksa Academic – not for commercial
use". Any access we grant at no charge has the limits we state when granting it and may end on reasonable notice.

2.3 **Paid Plans.** Pro licenses one Authorised User. Team (minimum three Seats), Mission and Sovereign license the
number of Seats in your subscription or Order Form. Sovereign may include deployment on your own servers, private
compute and additional terms in an Order Form.

2.4 **Installations.** When available, each Authorised User may install the desktop and mobile applications on devices they
personally use, up to 3 active devices at a time unless the Order Form states otherwise.

## 3. Seats and accounts

3.1 Seats are for named individuals and may not be shared. Credentials are personal. You are responsible for all
activity under your accounts and for keeping credentials secure. Tell us at once at security@arksa.space if you
think an account has been compromised.

3.2 You may reassign a Seat from one Authorised User to another when the original user no longer needs access
(for example, a change of role), but not more than once every 30 days per Seat, and not to rotate a Seat among
users to avoid buying more Seats.

3.3 Adding Seats during a term is charged pro rata. Seat reductions take effect at the next renewal.

3.4 Organisation owners and administrators control membership, roles and sharing within their organisation. You
are responsible for your Authorised Users' compliance with this Agreement.

## 4. Acceptable use

You must not, and must not allow anyone else to:

1. copy, modify or create derivative works of the Software except as this Agreement allows;
2. reverse engineer, decompile or disassemble the Software, except to the extent the law allows it despite this
   restriction;
3. remove, bypass or tamper with licence checks, Licence Files, usage metering, access controls or other technical
   protections;
4. rent, lease, resell, sublicense or provide the Software as a service to third parties, unless an Order Form
   permits it;
5. publish or share outside your organisation benchmark, performance or comparison results about the Software
   without our prior written consent;
6. misuse share links: send them to people who should not see what they share, post them publicly, or use them to
   get around Seat limits;
7. attack, probe, scan or test the security of the Services, overload them, or introduce malware, except under
   the security disclosure process on our trust page (security@arksa.space);
8. access the Services by automated means beyond the documented API and its rate limits, or access data that is
   not yours;
9. upload or share content that is unlawful, that you have no right to use, or that infringes anyone's rights;
10. use the Software in breach of law, including export-control and sanctions law (§10);
11. use the Software or our non-public materials to build a competing product.

We may suspend access for a breach of this section, as set out in §16.

## 5. Customer Data and Outputs

5.1 **You own your inputs and your Outputs.** Your Customer Data and your Outputs are yours. Third-Party Data in an
Output stays under its own terms (§7). The Software, its models and templates stay ours (§11).

5.2 **What we may do with them.** You grant us a limited licence to host, process, transmit and display your
Customer Data and Outputs only as needed to provide, secure and support the Services for you, and to comply with
the law, as described in the Privacy Policy (https://arksa.space/legal#privacy).

5.3 **No training on your data.** We do not use your data or outputs to train machine-learning models without your
explicit consent. We do not use them for any other purpose of our own either. Consent is an opt-in, in writing or
in the app, and you can withdraw it at any time.

5.4 **Service metrics.** We may use usage and performance metrics, aggregated so that they identify neither you
nor your Customer Data, to run and improve the Services.

5.5 **Sovereign.** On Sovereign your Customer Data stays on your own servers, apart from the licence,
reference-data and update checks listed in the Privacy Policy.

5.6 **Share links.** Anyone who has a share link can open what it shares until the link expires or is revoked.
Treat share links like the files themselves.

5.7 **Your responsibilities.** You are responsible for your Customer Data: for having the rights to it, for its
lawfulness, for classifying it under export-control law (§10), and for keeping your own copies of anything you
cannot afford to lose. You will not put classified information into the Services, or technical data controlled
under ITAR, unless an Order Form expressly allows it.

## 6. Decision support, not a safety system

6.1 Arksa is decision support, not a safety system. Its analyses, including conjunction screening,
collision-avoidance planning, re-entry and lifetime predictions, space-weather assessments and link and power
budgets, are engineering aids. You stay responsible for your mission and operational decisions. Verify anything
safety-critical independently, and never use Arksa as the sole basis for a safety-of-life or collision-avoidance
action.

6.2 Results depend on models, assumptions and input data, and are approximations. Arksa is not certified for
real-time operations or human-rated missions. A compliance pre-check is a pre-check, not a filing: it does not
replace the analyses, filings or approvals your mission needs.

6.3 Alerts and notifications are a convenience. They may be late or may not arrive, and you must not rely on them
as your only means of learning about a close approach or any other event.

## 7. Third-party data

7.1 Satellite catalogues, space-weather data and ephemerides come from third parties under their own terms. Arksa
passes them on with their credits and gives no warranty that they are accurate, complete or timely.

7.2 A third-party source may change, be late, contain errors, or stop. Some sources allow use only for our own
computations, so we show you our results and not the raw records; where you need raw records, you use your own
account with that source. You must keep the credits and follow the terms of any Third-Party Data you export.

## 8. Updates and support

8.1 We may provide updates, including automatic updates for the web app and, when available, the desktop and mobile
applications.
Some updates may be required to keep using the Services. We may change or remove features, but we will not
materially reduce the core functions of a paid Plan during a paid term.

8.2 Support levels are as stated for your Plan or Order Form. Support: contact@arksa.space.

## 9. Fees, renewal and cancellation

9.1 Fees are as stated in the plan catalogue or Order Form, exclusive of taxes. Subscriptions renew automatically
for the same term unless cancelled before renewal. Invoices are due within 14 days unless the Order Form says
otherwise. Late payments carry late-payment interest at the rate set by Estonian law. Invoices and
payment questions: contact@arksa.space.

9.2 On cancellation or non-payment, your account becomes read-only at the end of the paid term (or is suspended for
Sovereign): you can open and export Customer Data, but not edit, upload or use cloud compute. Usage limits are as
stated in your plan or Order Form. You can export your
Customer Data for 30 days after the end of a paid term. After that we delete it, as the Privacy Policy describes.

9.3 Except where the law requires or an Order Form states otherwise, fees are non-refundable.

## 10. Export control and sanctions

10.1 You comply with EU dual-use rules (Regulation (EU) 2021/821), EU sanctions and, where they apply, the US EAR
and ITAR, and you confirm you are not a sanctioned party. Arksa may suspend access where it must to comply.

10.2 In detail: space mission analysis software and its outputs can be subject to export-control laws, including
Regulation (EU) 2021/821 on dual-use items, the US Export Administration Regulations (EAR), the US International
Traffic in Arms Regulations (ITAR) and UK export-control law, and to EU and other sanctions. You will not export,
re-export, transfer or use the Software, Services or Outputs in breach of those laws.

10.3 You confirm that you, your Authorised Users and anyone who owns or controls you are not named on a sanctions
list that applies to us or to you, are not owned or controlled by anyone named on one, and are not located in a
country or region under comprehensive EU sanctions. You will tell us at once if that changes.

10.4 We screen accounts against sanctions lists. We may refuse, suspend or end access at once, without liability,
where we need to in order to comply with export-control or sanctions law.

## 11. Intellectual property, feedback and confidentiality

11.1 **Our rights.** Arksa keeps all rights in the platform: the Software, Services, models, documentation,
designs and all improvements to them, whoever suggested them. Third-party open-source components are licensed
under their own terms (see the third-party notices distributed with the Software). Nothing in this Agreement transfers ownership of our intellectual property
to you.

11.2 **Feedback.** If you send us feedback, you give us a perpetual, worldwide, royalty-free, irrevocable licence to
use it to improve Arksa, without owing you anything for it. This gives us no right to your Customer Data, your
Confidential Information or your name.

11.3 **Confidentiality.** Each party keeps the other's Confidential Information confidential, uses it only for this
Agreement and shares it only with its staff, advisers and subcontractors who need it for this Agreement and are
bound by the same duty. This does not cover information that is public, already known, independently developed or
that must be disclosed by law (with notice to the other party where the law allows). These duties last while this
Agreement runs and for 5 years after it ends, and for trade secrets as long as they remain trade secrets.

11.4 **Publicity.** We will not use your name or logo publicly without your written approval.

## 12. Data protection

12.1 The Privacy Policy (https://arksa.space/legal#privacy) says what personal data we process and why. We are the controller for
account, website and billing data.

12.2 For personal data inside the Customer Data of a business customer, we act as your processor. Our data
processing addendum under Article 28 GDPR (available on request) forms part of this Agreement for business
customers when you sign it or accept it in the app; ask at contact@arksa.space.

## 13. Warranties

13.1 **Paid Plans.** We warrant that the Software will perform materially as described in its documentation during
the subscription term. Your exclusive remedy for breach of this warranty is for us to fix the non-conformity or, if
we cannot within a reasonable time, to end the affected subscription and refund prepaid fees for the remaining
term.

13.2 **Otherwise**, and for access granted at no charge, the Software and Services are provided "as is" and "as
available". To the extent the law allows, we disclaim all other warranties, including merchantability, fitness for
a particular purpose, accuracy of results, uninterrupted or error-free operation and non-infringement. We give no
warranty for Third-Party Data (§7).

## 14. Limitation of liability

14.1 Our total liability is capped at the fees you paid in the 12 months before the claim (for a pilot, the pilot
fee). We are not liable for indirect or consequential loss, lost profits, loss of data beyond restoring it from
backups, or loss of a mission or spacecraft. These limits do not apply to intent or gross negligence, death or
personal injury, or anything else the law does not allow to be limited, and consumers keep their mandatory rights.

14.2 In detail: the cap and exclusions in 14.1 apply to each party, for all claims arising out of or in connection
with this Agreement together, in contract, delict (tort) or otherwise. Where no fees were paid, the cap is EUR 100. Neither
party is liable for indirect, incidental, special, consequential or punitive loss; for loss of profits, revenue,
business, goodwill or anticipated savings; for loss or corruption of data, beyond the cost of restoring it from our
most recent backup; or for loss of, or damage to, a mission, spacecraft, payload or launch.

14.3 The cap and exclusions do not apply to your payment obligations, to your indemnity (§15), to a breach of §4
(acceptable use), §10 (export control and sanctions) or §11.3 (confidentiality), or to liability that the law does
not allow to be limited, including liability for intent or gross negligence and for death or personal injury.

## 15. Your indemnity

15.1 You will defend and indemnify Ashforde OÜ against third-party claims, fines, penalties and reasonable costs
(including reasonable legal fees) arising from: (a) your or your Authorised Users' use of Arksa in breach of §4
(acceptable use); (b) a breach of export-control or sanctions law (§10) by you or your Authorised Users; or (c)
Customer Data or other content you upload or share that is unlawful or infringes anyone's rights.

15.2 We will tell you promptly about the claim, let you control its defence and settlement (you may not admit
fault for us without our consent), and help reasonably at your cost.

15.3 This section does not apply to consumers beyond what their mandatory law allows.

## 16. Suspension

16.1 We may suspend all or part of your access if: (a) you breach §4 or §10; (b) an invoice is more than 14 days
overdue after we have reminded you; (c) your use threatens the security, integrity or availability of the
Services or of other customers; or (d) the law or an authority requires it.

16.2 Where we can, we warn you first. We tell you why, limit the suspension to what is needed, and restore access
once the cause is fixed. Suspension does not end your obligation to pay for the term. You can still export your
Customer Data during a suspension unless the law or the cause of the suspension prevents it.

## 17. Changes to this Agreement

17.1 We may change this Agreement or the plan catalogue. We give at least 30 days' notice of a material change,
by email or in the app, before it takes effect. A change required by law or for security may take effect sooner.

17.2 For paid Plans, a material change that is adverse to you takes effect at your next renewal, unless the law
requires it sooner. Signed-in users accept the new version before they continue. If you do not accept a change,
you may end this Agreement before the change takes effect; for a paid Plan, we then refund prepaid fees for the
remaining term.

## 18. Term, termination and survival

18.1 This Agreement lasts while you use the Software or Services or hold a Plan. You may cancel at any time; a
cancellation takes effect at the end of the paid term.

18.2 Either party may end this Agreement for a material breach that is not cured within 30 days of written notice.
We may end it at once for a breach of §10, or where the law requires it.

18.3 On termination you must stop using the Software and delete copies, except as needed to export your Customer
Data under §9.2.

18.4 These sections survive termination: §4, §5.1, §5.3, §7, §9 (for amounts due), §10, §11, §12 (while we still
hold the data), §13.2, §14, §15, §18.4, §19 and §20.

## 19. Force majeure

Neither party is liable for a delay or failure caused by events beyond its reasonable control, such as natural
disasters, war, terrorism, epidemics, acts of authorities, failures of utilities, networks or third-party data
sources, or large-scale cyber attacks. This does not excuse payment obligations. If such an event lasts more than
60 days, either party may end the affected service by notice.

## 20. General

20.1 **Governing law and courts.** Estonian law governs, and the courts of Tallinn (Harju County Court) decide
disputes. If you are a consumer, you keep the protection of the mandatory law where you live and may also use your
local courts. Estonian conflict-of-law rules and the UN Convention on Contracts for the International Sale of
Goods do not apply.

20.2 **Mandatory law.** Nothing in this Agreement limits rights or liabilities that the law does not allow to be
limited.

20.3 **Consumers.** If you use the Software as a consumer, you keep any mandatory rights your local law gives you,
including your statutory rights where the Software does not conform.

20.4 **Assignment.** You may not assign or transfer this Agreement without our written consent, which we will not
withhold unreasonably for a merger or sale of your business. We may assign it to a company in our group or to a
successor to our business, with notice to you.

20.5 **Entire agreement.** This Agreement, any Order Form, the Privacy Policy and, for business customers, the data
processing addendum are the entire agreement on this subject and replace earlier discussions. If they conflict,
the Order Form prevails, then the data processing addendum on data protection, then this Agreement. Terms in your
purchase orders do not apply.

20.6 **Severability and waiver.** If a provision is unenforceable, the rest remains in effect, and the provision is
read as the closest enforceable one. Not enforcing a right is not a waiver of it.

20.7 **Notices.** To contact@arksa.space, and to the email address on your account or in your Order Form. Notices by
email are effective when sent, unless a delivery failure is reported.

20.8 **Language.** This Agreement is written in English. A translation is for convenience; the English text
governs.

**Contact:** Ashforde OÜ, Ahtri tn 12, 15551 Tallinn, Estonia · contact@arksa.space

# Arksa Privacy Policy
<!-- terms-version: 0.4 (not shown to readers, site re-audit A9) -->

**Last updated:** 2026-10-17

This policy explains what personal data **Ashforde OÜ**, registry code 17321180, Ahtri tn 12, 15551 Tallinn,
Estonia ("**Arksa**", "**we**") processes when you use the Arksa website, the studio and, when available, the desktop and mobile applications,
command-line tools and APIs, and the hosted Arksa services, and what your rights are.

## 1. The short version

- **One system of record.** Your organisation's missions live in one place: Arksa's cloud at general availability, or
  your own servers with Sovereign. During early access the studio keeps your working copy in browser storage (§3.1).
  With general availability the studio needs an account; during early access, invited members sign in with a
  one-time code.
- **Share links.** Anyone who has a share link can open what it shares until the link expires or is revoked.
  Treat share links like the files themselves.
- **We do not sell personal data, and we do not use advertising trackers.**
- **No training on your data.** We do not use your data or outputs to train machine-learning models without your
  explicit consent.
- With an account, we store what is needed to run it: your email, name, a password hash, sessions, organisation
  memberships, your cloud scenarios and an audit log.

## 2. Who is responsible

2.1 **Controller.** Ashforde OÜ is the controller for account, website, form, billing, security and support data.

2.2 **Processor.** For personal data inside the Customer Data that a business customer stores in Arksa (for
example names in mission files or documents), the customer is the controller and we act as its processor. We
process that data only on the customer's instructions, under the licence terms (EULA §12) and our data processing
addendum under Article 28 GDPR. Business customers can ask for the addendum at contact@arksa.space. Requests about
that data are best sent to the organisation; if you send them to us, we pass them on.

2.3 **Contact.** contact@arksa.space, or by post to Ashforde OÜ, Ahtri tn 12, 15551 Tallinn, Estonia.

## 3. What we process, and why

### 3.1 Early access and the website

| Data | Where it stays | Purpose |
|---|---|---|
| Working copy of your current mission, recent missions and preferences | Browser storage of the studio, during early access only | Restore your work and remember the tour |
| Requests to the website (IP address, user agent, time, path) | Our hosting and content-delivery provider | Delivering and protecting the site. We do not export or keep these logs |
| Visit statistics: page, referrer, browser, country; no cookies, no visitor identifier | Our hosting provider's web analytics | Aggregate page statistics; legitimate interest |
| Studio sign-in for invited early-access members: email, one-time code, a sign-in cookie (24 hours) | Our hosting provider's access-control service | Letting invited people into the studio; strictly necessary |

Public reference data (satellite catalogue, Earth orientation, space weather) and updates are served through
Arksa or, on Sovereign, your own server.

### 3.2 Website forms, the invitations list and error reports

| Data | Purpose | Legal basis | Kept for |
|---|---|---|---|
| Contact, demo, early-access, briefing, pilot and academic forms: name, email, organisation, message and answers, page, time, salted hash of the IP address (never the address) | Reply and follow up | Steps you ask for before a contract; legitimate interest | 24 months |
| Spam check: browser and connection signals, checked by our hosting provider's bot-protection service | Keep forms free of spam | Legitimate interest | Not stored by us |
| Invitations list: email; consent record (time, wording version, salted IP hash) | Send the invitations asked for | Consent (double opt-in); withdraw with the unsubscribe link | Until unsubscribe; unconfirmed 30 days; withdrawal record without the address 30 days |
| Error reports from the studio and failed form submissions: error, scrubbed message and stack, app version, page, salted IP hash | Find and fix faults | Legitimate interest | 90 days |

Stored in our hosting provider's database in Western Europe; emails sent through our transactional email provider (EU region); our mailboxes are with our email hosting provider (Switzerland).

### 3.3 With an account (Arksa cloud)

| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Email, display name, password hash (never the password itself) | Create and secure your account; sign-in | Contract |
| Date of birth at sign-up | A one-time age check; only the result is kept | Legitimate interest (keeping the service for adults) |
| Your declaration that you act for an organisation or in your profession | Confirm that Arksa is used as a business product | Contract |
| Sessions: token identifiers, IP address, user agent, timestamps | Keep you signed in; detect suspicious sign-ins; rate limiting | Contract; legitimate interest (security) |
| Organisations, memberships, roles, invitations (invitee email) | Teams, permissions, invitations | Contract |
| Cloud scenarios, versions, files and share links | Store, version and share your work | Contract |
| Licences and licence files (licence ID, plan, seats, expiry, device binding) | Entitlements, and on-site verification for air-gapped Sovereign | Contract |
| Acceptance of the licence terms and this policy (document, version, time, method, fingerprint of the IP address) | Show which terms you accepted | Legal obligation; legitimate interest (proving the contract) |
| Sanctions screening: name, organisation, country, and any list match | Comply with EU and other sanctions law | Legal obligation; legitimate interest |
| Audit log (actor, action, target, IP address, time) | Security, accountability, customer admin reporting | Legitimate interest; contract (for organisation admins) |
| Usage metering (missions, storage, compute minutes, API calls) | Plan limits and billing | Contract |
| Billing, once online payments open: customer and subscription identifiers, plan, status, invoices | Payments and invoicing | Contract; legal obligation (accounting and tax records) |
| Support messages | Answer you | Contract; legitimate interest |

Customer provider logins (e.g. Space-Track) are sealed at rest, write-only, shown only as a masked identity that keeps the e-mail domain, and deleted with the organisation.

**Encrypted vault (optional).** If you enable end-to-end encrypted sync, we store only ciphertext and the
metadata needed to sync it (sizes, timestamps, device identifiers). We cannot read vault contents.

We make no decisions about you based solely on automated processing that have legal or similarly significant
effects. A sanctions match that is not clear-cut goes to a person to decide.

### 3.4 Cookies and similar technologies

The website sets no cookies. The studio sign-in for early-access members uses one strictly necessary cookie, set
by our hosting provider's access-control service, that keeps an invited member signed in for 24 hours; the Arksa
cloud uses one strictly necessary session cookie that keeps you signed in. Browser storage is described in §3.1.
Our visit statistics are cookieless. We do not use advertising or cross-site tracking cookies, so there is no cookie
banner.

## 4. Who processes data for us, and sharing

4.1 **Service providers (subprocessors)**, under contract and on our instructions:

| Provider (category) | What it does for us | Where |
|---|---|---|
| Hosting and content-delivery provider (a US company) | Hosting, the studio sign-in, the forms spam check, visit statistics, and the database for forms and error reports | Global network; database in Western Europe |
| Transactional email provider | Transactional email | EU region |
| Email hosting provider | Our mailboxes | Switzerland |

These are the providers in use today. When the hosted Arksa cloud and online payments open, their providers will be
listed here at least 30 days before they process customer data. We give business customers at least 30 days' notice before we add or replace a subprocessor that
processes their Customer Data, so they can object. The categories are listed on https://arksa.space/legal#privacy;
business customers receive the named list of subprocessors with the data processing addendum, and anyone can ask
for it at contact@arksa.space.

4.2 **Your organisation.** If you join an organisation, its owners and administrators can see your name, email,
role, activity in the audit log, and the scenarios shared with the organisation.

4.3 **People you share with.** Anyone with a share link you create.

4.4 **Authorities**, where the law requires it, and **successors** in a merger or acquisition, under this policy.

## 5. Regions and international transfers

Your organisation's data is held in the EU.
Sovereign customers run Arksa on their own servers, and their mission data does not come to us. The
public website, its forms and visit statistics run on our hosting provider's global network (§3.1, §3.2).

Some providers process data outside the EU/EEA. Switzerland has an EU adequacy decision. For transfers to the US
we rely on the EU-US Data Privacy Framework where the recipient is certified, and otherwise on the European
Commission's Standard Contractual Clauses (with the UK Addendum for UK data), with extra safeguards where they are
needed. You can ask contact@arksa.space for a copy of the safeguards.

## 6. Retention

| Data | Kept for |
|---|---|
| Account data | While the account exists; deleted within 30 days of account deletion |
| Sessions | Until sign-out or expiry, then deleted |
| Cloud scenarios and versions | Until you or your organisation delete them; backups roll off within 35 days |
| Exports after a paid term ends | 30 days, then deleted |
| Audit log | 12 months, or longer where a contract requires it |
| Terms acceptances | While the account exists, then as long as needed to establish or defend legal claims |
| Sanctions screening records | 5 years |
| Billing records | 7 years, as Estonian accounting law requires |
| Form submissions | 24 months |
| Invitations list | Until unsubscribe (unconfirmed sign-ups 30 days) |
| Error reports | 90 days |

## 7. Security and breaches

7.1 Passwords are stored as salted, memory-hard hashes. Sessions use secure, HTTP-only cookies or bearer tokens.
Traffic is encrypted in transit (TLS). Access to production data is restricted and logged. Licence files are
signed with Ed25519. When available, the desktop app runs the studio in a sandboxed, context-isolated renderer with a strict
Content Security Policy.

7.2 If a personal data breach puts people's rights at risk, we notify the Estonian Data Protection Inspectorate
(Andmekaitse Inspektsioon) within 72 hours of becoming aware of it, and tell affected business customers without
undue delay. If a breach is likely to result in a high risk to you, we also tell you directly, without undue delay.
Report a suspected breach or vulnerability to security@arksa.space.

## 8. Your rights

8.1 Under the GDPR (and, where they apply to you, the UK GDPR or California's CCPA/CPRA) you can ask to access,
correct, export, delete or restrict the processing of your personal data, and object to processing based on
legitimate interests. Where we rely on consent, you can withdraw it at any time; this does not affect processing
before the withdrawal.

8.2 You can export your data from the app's Privacy Center. For anything else, including deleting your account,
write to contact@arksa.space. We answer within one month (extendable by two months for complex requests, in which
case we tell you why). We may ask you to confirm your identity first.

8.3 If your account belongs to an organisation, requests about organisation content may be referred to that
organisation as controller (§2.2).

8.4 You may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, Tatari 39, 10134
Tallinn, www.aki.ee), or to the data-protection authority where you live or work (in the UK, the ICO). We would
like the chance to help first, at contact@arksa.space.

## 9. Children

Arksa is not directed at children under 16, and we do not knowingly collect their personal data. Education
programmes run through schools or universities are covered by agreements with those institutions.

## 10. Changes

We post changes here and update the date above. We notify material changes in the app or by email at least 30
days before they take effect, unless the law requires a change sooner. Signed-in users accept the new version
before they continue.

## 11. Contact

Ashforde OÜ, Ahtri tn 12, 15551 Tallinn, Estonia · Data protection and GDPR requests, contracts and the data
processing addendum: contact@arksa.space · Security: security@arksa.space. Ashforde OÜ is established in the EU, so it needs no EU representative. A UK
representative is named where UK law requires one.