Comprehensive Privacy Policy and Data Protection Notice

1. Introduction, Policy Scope, Application, and Binding Effect

This Privacy Policy ("Policy," "Privacy Policy," "Privacy Notice," "Data Protection Policy," or "Privacy Statement") constitutes a comprehensive, exhaustive, detailed, legally binding disclosure, representation, explanation, and contractual agreement governing, regulating, and addressing the collection, acquisition, receipt, gathering, obtaining, accessing, use, processing, handling, storage, retention, archiving, disclosure, sharing, dissemination, transfer, transmission, pro tection, safeguarding, security, and ultimate disposal, deletion, anonymization, or destruction of personal information, personally identifiable information, individual data, personal data, sensitive personal information, sensitive data, special category data, biometric data, health data, financial data, location data, device data, usage data, behavioral data, and all other forms, types, categories, and species of information and data relating to, concerning, about, attributable to, connected with, associated with, or capable of identifying, whether directly or indirectly, identified or identifiable natural persons, living individuals, data subjects, users, customers, subscribers, visitors, or any other human beings (collectively, comprehensively, and exhaustively referred to as "Personal Information," "Personal Data," "PII," "Individual Data," or similar designations) by Santa Fe Applied Systems LLC, a limited liability company duly organized, validly existing, and in good standing under and pursuant to the laws, statutes, regulations, and legal framework of the State of New Mexico, United States of America, and conducting business operations, engaging in commercial activities, providing services, offering products, and interacting with customers, users, and the general public under the trade name, fictitious business name, assumed name, and doing-business-as designation of "ABsort" (hereinafter collectively, interchangeably, and comprehensively referred to as "Company," "we," "us," "our," "ABsort," "Santa Fe Applied Systems," "the Organization," "Data Controller," "Data Processor," or similar designations as the legal context, regulatory framework, or jurisdictional requirements may necessitate, require, dictate, or permit).

This Privacy Policy applies comprehensively, universally, and without limitation, exception, exclusion, or qualification to all Personal Information and Personal Data that is, has been, or may in the future be collected, received, obtained, gathered, acquired, accessed, processed, used, handled, stored, maintained, retained, archived, preserved, disclosed, shared, revealed, communicated, transmitted, transferred, conveyed, disseminated, distributed, or otherwise dealt with, managed, controlled, or administered by the Company through, from, by means of, in connection with, in association with, or in any way related to, arising from, or attributable to your access to, use of, interaction with, engagement with, browsing of, or connection to the ABsort website (including all primary domains, subdomains, related domains, mobile-optimized versions, responsive designs, and all associated URLs and web addresses), the ABsort platform, software applications of all types (including but not limited to web applications, web-based applications, browser-based applications, progressive web applications, mobile applications for iOS and Android, desktop applications for Windows, macOS, and Linux operating systems, command-line applications, and any other software delivery formats or mechanisms), application programming interfaces (APIs) of all versions and iterations, software development kits (SDKs), plugins, extensions, add-ons, integrations, connectors, widgets, embeddable components, services of all kinds (whether provided online, offline, or in hybrid formats), features, capabilities, functionality, tools, utilities, resources, content, materials, data, information, documentation, support services, customer service interactions, technical support communications, marketing communications, promotional materials, newsletters, email campaigns, and all other online and offline interactions, engagements, communications, transactions, relationships, and touchpoints between you and the Company (collectively, comprehensively, and exhaustively referred to as the "Service," "Services," "Platform," "Application," "System," or similar designations).

By accessing, visiting, viewing, browsing, navigating, using, interacting with, engaging with, or otherwise connecting to or utilizing the Service in any manner, method, way, form, or fashion whatsoever, whether as a registered user, authenticated user, logged-in user, guest user, anonymous user, trial user, free-tier user, freemium user, paying subscriber, premium member, enterprise customer, administrator, super administrator, account owner, team member, collaborator, contributor, viewer, commenter, or in any other capacity, role, status, or relationship, you expressly, explicitly, unambiguously, unequivocally, unconditionally, irrevocably, and absolutely acknowledge, recognize, understand, accept, agree, consent, and confirm that you have carefully, thoroughly, completely, and attentively read, reviewed, examined, studied, analyzed, and fully comprehended all terms, conditions, provisions, requirements, obligations, practices, procedures, policies, disclosures, explanations, and commitments set forth, stated, described, disclosed, or otherwise communicated in this Privacy Policy in its entirety, and that you voluntarily, knowingly, willingly, intentionally, and with full informed consent agree to be legally bound by, subject to, and responsible for compliance with all aspects of this Privacy Policy. If you do not agree with, accept, or consent to any provision, term, practice, procedure, or policy contained, stated, described, or disclosed in this Privacy Policy, or if you have any reservations, concerns, objections, or disagreements with any aspect of our data collection, use, processing, storage, disclosure, or protection practices, you must immediately, promptly, and without delay discontinue, cease, stop, terminate, and permanently refrain from all access to and use of the Service.

2. Governing Law, Jurisdiction, Venue, and Forum Selection for Privacy Disputes

This Privacy Policy, our data processing practices, privacy protection measures, information security procedures, data collection activities, data usage practices, data sharing arrangements, data transfer mechanisms, data retention policies, data deletion procedures, and any and all disputes, controversies, disagreements, conflicts, claims, demands, causes of action, proceedings, litigation, arbitration, mediation, or other legal or equitable matters of any kind, type, nature, or description whatsoever arising out of, relating to, based upon, connected with, attributed to, traceable to, or in any way associated with or concerning this Privacy Policy, our privacy practices, data protection obligations, information security measures, data breach incidents, unauthorized access, privacy violations, data misuse, identity theft, fraudulent activities involving personal data, or any other privacy-related, data-protection-related, information-security-related, or confidentiality-related matters (collectively referred to as "Privacy Disputes") shall be governed by and construed in accordance with the internal substantive laws of the State of Delaware, United States of America, without regard to its choice of law or conflict of law provisions.

You hereby irrevocably, unconditionally, and absolutely consent and submit to the exclusive personal jurisdiction and exclusive venue of the courts located in New Castle County, Delaware, and the United States District Court for the District of Delaware for any and all Privacy Disputes, matters, or proceedings. You acknowledge that Delaware courts have been selected as the exclusive forum due to Delaware's strong protections for business privacy, corporate confidentiality, and established legal framework for balancing privacy rights with legitimate business interests. You waive any objections to jurisdiction or venue in Delaware courts for privacy-related matters.

3. Information We Collect - Comprehensive Categories and Detailed Descriptions

3.1 Information You Provide Directly and Voluntarily

We collect, receive, obtain, acquire, and process Personal Information that you voluntarily, knowingly, intentionally, deliberately, purposefully, and affirmatively provide, submit, supply, furnish, deliver, upload, transmit, enter, input, communicate, disclose, or otherwise make available to us directly, explicitly, and in an identifiable manner through your use of, interaction with, engagement with, and participation in the Service, including but in no way limited to the following extensive, detailed, and comprehensive categories, types, classes, and species of information and data:

  • Account Registration and Profile Information: Full legal name (first name, middle name, last name, suffixes), preferred name, nickname, username, display name, handle, email address (primary, secondary, alternate), password (stored in hashed and encrypted form), security questions and corresponding answers, phone number (mobile, landline, work), mobile phone number with country code, physical address (street address, apartment/suite number, city, state/province, postal code/ZIP code, country), postal mailing address (if different from physical address), billing address, shipping address, delivery address, country of residence, country of citizenship, nationality, preferred language, secondary languages, timezone, date of birth, age, age range, gender identity, government-issued identification numbers (where legally permitted and necessary, such as passport numbers, national ID numbers, driver's license numbers, social security numbers or equivalent), profile photograph, avatar image, profile banner image, biographical information, personal description, interests, hobbies, preferences, and any other information you voluntarily provide during account creation, registration, signup, setup, onboarding, or profile configuration processes;
  • Merchant of Record and Financial Data Processing: PLEASE NOTE that all financial transactions, including subscription payments, credit card processing, and banking details, are handled exclusively by a third-party Merchant of Record ("MoR"). Santa Fe Applied Systems LLC does NOT directly collect, store, process, or maintain your full credit card number, CVV code, or bank account details on our servers. This sensitive financial data is provided directly by you to the MoR via secure, encrypted payment gateways. The MoR may share limited transaction data with us (e.g., transaction status, partial card numbers for identification, billing country) for account management purposes, but liability for the security and processing of your financial data rests with the MoR.
  • Business and Professional Information: Company name, business legal name, registered business name, doing-business-as names, trade names, employer identification numbers (EIN), tax identification numbers (TIN), business registration numbers, business addresses (headquarters, branch offices, registered agent address), business contact information (phone, fax, email), professional titles, job titles, positions, roles within organization, department names, industry classifications (NAICS codes, SIC codes), business type (corporation, LLC, partnership, sole proprietorship), number of employees, employee count ranges, annual revenue, annual revenue ranges, company size, years in business, business descriptions, organizational information, corporate structure, ownership structure (where disclosed), and other professional or business-related information;
  • User-Generated Content and Uploaded Materials: Text content, written documents, word processing files, spreadsheets, presentations, PDF documents, images, photographs, pictures, graphics, videos, video recordings, audio files, audio recordings, voice recordings, sound files, podcasts, comments, reviews, ratings, feedback, testimonials, endorsements, survey responses, poll responses, quiz answers, form submissions, forum posts, discussion board contributions, community contributions, chat messages, instant messages, direct messages, support tickets, help desk inquiries, customer service requests, technical support communications, bug reports, feature requests, enhancement suggestions, and any other content, data, materials, files, documents, or information that you create, generate, produce, author, compose, draft, design, develop, upload, submit, post, publish, transmit, store, save, share, or otherwise make available through, on, or by means of the Service;

3.2 Information Collected Automatically Through Technology and System Logs

When you access, visit, browse, navigate, use, interact with, or engage with the Service, we automatically, passively, systematically, and continuously collect, record, log, capture, gather, generate, derive, and process certain categories and types of information about your device, your system, your software environment, your network connection, your browsing behavior, your usage patterns, your interaction patterns, your engagement metrics, and your activities through the deployment, utilization, and operation of various technologies, mechanisms, systems, tools, and methodologies including but not limited to HTTP cookies (session cookies, persistent cookies, first-party cookies, third-party cookies), browser cookies, flash cookies, web beacons, tracking pixels, pixel tags, clear GIFs, tracking GIFs, JavaScript tags, tracking scripts, embedded scripts, local storage mechanisms (HTML5 local storage, DOM storage), session storage, IndexedDB, Web SQL, server logs, access logs, error logs, application logs, system logs, audit logs, security logs, analytics logs, and other automated data collection technologies, tracking mechanisms, monitoring systems, and logging infrastructure. This automatically and passively collected information includes but is in no way limited to the following extensive, detailed, and comprehensive categories:

  • Device and Hardware Information: Device type, device category, device classification (smartphone, tablet, laptop, desktop, smart TV, gaming console, wearable device, IoT device), device model, device model number, device manufacturer, device brand, hardware manufacturer, operating system type, operating system name, operating system version, operating system build number, firmware version, BIOS version, browser type, browser name, browser version, browser build, browser language, browser plugins, browser extensions, screen resolution, screen size, screen dimensions, display resolution, pixel density, color depth, device identifiers (Unique Device Identifier - UDID, Identifier for Advertisers - IDFA, Google Advertising ID - GAID, Android ID, Windows Advertising ID), hardware identifiers, serial numbers, IMEI numbers, MAC addresses (Media Access Control addresses), processor type, processor speed, CPU architecture, GPU information, RAM capacity, storage capacity, battery level, battery status, device orientation, device sensors, accelerometer data, gyroscope data, proximity sensor data, ambient light sensor data, and other technical characteristics, specifications, and configurations of your device, hardware, software environment, and system setup;

4. How We Use Your Personal Information - Purposes, Legal Bases, and Justifications

The Company uses, processes, analyzes, examines, evaluates, manipulates, transforms, combines, aggregates, synthesizes, correlates, cross-references, merges, links, stores, maintains, retains, archives, and otherwise handles, manages, controls, and administers the Personal Information and Personal Data we collect from you, about you, and concerning you for a broad, extensive, comprehensive, and wide-ranging array of business purposes, operational purposes, commercial purposes, administrative purposes, technical purposes, marketing purposes, advertising purposes, promotional purposes, research purposes, analytical purposes, security purposes, fraud prevention purposes, compliance purposes, legal purposes, regulatory purposes, contractual performance purposes, service delivery purposes, and any other purposes that we deem necessary, appropriate, useful, beneficial, advantageous, helpful, relevant, material, or otherwise valuable, important, or conducive to our legitimate business interests, operational requirements, commercial objectives, strategic goals, legal obligations, contractual commitments, regulatory compliance, risk management, security protection, or competitive positioning, including but in no way limited to each and every one of the following specific, detailed, and comprehensive purposes and use cases...

5. Data Retention, Storage Duration, and Deletion Practices

We retain, store, maintain, preserve, archive, and keep your Personal Information and Personal Data for as long as reasonably necessary, appropriate, useful, beneficial, required, mandated, or legally obligated to fulfill, accomplish, satisfy, achieve, complete, or perform the purposes described, stated, disclosed, and explained in this Privacy Policy, to comply with, satisfy, fulfill, and meet our legal obligations, statutory requirements, regulatory mandates, contractual commitments, tax obligations, record-keeping requirements, audit requirements, litigation holds, preservation orders, court orders, subpoena requirements, government requests, law enforcement demands, to resolve, settle, adjudicate, or defend disputes, controversies, claims, lawsuits, litigation, arbitration proceedings, to enforce, implement, uphold, and give effect to our agreements, contracts, terms of service, policies, and legal rights, to protect, defend, preserve, and safeguard our legal rights, intellectual property rights, property rights, business interests, financial interests, to defend against, respond to, investigate, prosecute, or pursue claims, lawsuits, legal proceedings, to maintain comprehensive, accurate, and complete business records, financial records, transaction records, activity logs, audit trails, and for any other legitimate business purposes, operational requirements, security considerations, fraud prevention measures, or risk management objectives, whether presently existing, currently applicable, or reasonably anticipated to arise, develop, occur, or materialize in the future.

6. Your Privacy Rights - Access, Correction, Deletion, and Data Portability

Subject to applicable law, legal restrictions, statutory limitations, regulatory requirements, established exceptions, recognized exemptions, and our legitimate business interests, security requirements, fraud prevention obligations, legal compliance mandates, and contractual commitments, you may have certain rights, entitlements, privileges, options, and choices regarding your Personal Information and Personal Data, which rights may vary, differ, or change based upon your geographic location, jurisdiction of residence, citizenship, the specific regulatory framework applicable to you (such as GDPR for EEA residents, CCPA/CPRA for California residents, or other privacy laws), and the specific circumstances, contexts, and factual situations involved in your particular case or situation...

7. Contact Information for Privacy Inquiries and Data Subject Requests

For questions, concerns, inquiries, requests, complaints, or any communications regarding this Privacy Policy, our privacy practices, data protection measures, or your Personal Information, please contact:

Santa Fe Applied Systems LLC
(d/b/a ABsort)
Privacy Officer
Data Protection Office
Email: privacy[at]absort[dot]com
Legal Department: legal[at]absort[dot]com

Last Updated: February 11, 2026

Effective Date: February 11, 2026

© 2026 Santa Fe Applied Systems LLC. All rights reserved worldwide.