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KEELHELM — COMPLETE POLICY FOR KEELHELM This document combines every Keelhelm company-wide policy that applies to your Keelhelm account and to every Keelhelm app. Individual apps add their own supplemental terms, which you agree to when you first use each app. The authoritative, formatted versions live at keelhelm.com/legal. ======================================================================== Terms of Service — Keelhelm company policy (version 2026-07-04) ======================================================================== These Terms of Service (the "Terms") are the master agreement between you and Keelhelm ("Keelhelm", "we", "us", or "our"). They govern your use of the Keelhelm website at keelhelm.com and every application, site, and service we operate (each a "Service", together the "Services"). By using any Service, you agree to these Terms. How our terms stack. Keelhelm operates a fleet of separate applications. Each one has its own supplemental terms and privacy notice covering what that app does, what it costs, and how it handles your data. When you use an app, both these master Terms and that app's supplemental terms apply to you. If a supplemental term directly conflicts with these Terms for that app, the supplemental term controls for that app only. 1. Who we are ------------- Keelhelm is the software publisher and development studio that builds and operates the Services. Our formal company registration details and registered address will be published here once finalized; regardless, the operator of the Services stands behind these Terms. 2. The Services and supplemental app terms ------------------------------------------ Each Service has a dedicated page describing what it does and its own supplemental terms — for example, an app's Terms of Service and Privacy Policy linked in that app's footer. Those supplemental terms are incorporated into your agreement with us the moment you use that app. You should read the supplemental terms for any app you use; the Keelhelm policy library (https://keelhelm.com/legal/) links to all of them. 3. Eligibility and your account ------------------------------- You must be at least 16 years old (or the age of digital consent in your country, if higher) and able to form a binding contract to use the Services. If you use a Service on behalf of an organization, you represent that you are authorized to bind that organization to these Terms. You are responsible for activity under your account and for keeping your credentials secure. 4. Acceptable use ----------------- Your use of every Service is subject to the Keelhelm Acceptable Use Policy (https://keelhelm.com/legal/acceptable-use), which is part of these Terms. It prohibits illegal activity, infringement, abuse, and other conduct that harms the Services or other people. We may remove content, and suspend or terminate access, for a violation — see Sections 11 and 12. 5. Your content and data ------------------------ As between you and us, you keep all rights to the content and data you provide to or process through a Service ("Your Content"). You grant us a limited license to host, process, and transmit Your Content solely to operate and provide the Service to you, and as described in the Privacy Policy (https://keelhelm.com/legal/privacy) and the relevant app's privacy notice. We do not sell Your Content, and we do not use it to train AI models except where an app's supplemental terms expressly say so and you have agreed. You are responsible for having the rights necessary to provide Your Content and for its legality. 6. Our intellectual property ---------------------------- The Services, including their software, design, text, and branding, are owned by Keelhelm or its licensors and are protected by intellectual-property laws. We grant you a limited, non-exclusive, non-transferable, revocable license to use the Services in accordance with these Terms. You may not copy, modify, reverse-engineer, resell, or create derivative works of the Services except as the law expressly permits or an app's terms allow. 7. Third-party platforms, services, and payments ------------------------------------------------ Some Services run on, integrate with, or are distributed through third-party platforms (for example, an app store or a store platform), and payments for paid Services are handled by third-party payment processors or platform billing. Your use of those platforms and processors is also subject to their terms; we are not responsible for third-party platforms. Where an app is distributed through a third-party marketplace, that marketplace's rules also apply to your use of it. 8. Fees, billing, and trials ---------------------------- Some Services are free and some are paid. Pricing, billing cycles, trials, and cancellation for a paid Service are described in that app's supplemental terms and at the point of purchase. Unless the supplemental terms say otherwise, fees are charged in advance, are non-refundable except where required by law, and paid plans renew until cancelled. Material price changes will not apply retroactively to a billing period already in progress. 9. Disclaimers -------------- The Services are provided "as is" and "as available", without warranties of any kind, whether express, implied, or statutory, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement. We do not warrant that the Services will be uninterrupted, error-free, or secure, or that any output is accurate or fit for a given purpose. The Services are general-purpose software tools and are not a substitute for professional, financial, legal, medical, or other regulated advice. You are responsible for verifying any output before relying on it. 10. Limitation of liability --------------------------- To the fullest extent permitted by law, Keelhelm will not be liable for any indirect, incidental, special, consequential, or punitive damages, or for lost profits, revenue, data, or goodwill, arising out of or relating to the Services. Our total aggregate liability arising out of or relating to the Services and these Terms will not exceed the greater of (a) the amount you paid us for the relevant Service in the three months before the event giving rise to the claim, or (b) fifty US dollars ($50). Some jurisdictions do not allow certain limitations, so some of these may not apply to you. 11. Indemnity ------------- You agree to indemnify and hold Keelhelm harmless from claims, damages, and expenses (including reasonable legal fees) arising from Your Content, your use of the Services, or your violation of these Terms, the Acceptable Use Policy, or the law. 12. Suspension and termination ------------------------------ You may stop using the Services at any time and close your account or uninstall an app as described in that app's terms. We may suspend or terminate your access, with notice where reasonably possible, if you violate these Terms or the Acceptable Use Policy, if required to protect the Services or other users, or if required by law. We may also discontinue a Service; where a paid Service is discontinued, we will handle any prepaid amounts as required by law. 13. Changes to the Services and these Terms ------------------------------------------- We may change the Services and these Terms from time to time. When we make material changes to these Terms, we will update the version date above and, where appropriate, give notice through the Service. Your continued use after a change takes effect means you accept the updated Terms. 14. Governing law and disputes ------------------------------ These Terms are governed by the laws of the State of New Hampshire, USA, without regard to its conflict-of-laws rules. The state and federal courts located in New Hampshire have exclusive jurisdiction over any dispute that is not otherwise resolved. Nothing in these Terms removes rights you have under the mandatory consumer-protection laws of your own country of residence. Before filing any formal claim, you agree to first contact us at legal (at) keelhelm (dot) com so we can try to resolve it. 15. Contact ----------- Questions about these Terms, or legal notices of any kind: legal (at) keelhelm (dot) com. To report a violation or illegal content, use the reporting form (https://keelhelm.com/report). For copyright, use the copyright notice form (https://keelhelm.com/dmca). For privacy and data requests, use the privacy request form (https://keelhelm.com/privacy-request). ======================================================================== Acceptable Use Policy — Keelhelm company policy (version 2026-07-04) ======================================================================== This Acceptable Use Policy (the "AUP") applies to everyone who uses any Keelhelm Service. It is part of the Keelhelm Terms of Service (https://keelhelm.com/legal/terms), and individual apps may add stricter rules in their own terms. The point of this policy is simple: use our Services lawfully, and don't use them to harm other people, the Services, or the platforms we depend on. You must not use any Service to: -------------------------------- Break the law ~~~~~~~~~~~~~ - Do anything illegal, or promote, facilitate, or provide instructions for illegal activity. - Violate the rights of others, including intellectual-property, privacy, publicity, or contractual rights. - Evade sanctions, export controls, or other trade-control laws. Infringe intellectual property ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ - Upload, generate, store, or distribute material that infringes someone else's copyright, trademark, patent, or trade-secret rights, or misrepresent that you hold rights you do not. Exploit or endanger children ~~~~~~~~~~~~~~~~~~~~~~~~~~~~ - Create, store, request, or transmit child sexual abuse material (CSAM) or any content that sexualizes minors, or use a Service to groom, endanger, or exploit a child. We have zero tolerance for this. We remove such material, terminate the account, preserve relevant evidence, and report it to the appropriate authorities and hotlines as required by law. Attack, defraud, or deceive ~~~~~~~~~~~~~~~~~~~~~~~~~~~ - Distribute malware, ransomware, or other harmful code, or run phishing, credential-harvesting, or fraud schemes. - Impersonate a person or organization, or misrepresent your affiliation, in a way intended to deceive. - Send spam or unsolicited bulk or commercial messages, or harvest contact details for that purpose. Harm or harass people ~~~~~~~~~~~~~~~~~~~~~ - Harass, threaten, defame, or incite violence against anyone, or promote hateful conduct against people based on protected characteristics. - Publish another person's private or identifying information without a lawful basis ("doxxing"), or use a Service to stalk or surveil someone unlawfully. Abuse or overload the Services ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ - Probe, scan, or breach the security of a Service, access accounts or data that are not yours, or circumvent authentication, rate limits, quotas, or usage controls. - Interfere with or place an unreasonable load on the Services or the infrastructure and third-party platforms they run on, including denial-of-service activity. - Reverse-engineer, scrape, or copy a Service except as the law expressly permits, or use a Service to scrape or attack a third party in violation of their terms. Misuse for high-risk or prohibited purposes ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ - Rely on a Service as the sole control in safety-critical, medical, legal, financial, or other high-risk settings without your own independent verification and safeguards. Our Services are general tools, not certified advice or life-safety systems. - Resell, sublicense, or misrepresent a Service as your own except where an app's terms expressly allow it. Enforcement ----------- If we believe you have violated this policy, we may remove or disable the offending content, throttle, suspend, or terminate your access, and where the law requires or permits, preserve evidence and notify the relevant authorities. We try to act proportionately and to give notice where reasonably possible, but for severe violations — especially those that endanger people or the Services — we may act immediately and without prior notice. Serious or repeated violations can result in a permanent ban, including a repeat-infringer termination under our Copyright / DMCA Policy (https://keelhelm.com/legal/copyright-dmca). Reporting a violation --------------------- If you believe someone is misusing a Keelhelm Service or that content on our Services is illegal, please tell us. Use the reporting form (https://keelhelm.com/report) for abuse and illegal content, the copyright notice form (https://keelhelm.com/dmca) for infringement, or email legal (at) keelhelm (dot) com. See the Reporting & Notice-and-Action Policy (https://keelhelm.com/legal/reporting) for how we handle reports. If someone is in immediate danger, contact your local emergency services first. ======================================================================== Privacy Policy — Keelhelm company policy (version 2026-07-20) ======================================================================== This Privacy Policy explains how Keelhelm ("we", "us") processes personal data across the Keelhelm website and our Services. It is the baseline for everything we operate. Each app also has its own privacy notice with the specifics for that app — what data it reads, why, and how long it keeps it. Where an app's notice adds detail, read both together; where it is silent, this policy applies. The short version. We collect the minimum we need to run our Services and answer your messages. We don't sell your personal data or use it to build advertising profiles, and we don't use it to train AI models unless an app explicitly says so and you agree. Our public websites use privacy-respecting analytics (including Google Analytics) that you control with cookie choices — see our Cookie Policy (https://keelhelm.com/legal/cookies). You can ask us to access or delete your data at any time via the privacy request form (https://keelhelm.com/privacy-request). Who is responsible ------------------ Keelhelm is the data controller for the processing described here. You can reach us about privacy at legal (at) keelhelm (dot) com. Our registered company details will be added here once finalized. What we process --------------- - Website usage — when you visit our websites we process privacy-preserving, aggregate analytics (such as page views and coarse referrer and device type). Our public sites also use Google Analytics, a third-party analytics service provided by Google, which sets cookies subject to your choices — see our Cookie Policy (https://keelhelm.com/legal/cookies). We do not build advertising profiles and do not use cookies for advertising or cross-context behavioral advertising. - Messages and reports — when you contact us or submit a report, copyright notice, or privacy request, we process the information you provide (such as your name, email, the details of your request, and any evidence you attach) so we can handle it. - App account and service data — when you use one of our apps, we process the account, configuration, and service data that app needs to work. The categories, purposes, and retention for each app are in that app's own privacy notice. - Operational logs — we keep short-lived request and error logs to run the Services reliably and securely and to diagnose problems. Why we process it (legal bases) ------------------------------- Where the GDPR or similar laws apply, we rely on: performance of a contract (to provide a Service you asked for); legitimate interests (to keep the Services reliable and secure, prevent abuse, and answer your messages, balanced against your rights); consent (where we ask for it, such as an optional newsletter); and legal obligation (to comply with the law and respond to lawful requests). You can withdraw consent at any time. Who we share it with -------------------- We do not sell your personal data. We share it only with: - Service providers that process data on our behalf to run the Services — categories include hosting and compute, email delivery, payment processing, and analytics (including Google Analytics, a third-party analytics provider). They may only use the data to provide their service to us, under confidentiality and data-protection terms. - Third-party platforms you choose to connect a Service to, or through which an app is distributed, as described in that app's notice. - Authorities or others where we are legally required to, or to protect the Services, our rights, or the safety of people. International transfers ----------------------- We and our service providers may process data in countries other than yours, including the United States. Where we transfer personal data out of the EEA or UK, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses. Our analytics provider, Google, may process analytics data in the United States and states that it relies on the EU-US Data Privacy Framework and Standard Contractual Clauses for such transfers. How long we keep it ------------------- We keep personal data only as long as needed for the purpose we collected it, then delete or anonymize it. Website analytics are aggregate; where we use Google Analytics, user-level data is retained for our configured retention window (up to 14 months) and then automatically deleted. Operational logs roll off on a short window. When you contact us or submit a report, copyright/DMCA notice, or privacy request, we retain your submission — the details and any evidence you provide — in a restricted internal support system so we can handle it, follow up with you, and keep a record of legal notices; access is limited to authorized staff. We keep abuse and copyright/DMCA reports for up to 24 months after they are resolved, and completed privacy requests for up to 12 months, unless we are required to keep them longer to comply with the law or to establish, exercise, or defend a legal claim; matters that are still open are kept until they are closed. App data is kept per that app's notice and deleted on account closure or uninstall as described there. Your rights ----------- Depending on where you live, you have rights over your personal data. Under the GDPR these include the rights to access, rectify, erase, restrict, port, and object to processing of your data, and to withdraw consent. Under the CCPA/CPRA (California) these include the rights to know, delete, and correct your personal information, and to opt out of its sale or sharing. We do not sell your personal information for money and do not use it for cross-context behavioral advertising. Our use of third-party analytics cookies may be considered sharing under California law; you can opt out at any time using Your Privacy Choices (linked on every page) or by turning on Global Privacy Control in your browser, which we treat as a valid opt-out and confirm as honored (see our Cookie Policy (https://keelhelm.com/legal/cookies)). We will not discriminate against you for exercising your rights. To exercise any right, use the privacy request form (https://keelhelm.com/privacy-request) or email legal (at) keelhelm (dot) com. We will verify your request and respond within the time the law allows — normally within one month under the GDPR and 45 days under the CCPA, extendable where permitted. You also have the right to complain to your local data-protection authority. Children -------- Our Services are not directed to children under 16, and we do not knowingly collect their personal data. If you believe a child has provided us personal data, contact us and we will delete it. Security -------- We use reasonable technical and organizational measures to protect personal data, including encryption in transit and access controls. No system is perfectly secure; if a breach affects your data, we will notify you and the authorities as the law requires. Changes ------- We may update this policy; when we make material changes we will update the version date above. Continued use of the Services after a change means you accept the update. ======================================================================== Cookie Policy — Keelhelm company policy (version 2026-07-20) ======================================================================== This Cookie Policy explains the cookies and similar technologies used on Keelhelm websites — keelhelm.com and our apps' public sites — what they do, and how you control them. It supplements the Keelhelm Privacy Policy (https://keelhelm.com/legal/privacy), which describes how we handle personal data generally. Your choice, once, everywhere. Our sites all live under keelhelm.com, so the choice you make in the cookie banner is remembered across every Keelhelm site — you don't have to decide again on each one. You can change it any time using the Your Privacy Choices link shown on every page. What cookies are ---------------- Cookies are small text files a website stores in your browser. Some are strictly necessary for the site to work or to remember a choice you made; others, like analytics cookies, are optional and only used with your permission where the law requires it. Cookies we use -------------- - Consent choice (khc) — first-party, strictly necessary. Remembers whether you accepted or rejected analytics cookies, so we don't ask again. Set on .keelhelm.com so it applies across all Keelhelm sites. Stored for about 180 days. No consent needed — it only exists to honor your choice. - Google Analytics (_ga, _ga_<id>) — third-party, analytics. Provided by Google, these help us understand aggregate site usage (such as visits and popular pages) so we can improve. They do not build advertising profiles — we run analytics only, with Google's advertising features turned off. In the EEA and UK these are set only after you accept; elsewhere they are set unless you opt out (see below). Typically stored for up to about 13 months. - Security challenge — strictly necessary. On pages with a form (for example, our reporting forms) a bot-protection challenge may set a short-lived cookie to tell humans from automated abuse. Strictly necessary; no consent required. We do not use advertising cookies, cross-context behavioral advertising, or third-party tracking pixels. Analytics and your consent -------------------------- How analytics cookies behave depends on where you are, so we serve the appropriate treatment automatically: - EEA, UK & similar (opt-in). Analytics cookies are off by default. Nothing that identifies you is stored until you click Accept in the cookie banner. If you ignore or reject the banner, no analytics cookies are set. - United States & elsewhere (opt-out). Analytics is on by default, and you can turn it off at any time with Reject in the banner or the Your Privacy Choices link. - Global Privacy Control (GPC). If your browser sends a GPC signal, we treat it as a valid opt-out everywhere and do not set analytics cookies — and we show that your opt-out has been honored. How to change your choice ------------------------- Use the Your Privacy Choices link shown on every Keelhelm page to reopen the banner and accept or reject analytics at any time. You can also clear cookies in your browser settings, or enable Global Privacy Control so your preference is applied automatically. Do Not Sell or Share My Personal Information (California) --------------------------------------------------------- We do not sell your personal information for money. Our use of third-party analytics cookies may be considered sharing under California law. You can opt out at any time using Your Privacy Choices or by enabling Global Privacy Control, which we honor and confirm as processed. More detail is in the Keelhelm Privacy Policy (Your rights) (https://keelhelm.com/legal/privacy#your-rights). More information ---------------- For how we handle personal data generally — including international transfers, retention, and your rights — see the Keelhelm Privacy Policy (https://keelhelm.com/legal/privacy). To make a privacy request, use the privacy request form (https://keelhelm.com/privacy-request) or email legal (at) keelhelm (dot) com. Keelhelm company policies ------------------------- This Cookie Policy is part of the Keelhelm company policies and applies across every Keelhelm site alongside the Privacy Policy (https://keelhelm.com/legal/privacy) and the rest of the policy library (https://keelhelm.com/legal/). Changes ------- We may update this policy; when we make material changes we will update the version date above. ======================================================================== Copyright and DMCA Policy — Keelhelm company policy (version 2026-07-04) ======================================================================== Keelhelm respects intellectual-property rights and expects users of our Services to do the same. If you believe material available through a Keelhelm Service infringes your copyright, you can send us a takedown notice under the U.S. Digital Millennium Copyright Act (DMCA), 17 U.S.C. § 512, and we will respond as described below. For non-copyright illegal content, use the Reporting & Notice-and-Action Policy (https://keelhelm.com/legal/reporting) instead. How to file a copyright notice ------------------------------ Use our copyright notice form (https://keelhelm.com/dmca), or send a written notice to our copyright agent at legal (at) keelhelm (dot) com. To be effective under § 512(c)(3), your notice must include all of the following: 1. A physical or electronic signature of the copyright owner or a person authorized to act on their behalf; 2. Identification of the copyrighted work you claim has been infringed (or a representative list, if multiple works); 3. Identification of the material you claim is infringing, and information reasonably sufficient to let us locate it — such as the exact URL; 4. Information reasonably sufficient to let us contact you, such as your name, address, telephone number, and email; 5. A statement that you have a good-faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and 6. A statement that the information in your notice is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of the exclusive right that is allegedly infringed. Please note that under § 512(f) you may be liable for damages, including costs and legal fees, if you knowingly materially misrepresent that material is infringing. Designated agent. Keelhelm's designated copyright agent can be reached at legal (at) keelhelm (dot) com (postal address to be added on incorporation; a formal designated-agent registration with the U.S. Copyright Office is in progress). Until that registration completes, email remains the fastest way to reach us, and we still act on valid notices. What we do with a valid notice ------------------------------ When we receive a notice that substantially complies with the requirements above, we will act expeditiously to remove or disable access to the material, and — where the material was posted by an identifiable user — take reasonable steps to notify that user that we have done so. Counter-notification -------------------- If you are a user whose material was removed and you believe it was removed by mistake or misidentification, you may send us a counter-notice under § 512(g). A valid counter-notice must include: 1. Your physical or electronic signature; 2. Identification of the material that was removed and the location where it appeared before removal; 3. A statement under penalty of perjury that you have a good-faith belief the material was removed as a result of mistake or misidentification; and 4. Your name, address, and telephone number, and a statement that you consent to the jurisdiction of the federal court for the judicial district in which your address is located (or, if outside the United States, any judicial district in which we may be found), and that you will accept service of process from the person who filed the original notice or their agent. If we receive a valid counter-notice, we may restore the material in 10–14 business days unless the original complainant notifies us that they have filed a court action to keep it down. Send counter-notices to legal (at) keelhelm (dot) com. Repeat infringers ----------------- In accordance with § 512(i), Keelhelm has adopted and will reasonably implement a policy of terminating, in appropriate circumstances, the accounts of users who are repeat infringers. Repeat infringement is also a violation of our Acceptable Use Policy (https://keelhelm.com/legal/acceptable-use). Other jurisdictions ------------------- Rights holders outside the United States may use the same process. For illegal content other than copyright infringement — including under the EU Digital Services Act — see the Reporting & Notice-and-Action Policy (https://keelhelm.com/legal/reporting). ======================================================================== Reporting and Notice-and-Action Policy — Keelhelm company policy (version 2026-07-04) ======================================================================== This policy explains how to tell Keelhelm about illegal content or abuse on our Services, and how we handle what you send. It includes the notice-and-action mechanism we provide under Article 16 of the EU Digital Services Act (DSA). It works alongside the Acceptable Use Policy (https://keelhelm.com/legal/acceptable-use), the Copyright / DMCA Policy (https://keelhelm.com/legal/copyright-dmca), and the Privacy Policy (https://keelhelm.com/legal/privacy). Emergencies. If someone is in immediate danger, contact your local emergency services first. To report child sexual abuse material, you may also contact the authorities or a national hotline directly; we act on and escalate such reports with the highest priority. How to report ------------- - Illegal content or abuse (fraud, malware, harassment, privacy violations, and other unlawful or prohibited use): the reporting form (https://keelhelm.com/report), or legal (at) keelhelm (dot) com. - Copyright infringement: the copyright notice form (https://keelhelm.com/dmca) (see the Copyright / DMCA Policy (https://keelhelm.com/legal/copyright-dmca)). - Your personal data (access, deletion, or other privacy rights): the privacy request form (https://keelhelm.com/privacy-request). What your notice should contain ------------------------------- To let us assess and act on a report of illegal content, please give us — as required by DSA Article 16 — enough to make an informed decision: - A clear explanation of why you consider the content illegal or in violation of our policies; - The exact location of the content, such as the URL or other information that lets us find it; - Your name and email, so we can acknowledge the report and follow up — except for reports involving certain offences against children, where you may report without identifying yourself; and - A statement that you believe, in good faith, that the information in your report is accurate and complete. The more precise and substantiated your notice, the faster we can act on it. How we handle reports --------------------- We review reports without undue delay and in a diligent, non-arbitrary way. Depending on what we find, we may remove or disable the content, restrict or terminate the responsible account, refer the matter to the authorities, or decide that no action is warranted. Where you provided contact details, we will acknowledge your report and, as required by the DSA, inform you of the decision we take and the main reasons for it, along with information about how to contest it where applicable. If your notice gives us actual knowledge of illegal content, we act on it as the law requires. Fair use of this mechanism -------------------------- Please report in good faith. If you repeatedly submit notices or complaints that are manifestly unfounded, we may suspend our handling of your reports for a reasonable period after a prior warning, as the DSA permits. Misusing the reporting process — for example, to harass another user or to suppress lawful content — may itself violate the Acceptable Use Policy (https://keelhelm.com/legal/acceptable-use). Point of contact ---------------- Our single point of contact for reports, legal notices, and communications from authorities is legal (at) keelhelm (dot) com. We can receive communications in English.