Privacy Policy

Last updated: 2026-01-16
Effective: 2026-01-16

INTRODUCTION
‍We at Dimension 5 PTE. LTD. (hereinafter referred to as “D5”, “we” or “us”) attach great importance to the protection of your privacy and personal data. This privacy policy (“Privacy Policy”) explains to you how we collect, use, save, share, transfer or otherwise process your personal data, and your rights regarding your use of the products and services of D5, including but not limited to D5 Render, D5 Official Website, D5 Forum, D5 Works, D5 Launcher and D5 Lite (hereinafter referred to as “Products” or “Services” collectively).
‍If you are a California resident, please refer to “California Specific Terms” section.
If you live in the European Economic Area (“EEA”), please refer to the “EEA Specific Terms” section.

1. WHAT INFORMATION WE COLLECT FROM YOU
To provide D5 products and services, ensure the secure and stable operation of our systems, and support account management and commercial features, we collect personal data in accordance with the principle of data minimization. The types of personal data we collect are described below.

A. Personal Data You Provide
‍
‍1.Registration for a D5id and Log-in Information
‍When you use our Products or Services, we may advise you to sign up for a D5id so that you can make full use of our Products, our Services and all their features. You may provide certain personal data, including country/region you reside, e-mail address, the profile photo that you choose or upload and create a password, nickname, to ensure the correspondence and recognizability of the account you created. We collect this information to create and manage your account, enable authentication and communication, and protect account security. When creating an account and logging in the account to set up your profile, to provide you with a more personalized service to enhance your experience in using our products, we may ask you to provide personal data, including your organization, job title, specific industries and workflow you use, the way you learn about D5. If you choose to log in via single sign-on (SSO), such as through Microsoft or other third-party platforms, we may verify your account credentials through those platforms. The relevant third-party service providers will return authentication results to us for login verification purposes.

If you are registering an Enterprise/Teams account, you may be required to provide additional information, such as your email address, company name, and the name and mobile phone number of the account administrator or authorized contact person. We collect such information to set up and manage Enterprise/Team accounts and ensure account security.

We automatically assign you a device ID when you install our Products and a user ID when you log into your D5id. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.

Please note that accounts used across the D5 product ecosystem (including D5 Render, D5 Launcher, D5 Lite, D5 works and other D5 products) are based on a unified account system. Once you register a D5 account, you may use the same account to access other D5 products.

2.Account Binding and Settings
‍After logging in, you may update or manage your security settings through your account profile. We may collect information such as your login credentials, SMS verification codes, and bound email address or Google account (if applicable). This information is collected to safeguard your account security. Failure to provide such information may affect certain security-related functions but will not prevent you from using basic product features.You may also voluntarily provide or update additional profile information, including your industry field (such as architecture, landscape, interior design, exhibition, lighting, advertising, film, gaming, urban planning, or others), commonly used workflows (e.g., SketchUp, Revit, 3ds Max, Rhino, Blender, Cinema 4D, Vectorworks), years of experience, professional role, company or organization name, and commonly used renderers. This information helps us better understand user needs and provide more tailored services and product experiences. Providing such information is optional and does not affect your ability to use basic services.

‍3. Identity and Education Eligibility
‍When you apply for an Education License, we may collect certain information necessary to verify your eligibility, including your real name, school or institution name, major or field of study, and supporting documents demonstrating your current enrollment status (such as a student ID, enrollment certificate, or other equivalent proof).

We collect and process the above information solely for the purpose of verifying your eligibility for Education License benefits. If you choose not to provide the required information or documentation, you may be unable to complete the verification process or access student-specific benefits; however, your ability to use other D5 products and services will not be affected.

‍4. Team Seat Management
‍If you are a Teams or Enterprise user and use team seat management features, we may collect information relating to organization members, including nicknames, profile picture, phone numbers, email addresses, department information, account activation and expiration dates, and usage behavior data (such as login or feature usage frequency). We collect this information to enable team management functions. You may also choose to set your company name and logo, which we will collect accordingly. If you do not provide such information, certain team management features may not be available, but other services remain unaffected.

5. Post Content
When you post certain content on the forum (the “D5 Render Forum”), you may provide certain personal data, including text, image, video, uploaded programs, logs, datasets/files.

‍6. Customer Support, Complaints, and Technical Assistance
‍When you submit inquiries, complaints, or requests relating to our Products or Services, you may provide personal data such as your email address, identity information, and related supporting materials. When submitting infringement notices, you may also be required to provide identification documents, authorization materials, and contact details. Failure to provide required information may prevent us from processing certain requests, but will not affect your use of other services.

In the course of providing customer support or technical assistance, you may voluntarily submit or upload content related to your workflow or usage of our Products, including text, images, videos, uploaded programs, logs, datasets, files, or other materials, for the purpose of issue reporting, troubleshooting, diagnosis, or service improvement.

We may collect and process such information, together with communication records, account information, contact details, and supporting materials you provide, solely to respond to your requests, resolve technical or service-related issues, maintain support records, and improve the stability, security, and reliability of our Products and Services.

‍7. AI-Related Features
‍When you use AI-powered features (such as AI Enhancer or AI image generation), we may collect images you upload, keywords or prompts you provide (including style models, descriptions, or generation modes), and related interaction data. This information is collected solely to provide AI-related services. If you do not provide such information, you may be unable to use certain AI features, but other Product functionalities will remain available.

When you use AI Q&A features, we may collect and analyze keywords or questions you submit to help respond to your inquiries related to the use of D5 Products.

We do not use your AI interaction content (such as your prompts, questions, chat inputs, or outputs generated for you) to train or improve our general-purpose AI models by default. If we intend to use such content for AI model training or improvement in the future (for example, to enhance the model’s understanding and response quality), we will obtain your prior authorization/consent where required by applicable law, and we will provide you with a clear and easy way to withdraw your consent or opt out at any time. Your withdrawal will not affect the lawfulness of processing based on your consent before it was withdrawn.

Where we use AI interaction content for product safety, security, debugging, or quality assurance (e.g., to investigate abuse, fraud, or technical issues), we will do so in a proportionate manner and subject to appropriate safeguards.

8. Questionnaire.
When you choose to fill out our questionnaires, you may provide certain personal data, including Name, email address, mobile phone number, organization, job title, specific industries, country/region for us to conduct data analysis.

‍9. Contact Us for Teams/Enterprise.
When you Contact Us for Teams/Enterprise, you may provide certain personal data, including name, phone number, email address, company & job title, location (country/region), industry, inquiry, other information you would like to provide.


B. Personal Data We Automatically Collect

‍1. Technical Information.
When you use our Products or Services, we may automatically collect personal data including device information, computer name and hardware specification, operation system, network configuration, IP Address and other software information, as well as some of the product usage information, including your device identifier, hardware serial number and MAC address.

A device ID may be assigned when you install our Products, and a user ID may be assigned when you log in to your D5id. These identifiers help us ensure security, prevent fraud, and provide seamless cross-device experiences.

‍2. Usage Data
When you use our Products or Services, we may automatically collect personal data about your use of our Products or Services, including the number of uses of specific functions.

‍3. Cookies
The Products or Services uses cookies or similar technologies, which will collect information about your use of our Products or Services, such as the application used, the site visited, and how to interact with the content provided through the service. Please check “COOKIES AND SIMILAR TECHNOLOGIES” section for further details.

‍4. Search Functions
‍When you use search features, we may collect search queries and related interaction data to provide search results and improve functionality. If you do not agree to such collection, certain search features may not be available.

5. Orders and Payments
‍When you place an order or make a payment through D5 products or services, we may collect and process information related to your order and transaction, including order details, transaction status, and service entitlement information.

Payments are processed through third-party payment service providers (such as PayPal, Stripe, WeChat Pay, Alipay, banks, or other local payment partners, depending on your region). These payment service providers may independently collect and process your payment information (such as payment instrument details) in accordance with their own privacy policies. We do not store your full payment instrument details.

We may receive certain payment-related information from these payment service providers, such as payer identifiers, payment confirmation, transaction reference numbers, and payment status, for the purposes of processing your payment, providing the services, protecting against fraud, ensuring transaction security, and handling disputes or refunds.

During the checkout process, we may also collect billing information that you provide, such as your billing address and related contact details. Where you request an invoice, we may further collect invoicing information, including invoice title, billing address, tax identification number (e.g., VAT ID, where applicable), and other information required to issue invoices or comply with applicable tax, accounting, and regulatory obligations.

We process the above information for the purposes of fulfilling our contractual obligations to you, complying with applicable legal and financial obligations, maintaining accurate records, and providing customer support. Where required by law, such information may be retained for statutory retention periods.

‍6. Experience Points, Credits, and Certification Records
‍When you participate in activities, we may collect records related to your participation, experience points, credits, redemption records, and interaction behavior to enable free or discounted services. When you use certification or capability assessment services, we may collect information relating to assessment results, certification records, and issued certificates to provide certification services and related features.


C. Personal Data We May Receive from Third Parties
‍We may collect or receive personal data about you from third parties when you use a third-party account to log in to D5 products. After you register or log in with a third-party account, your third-party account will be linked to D5id, you may cancel your linked account. This information includes:

Please note: the exact categories of data we receive depend on the third party, its policies, and the permissions you grant.

D. Combination of Data
We may combine personal data from different sources (including Personal Data You Provide, Personal Data We Automatically Collect, and Personal Data We May Receive from Third Parties) where this is necessary to: (i) provide and secure the Products or Services (such as account management, fraud prevention, security monitoring, and service entitlement), (ii) maintain and improve the Products or Services (such as troubleshooting, performance analysis, and feature improvements), and (iii) comply with legal obligations.

Where combining data is used for marketing communications, targeted advertising, or user profiling beyond what is necessary to provide the Products or Services, we will do so only where permitted by law and, where required, based on your consent or with a clear opt-out mechanism. Your choice regarding marketing or profiling will not affect your access to core product functionalities.

It may be that providing certain personal data to us is a statutory or contractual requirements, a requirement necessary to enter a contract, or that you are otherwise obliged to provide the data to us. If that is the case, we will inform you thereof separately, and will also explain the possible consequences if you fail to provide such personal data to us.

2. USE OF YOUR PERSONAL DATA
‍We collect and use your personal data for the following purposes:

3. SHARING, TRANSFERRING AND DISCLOSING INFORMATION
Other than consented by you, we commit that we will not share or sell your personal data to any third party. In addition to the information disclosed in the “COOKIES AND SIMILAR TECHNOLOGIES” section, we may share information with the following third parties:

Additional Clarification on Advertising/Marketing Partners.

Where permitted by law, we may share limited identifiers (such as hashed email addresses) with advertising partners to measure campaign performance, create audience segments, or deliver relevant ads. Where required by applicable law (including in the EEA/UK), we will do so only with your prior consent (for example via cookie/advertising preferences) and you may withdraw your consent at any time.

You can manage your marketing and advertising preferences through the settings or mechanisms provided in our Products/Services (where available), by using cookie preference controls (where applicable), or by contacting us as described in the “CONTACT US” section.

Depending on where you are and which product you asked for, we may share your personal data with our affiliates so that we can response to your request, provide our services in a consistent manner or for other purposes in this Privacy Policy. You can obtain the identity and contact details on our affiliates with who we share your personal data by contacting us using the details in the “CONTACT US” section.

We will not disclose or transfer your personal data to any non-affiliated third parties, unless:

‍Legal Reasons
‍We will share personal data if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to (i) meet any applicable law, regulation, legal process/procedure, lawsuit or enforceable governmental request, (ii) protect and defend our rights or property, (iii) prevent fraud or criminal activity, (iv) respond under urgent circumstances to protect the personal safety of any entity, person or group, or (v) to avoid or mitigate against legal liability.

‍Business Transfers
‍If D5 is involved in a reorganization, merger, acquisition, sales of assets or liquidation, we will continue to ensure the confidentiality of your personal data and inform you that your personal data will be transferred or become subject to a different Privacy Policy in advance.
‍

4. COOKIES AND SIMILAR TECHNOLOGIES
‍We use technology such as cookies and other technologies to collect information and store your online preferences.

‍Cookies
‍A cookie is a very small text document, which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server. Find out more about the use of cookies on www.allaboutcookies.org .

Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.

‍Local storage technology
‍We and some third parties may use other local storage technology types associated with our Products or Services, such as local shared objects (also known as “Flash cookies”) and HTML5 local storage. These techniques are similar to the cookies described above because they are stored in your device and can be used to store certain information about your activities and preferences. However, the devices used by these technologies may differ from standard cookies, so you may not be able to use standard browser tools and settings to control them.

We use (i) strictly necessary cookies and similar technologies to operate our Products/Services (for example, to maintain login sessions and security), and (ii) optional cookies/technologies (such as analytics and advertising cookies) that help us understand usage and improve marketing effectiveness.

Where required by law (including in the EEA/UK), optional cookies/technologies will be enabled only after you provide your consent via the cookie preference controls presented to you. You can withdraw your consent at any time through those controls or other available settings.

We use Cookies on our Products or Services as described below:

cookie type

5. PROTECTING INFORMATION
Security Measures
‍We use a variety of organizational and technical security measures, including encryption and authentication tools, to protect your personal data. We use secure servers when you use our Products or Services.

For privacy protection reasons, we kindly request you do not disclose certain personal data, such as passwords, credit card numbers or PINs or other confidential data during your use of D5 Products or Services. Our commitment to safeguarding your privacy is unwavering, but the security of personal data also relies on safe user practices.

‍Data Transfers
‍We may maintain servers around the world and your personal data may be processed on servers located outside of the country where you live.

Regardless of where your personal data is processed, we apply the same protections described in this policy. We will also keep this Privacy Policy in compliance with significant legal frameworks relating to the transfer of data. If we receive your complaints about data transfers, we will cooperate with appropriate regulatory authorities when we cannot directly resolve it. Some of our recipients of your personal data are located in countries that may not – by law – provide the same level of data protection as you are used to in certain countries. If that is the case, we will ensure that adequate safeguards are in place to duly protect your personal data and we guarantee that we are able to and have mechanisms in place to respect the level of data protection required by EU/US data protection laws and that we shall refrain from processing personal data in the event of a breach of the concluded safeguarding measures or if we (or our recipients) are no longer able to honor them.

For transfers of personal data from EEA to a third country, please refer to our “EEA SPECIFIC TERMS” section below.
‍

6. MINOR’S POLICY
‍We do not knowingly collect or solicit personal data from children. Our Products/Services are intended for users who are at or above the age of digital consent in their jurisdiction. If you are under the age of digital consent (or under the minimum age required by applicable law), you must obtain permission from your parent or legal guardian before using our Products/Services. If we become aware that we have collected personal data from a child without valid consent where required, we will take reasonable steps to delete such information. If you believe a child has provided personal data to us, please contact us via support@d5techs.com. 

7. APPLICATION
‍This Privacy Policy applies to all the Products or Services provided by D5.

To better enrich your experience, our Service may contain links to other websites not operated or controlled by D5 (including our affiliates), including payment services (such as Stripe, Paypal, Airwallex), social media platforms (such as Facebook and YouTube) and the home page of third-party distributers. You can choose whether to access such content or links, or whether to use the third party’s products or services. However, we do not have control over the products or services provided by third parties. We cannot control any of your personal data held by third parties. By providing these links we do not imply that we endorse or have reviewed these third-party services. The personal data protection issues in connection with your use of any third-party services are not governed by this Privacy Policy. We strongly advise you to review the privacy policy of every site you visit.

If provisions from this Privacy Policy are in conflict with the law, they will be replaced by provisions of the same purport that reflects the original intention of the provision, all this to the extent legally permissible. In that case, the remaining provisions remain applicable unchanged.

8. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
You are entitled to the following rights:
a)  right of access to your personal data;
b)  right to data portability (i.e., you have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller);
c)  right to correction if your personal data is not complete or accurate (you are responsible for the truthfulness, accuracy, legality, validity and completeness of the information you provide, and update and maintain your personal data in a timely manner to ensure the truthfulness, accuracy and validity of the information);
d)  right to deletion or restriction of your personal data, as permitted by law (in some cases, we retain data for limited periods when it needs to be kept for legitimate business or legal purposes or to be protected from accidental or malicious deletion, there may be delays between when you delete something and when copies are deleted from our active and backup systems);
e)  right to object (i.e., objecting to our processing of your personal data) (e.g., in case we process your data for direct marketing purposes), as permitted by law;
f)  right to withdraw your consent where we have asked for your consent at any time with future effect and without affecting the lawfulness of processing of your personal data based on the consent you provided before you withdrew it.

The exercise of the abovementioned rights is free of charge and can be carried out via the contact details in the “CONTACT US” section. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we will either charge you a reasonable fee or refuse to comply with the request. We may request specific information from you to help us confirm your identity before we comply with a request from you concerning one of your rights.

We will provide you with information about the follow-up to the request without undue delay and in principle within one month of receipt of the request. The applicable privacy legislation may allow or require us to refuse your request. If we cannot comply with your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

These rights are not absolute, they may be limited in some situations. For example, where we can demonstrate that we have a legal requirement to process your data or if making the information available to you would reveal personal data about another person or if we are legally prevented from disclosing such information. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

We hope that we can satisfy any queries you may have about the way we process your data. In the event you still have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority, in particular to the data protection authority in the country of your habitual residence or place of work. 

‍Your California Privacy Rights
‍If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please refer to “CALIFORNIA SPECIFIC TERMS: PRIVACY DISCLOSURES” section below.

9. MARKETING
‍If we are legally required to do so, we will seek your prior consent before providing you with promotional materials or information. You may withdraw your consent at any time (this will not affect the processing of your personal data undertaken until the withdrawal). If you want to stop receiving promotional materials, etc., you can do so at any time by communicating with us.Where you have the right to object to marketing (including under GDPR/EEA rules), you may object at any time and we will stop processing your personal data for such purposes. 

10. DATA RETENTION
‍We will retain your personal data for as long as is necessary to carry out the purposes set out herein. We will also retain your personal data deemed necessary to comply with legal obligations, settle disputes, and enforce agreements.We will store data about your visit and use of the Products or Services and for the secure provision and use of the Services when you use the Products or Services. Your personal data will be deleted within 1 month of your account being cancelled. Where applicable, we will delete your personal data upon your request. Please note that certain data may be retained for longer periods where required or permitted by law (for example, tax, accounting, anti-fraud, security logging, and dispute resolution), or where necessary to establish, exercise, or defend legal claims.If you wish to obtain further information about the retention periods as applied to your personal data, you may contact us via the contact details in the “CONTACT US” section. 

11. CHANGES TO THE PRIVACY POLICY
‍We reserve the right to amend this Privacy Policy at our discretion and at any time, to reflect changes in legal, regulatory, operational requirements, our practices, and other factors. When we make changes to this Privacy Policy, we will post the updated notice by pop-up window, push and so on within our Products or Services, and update the notice’s effective date.Your continued use of the Products or Services following the posting of changes constitutes your acceptance of such changes. Please check these policies periodically for the latest updates. 
‍

12. CONTACT US
‍The data controller for your personal data will be D5. If you have questions, comments, suggestions or complaints about this Privacy Policy or wish to contact us for any reason in relation to our personal data processing, please send an email to Privacy Team’s email address at support@d5techs.com or by writing to 60 PAYA LEBAR ROAD #13-04 PAYA LEBAR SQUARE SINGAPORE 409051.

EEA SPECIFIC TERMS
In addition to our Privacy Policy presented above, the following terms will apply to the processing of Personal Data of data subjects in the European Economic Area (“EEA”).  

1. LEGAL BASIS OF GDPR FOR PROCESSING YOUR PERSONAL DATA
We process this personal data for the following purposes and based on the following legal grounds:
1.0 Contract necessity (GDPR Art. 6(1)(b)). We process certain personal data where it is necessary to perform a contract with you or to take steps at your request before entering into a contract (for example, to create and administer your account, provide purchased services, process transactions, and deliver core functionalities).

1.1 On the basis of our legitimate interests for example when required by us to conduct our business, in particular:
o we will use your information to identify you and provide you with a consistent service experience throughout our Products or Services;
o we will use your information to respond to any comments or complaints you may send us;o we use your information to help us maintain, improve and optimize our Products or Services;
o we use personal to provide personalized display service;
o we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); ando we will notify you about changes to our Products or Services, where applicable.

1.2 On the basis of your consent:
o providing you with information relating to D5 or promotional materials that may be of interest to you, as well as marketing mailings (electronic or otherwise) or other communications;
o we place cookies and use similar technologies in accordance with the “Cookies and Similar Technologies” section of the Privacy Policy and the information provided to you when those technologies are used; and
o on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

1.3 Legal obligation (GDPR Art. 6(1)(c)). In some cases we process personal data to comply with legal obligations (for example, tax/accounting obligations, responding to lawful requests, and certain compliance requirements).
‍

1.3 As this might be necessary for compliance with a legal obligation that is applicable to us, such as: in response to requests by government or law enforcement authorities conducting an investigation, or to comply with the requirements imposed by applicable law or any court order.

Aggregated Personal Data refers to data that has been carefully de-identified and anonymized to ensure that it cannot be linked back to any specific individual. We may aggregate Personal Data or collect aggregated data from our users, which is essential for enhancing the functionality and performance of our Products or Services. This enables us to analyze user behavior, improve our product's features, develop new products and services, conduct research, and other similar purposes. We use this information to gain insights into overall usage patterns and trends, helping us make data-driven decisions to enhance the user experience. In some cases, we may also choose to share or publish this aggregated information.

In addition, from time to time, we may share or publish aggregated information like general user statistics with third parties. We collect this information through the Products or Services, through cookies, and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form, and we will not attempt to re-identify the information, unless required by law.

We are committed to adhering to relevant privacy and data protection regulations and our Privacy Policy in all our data aggregation activities. If you have any questions or concerns regarding data aggregation, please read our full Privacy Policy for more details on how we handle and safeguard your information. Your privacy and security are our top priorities.

2. TRANSFER OF PERSONAL DATA OUTSIDE OF THE EEA
‍In situations where we transfer your personal data outside the EEA to a third country which may not be subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the applicable laws. We use the European Commission-approved Standard Contractual Clauses, a vendor’s Processor Binding Corporate Rules or other data transfer mechanisms available under applicable data protection laws, and further (organisational/contractual/technical) supplementary measures where necessary to ensure the effectiveness of the transfer mechanisms.

Where we transfer your personal data from EEA to other entities in Canda, the United States and China, we use the European Commission approved Standard Contractual Clauses. A copy of the relevant mechanism can be obtained for your review on request via the contact details displayed in the “CONTACT US” section.

CALIFORNIA SPECIFIC TERMS: PRIVACY DISCLOSURES

‍If you are a California resident, the following additional privacy disclosures under the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws may be applicable to you and allow you to exercise your rights regarding your personal information. 
‍
1. INTRODUCTION
‍If the CCPA is applicable, you have the right to know and understand how we collect, use, disclose, and share your personal information, to access your information, to request that we delete specific information and also not be discriminated against when exercising your privacy rights granted under the CCPA.As amended by the California Privacy Rights Act (“CPRA”), these rights also include the right to opt out of the “sale” or “sharing” of personal information, the right to limit the use and disclosure of sensitive personal information (where applicable), and additional transparency rights. 

2. CATEGORIES OF INFORMATION WE MAY COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly, or indirectly, with a particular consumer, household, or device (“personal information”). We may have collected the following categories of personal information from users within the last twelve (12) months:

A. Identifiers: real name, online identifier device ID, user ID, email address, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, nickname cell phone number, and other personal information details that may overlap with other categories.
C. Commercial information, including your payment card information, items/subscriptions you purchased and browsing history.
D. Internet or other electronic network activity information, such as the usage data we receive when you access or use our Products or Services. This includes information about your interactions within the Products or Services including your device identifier, hardware serial number，IP Address and MAC address, and about the devices and computers you use to access the Products or Services, as well as browsing history, and inquiry interactions device information, computer name and hardware specification, operation system, network configuration and other software information, as well as some of the product usage information, data collected by cookies about your use of our Products or Services, such as the application used, the site visited, and how to interact with the content provided through the service. Please check “COOKIES AND SIMILAR TECHNOLOGIES” section for further details.
E. Geolocation data, including country/region you reside.
F. Professional or employment-related information, including organization, job title, specific industries and workflow you use.
G. Education Information under California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99) Information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). Includes  financial information (image, video, the profile photo that you choose may involve).
H. Inferences that can be drawn from any of the above categories, including a person’s preferences, the way you learn about D5.
I. Post Content, including text, image, video, uploaded programs, logs, datasets/files.

As amended by the California Privacy Rights Act (“CPRA”), these rights also include the right to opt out of the “sale” or “sharing” of personal information, the right to limit the use and disclosure of sensitive personal information (where applicable), and additional transparency rights. 

We obtain the categories of personal information listed above from the following categories of sources:
1 Information and data directly provided by you on the Products or Services.
2 Information and data indirectly from you through the Products or Services.

Personal information does not include:
1 Publicly available information from government records.
2 Deidentified or aggregated consumer information
3 Information excluded from the CCPA’s scope, like health or medical information covered by HIPAA, clinical trial data, or other qualifying research data; and personal information covered by certain sector-specific privacy laws, including the FCRA, GLBA, or FIPA, and the Driver’s Privacy Protection Act of 1994.

To better understand how we collect your information, please review the general terms of the Privacy Policy.

3. PERSONAL INFORMATION WE MAY USE OR DISCLOSE
We may use, disclose the personal information we collect for one or more of the following business purposes:
1 To provide you with the Products or Services or otherwise fulfil or meet the reason for which you provided the information.
2 To provide you with support and to respond to your inquiries, including to investigate user reported issues and address your concerns.
3 To provide, support, personalize, improve, analyze, and develop our Products or Services for user experience and operational stability.
4 To personalize user experience and, where permitted by law, to deliver marketing communications or advertising, including interest-based or targeted advertising, subject to your rights to opt out of the sale or sharing of personal information.
5 To notify you about changes to our services or this policy, where applicable.
6 To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
7 To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
8 To help maintain the safety, security, and integrity of the Products or Services, our databases and other technology assets, and business.
9 To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
10 As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To better understand how we use and disclose your information, please review the general terms of the Privacy Policy presented above. 

4. PERSONAL INFORMATION THAT WE MAY SHARE
‍We may share your personal information by disclosing it to third parties for business purposes. We only make these business purpose disclosures under written contracts that describe the specific business purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the obligations under the contract.

As stated in the general terms of the Privacy Policy, we do not sell personal information for monetary consideration. However, under California law, certain disclosures of personal information for cross-context behavioral advertising or audience measurement may be considered a “sale” or “sharing” of personal information.

We do not knowingly collect personal information from individuals under age 16; and therefore, our personal information sales do not include information about individuals we know are under age 16.

In the preceding twelve (12) months, D5 has shared the following categories of personal information to the following categories of third parties:

“Sharing” refers to disclosure of personal information for cross-context behavioral advertising, as defined under the CPRA. We do not sell personal information for monetary consideration.

To better understand how we share your information, please review the general terms of the Privacy Policy presented above.

5. YOUR RIGHTS AND CHOICES
Right to Know and Data Portability
‍The CCPA provides California residents specific rights to know about our collection and use of their personal information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:
1 The categories of personal information we collected about you.
2 The categories of sources for the personal information we collected about you.
3 Our business or commercial purpose for collecting or selling (if applicable) that personal information.
4 The categories of third parties with whom we share that personal information.
5 If we sold or disclosed (if applicable) your personal information for a business purpose, we will provide two separate lists that:o identify the personal information categories that each category of recipient purchased in connection with sales of your personal information; and o identify the personal information categories that each category of recipient obtained in connection with disclosures of your personal information for a business purpose.
6 The specific pieces of personal information we collected about you (also called a data portability request). 
‍
Right to Delete
‍The CCPA provides California residents specific rights to delete their personal information that we collected from them and retained, subject to certain exceptions (the “right to delete”). We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1 Provide service that you requested from the Products or Services, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2 Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3 Debug the Products or Services to identify and repair errors that impair existing intended functionality.
4 Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5 Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6 Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7 Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8 Comply with a legal obligation.
Once we receive your request and confirm your identity, we will delete or deidentify personal information and direct our service providers to take similar action, unless subject to one of these exceptions above. 

How to Exercise the Rights to Know or Delete
‍To exercise your rights to know or delete described above, please submit a request via the contact details displayed in the “CONTACT US” section.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

1 Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: your identification information, a signed permission authorizing the representative to submit the request on your behalf, and any other information permitted or recommended by the CCPA and applicable regulations.

2 Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in the request to verify the requestor's identity or authority to make the request.  

Response Timing and Format regarding Requests to Know or Delete
‍We will confirm receipt of your request within fifteen (15) business days. If you do not receive confirmation within the fifteen (15) business days timeframe, please contact us via the contact details displayed in the “CONTACT US” section.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We may deliver our written response by email.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded, or as otherwise permitted by the CCPA. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  

‍Personal Information Sales and Sharing Opt-Out Rights
‍Under the CCPA/CPRA, California residents have the right to opt out of the “sale” or “sharing” of their personal information.

As stated in the general terms of our Privacy Policy, we do not sell personal information for monetary consideration. However, we may “share” personal information for cross-context behavioral advertising purposes. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise your right to opt-out of the sale or sharing of personal information, you (or your authorized representative) may submit a request to us via the contact details displayed in the “CONTACT US” section.

We will only use personal information provided in an opt-out request to review and comply with the request. 

‍Right to Limit the Use of Sensitive Personal Information
‍Where we process “sensitive personal information” as defined under the CPRA, you have the right to limit our use and disclosure of such information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer.If applicable, you may exercise this right by contacting us via the methods described in the “CONTACT US” section. 

‍Non-Discrimination
‍We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
1 Deny you goods or services.
2 Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3 Provide you a different level or quality of goods or services.
4 Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. 

‍Other California Privacy Rights‍