Please read these Terms of Service (“Terms”, “Terms of Service”) carefully before using the https://distro.io? Website (the “Service”) operated by Distro, LLC (“us”, “we”, or “our”).

Your access to and use of the Service is conditioned upon your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who wish to access or use the Service.

By accessing or using the Service you agree to be bound by these Terms. If you disagree with any part of the terms then you do not have permission to access the Service.

When you create an account with us, you guarantee that you are 18 or older, and that the information you provide us is accurate, complete, and current at all times. Inaccurate, incomplete, or obsolete information may result in the immediate termination of your account on the Service.

You are responsible for maintaining the confidentiality of your account and password, including but not limited to the restriction of access to your computer and/or account. You agree to accept responsibility for any and all activities or actions that occur under your account and/or password, whether your password is with our Service or a third-party service. You must notify us immediately upon becoming aware of any breach of security or unauthorized use of your account.

You may not use as a username the name of another person or entity or that is not lawfully available for use, a name or trademark that is subject to any rights of another person or entity other than you, without appropriate authorization. You may nust use as a username nay name that is offensive, vulgar or obscene.

The Service and its original content, features and functionality are and will remain the exclusive property of Distro, LLC and its licensors. The Service is protected by copyright, trademark, and other laws of both the United States and foreign countries. Our trademarks and trade dress may not be used in connection with any product or service without the prior written consent of Distro, LLC.

Distro makes no claim to ownership of any intellectual property developed, created, or shared through the Distro marketplace. Furthermore, no Distro candidate user shall make any claim to ownership, rights, access, or security of any intellectual property owned by a Distro customer.

We may terminate or suspend your account and bar access to the Service immediately, without prior notice or liability, under our sole discretion, for any reason whatsoever and without limitation, including but not limited to a breach of the Terms.

All provisions of the Terms which by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

Cause for termination may include, but not limited to, failed payment of 14 days or more, disclosure of compensation, solicitation and hiring of users in Distro without Distro’s prior written consent, using Distro users to find and hire other users outside of Distro, abuse or improper use of any other terms found in the Distro Terms and Conditions.

Failed payments of 14 days or more will incur a 5% late fee, monthly.

Customers may cancel only with a 30 day notice for services altogether or per candidate they have hired in the Distro application. The period of 30 days starts from the termination of a candidate user on the candidate user profile.

In the event that breach of terms occurs, Distro will be entitled to collect the annualized value of the monthly invoices. Distro will also be entitled to collect legal fees incurred in the collection process.

You agree to defend, indemnify and hold harmless Distro, LLC and its licensee and licensors, and their employees, contractors, agents, officers and directors, from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorney’s fees), resulting from or arising out of a) your use and access of the Service, by you or any person using your account and password, or b) a breach of these Terms.

In no event shall Distro, LLC, nor its directors, employees, partners, agents, suppliers, or affiliates, be liable for any indirect, incidental, special, consequential or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from (i) your access to or use of or inability to access or use the Service; (ii) any conduct or content of any third party on the Service; (iii) any content obtained from the SErvice; and (iv) unauthorized access, use or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence) or any other legal theory, whether or not we have been informed of the possibility of such damage, and even if a remedy set forth herein is found to have failed of its essential purpose.

Your use of the Service is at your sole risk. The Service is provided on an “AS IS” and “AS AVAILABLE” basis. The Service is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement or course of performance.

Distro, LLC, its subsidiaries, affiliates, and its licensors do not have warrant that a) the Service will function uninterrupted, secure or available at any particular time or location; b) any errors or defects will be corrected; c) the Service is free of viruses or other harmful components; or d) the results of using the SErvice will meet your requirements. 

Some jurisdictions do not allow the exclusion of certain warranties or the exclusion or limitation of liability for consequential or incidental damages, so the limitations above may not apply to you.

These Terms shall be governed and construed in accordance with the laws of Utah, United States, without regard to its conflict of law provisions.

Our failure to enforce any right or provision of these Terms will not be considered a waiver of those rights. If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions of these Terms will remain in effect. These Terms constitute the entire agreement between us regarding our Service, and supersede and replace any prior agreements we might have had between us regarding the Service. 

We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material we will provide at least 30 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.

By continuing to access or use our Service after any revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, you are no longer authorized to use the Service.

By utilizing our services, you agree to grant Distro, LLC authorization to initiate debt entires to the designated bank account provided for the purpose of Distro services. This authorization remains in effect until a minimum of sixty (60) days written notice is given to Distro, LLC and any modifications to this agreement will be communicated through our website’s terms and conditions.

By clicking to accept the Terms of Service on the Site or by continuing to use the Site or the Site Services on or after the effective date noted above, you accept and agree to the Terms of Service. To the extent permitted by applicable law and except as otherwise provided in the Terms of Service, we may modify the Terms of Service without prior notice to you, and any revisions to the Terms of Service will take effect when posted on the Site unless otherwise stated. However, we will provide advance notice of any increase in prices or fees affecting current Users. Please check the Site often for updates.

Customers will maintain a Credit Container that tracks available credits in Distro. When the credit balance reaches just 20%, the balance will recharge the same container for credits automatically. Distro will charge the credits with the payment method on file. Credits may be paid for with credit card or ACH authorization. The balance of the credit container can be viewed in the Distro web application. 

You must pay the contracted candidate fees, if any, through your established payment method. Each contracted candidate fee, if any, and each Flat Payment Processing Fee, if applicable, covers a monthly billing period beginning on the date that you first make payment and ending one month later. You irrevocably authorize and instruct us to automatically charge the fees for the selected candidates and their associated fee, if any, to your payment method on file at the beginning of each billing period. This authorization will remain in full force and effect as long as the client has active, hired candidates in Distro, otherwise notify us that you wish to revoke your authorization by contacting support@distro.io, or cancel your Account.

You can add or remove contracted candidates at any time. A minimum of thirty (30) days notice is required for each candidate hired. You will have the option to either issue severance or retain the amount as credit for future invoices for one year. A minimum of sixty (60) days written notice is required to cancel all services, altogether.

If and to the extent permitted by Distro in its sole discretion, Users may pay Contracted Candidate Fees, Payment Processing Fees, and other fees owed under the Terms of Service from their designated bank accounts. Subject to Distro’s eligibility requirements, if you elect to pay Contracted Candidate Fees or any other amounts owed under the Terms of Service via ACH transfers from your designated bank account, you hereby authorize us to electronically debit your designated bank account via ACH for such amounts pursuant to the Terms of Service, and you agree to comply with the ACH rules issued by the National Automated Clearing House (“NACHA”) and all applicable laws, including, but not limited to, the federal Bank Secrecy Act, the U.S.A. Patriot Act, and economic sanctions overseen by the Office of Foreign Assets Control (OFAC). Your authorization for ACH transfers will remain in full force and effect until you notify us that you wish to revoke your authorization by contacting support@distro.io. You understand that we require at least five (5) business day’s prior notice in order to cancel your authorization for ACH transfers. 

You must notify us of any change in your designated bank account’s information at least ten (10) business days before any such change by updating you bank account information in your Profile or by contacting support@distro.io. If we do not receive notice at least ten (10) days before any such change, we may attempt, in our sole discretion, to implement such change prior to any ACH debit performed pursuant to your authorization provided in the Terms of Service. However, we assume no responsibility for our failure to do so.

You may view a history of your Account transactions by logging in to the Site. You are solely responsible for promptly reconciling your Account transaction history (each, an “Error”) within 30 days of when the Error could be viewed in your Account transaction history on the site. If you do not notify us of the Error within 30 days of when the Error could be viewed in your Account transaction history on the Site, you will forfeit the right to contest the Error, except to the extent such forfeiture is prohibited by applicable law or the NACHA rules.

Subject to the foregoing notice requirement: (a) if and to the extent an Error is caused by us, we will correct the Error and (b) if an Error is caused by you, we may, but are under no obligation to, attempt to correct the Error and will offset any costs we incur from any funds returned to your bank account or your Client Escrow Account, as applicable.

Distro customers agree to not solicit Distro developers to contract work either part-time or full-time or project-based outside of Services provided by Distro. Customers may not send payments directly to developers for any reason. In the event that a customer reaches out to solicit work directly outside of the Distro services, Distro may sever services wholly and immediately. This agreement will remain in effect for three (3) years from the termination date and effective until the candidate is not actively working in Distro. Inquiring or disclosing candidate compensation is solicitation. In the event that any solicitation that causes damage to the existing customer invoice or relationship occurs, Distro will be entitled to collect the annualized value of the monthly invoices. Distro will also be entitled to collect legal fees incurred in the collection process.

The terms of this Service Agreement commences on the Service Order Effective Date and continues on a monthly basis set to renew each month. This Service Order shall automatically renew for provision of the Renewable Services specified in the above services description and fees for a continuous month to month period (each, a “Renewal Term”) unless: (i) Customer provides written notice to Distro via email to support@distro.io sixty (60) days before the end date of the Initial Term or any Renewal Term of Customer’s intention not to renew services; (ii) Customer provides written notice to Distro via email to support@distro.io thirty (30) days before the end date of the Initial Term or any Renewal Term, as applicable. The initial Term together with any Renewal Terms shall be considered the “Service Order Term”.

Annual ten percent (10%) raise will take effect on the first payroll run after a Distro candidate completes their anniversary each year. Customer can provide more than the ten percent (10%) standard raise, if they choose. The customer and candidate will be notified one (1) month prior and one (1) week prior to the raise effective date.

By Creating an account in Distro, you agree to all the terms and conditions herein. Your access to and use of the User Agreement is conditioned upon your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who wish to access or use the User Agreement. User Agreement provided under this User AgreementUser Agreement are provided pursuant to the Distro Subscription Agreement, the terms and conditions of which are set forth at https://distro.io/terms-and-conditions/ (the “Agreement”), and are incorporated into this User Agreement. This User Agreement is intended to supplement the Agreement and is subject in all respects to the terms of the Agreement. In the event of any direct conflict between the terms of this User Agreement and the Agreement, the terms of this User Agreement shall govern to the extent of the conflict. Capitalized terms used in this User Agreement but not defined herein shall have the meanings given in the Agreement. 

Candidate acknowledges that this role is a remote position with a minimum of 40 hours per week performed, unless agreed upon or a part-time position. Candidate makes no claim on employment status, benefits, or any tax liability implications regardless of country, county, and city of origin. 

Distro candidates agree to not solicit Distro developers to contract work either part-time or full-time or project-based outside of User Agreement provided by Distro. 

Candidates may not recruit on behalf of the customer unless done through the Distro application itself. Where applicable, Candidates may receive compensation for referring other candidates through the Distro application. Candidates recruiting and hiring on behalf of the customer outside of Distro may be cause for immediate termination as it violates the termination clause. 

Candidates may not receive payments directly or indirectly from a customer for any reason. In the event that a customer reaches out to solicit work directly or indirectly outside of the Distro User Agreement, Distro may sever this agreement wholly and immediately. (Unless otherwise set out by the terms set out by this Agreement and/or its addendum(s). Distro Candidates agree to not ask, infer, or investigate the personal pay amount received by any other candidates or the price customers pay for each candidate through Distro. Violation of this may cause immediate cancellation of the User Agreement. 

Candidate shall provide payment authorization to Distro prior to the start of User Agreement provided by Distro. Payment authorizations include partners such as Stripe, Wise, and Payoneer. Upon accepting a job offer from a Distro customer, candidate will be issued payment by the 5th of each month for work performed the prior month. 

Disclosing compensation or inquiring about compensation to the Client is solicitation. In the event that solicitation or circumvention have occurred, Distro may hold payments until an investigation is completed. 

Candidate is required to provide a thirty (30) day written notice to support@distro.io if they wish to stop working for the Client.

Distro, LLC Privacy Policy

Last modified: August 4, 2025

1. Introduction

Distro, LLC (“Distro“, “we“, “us” or “”our“) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our website (our “Website“), or any other services or offerings which may reference this Privacy Policy and our practices for collecting, using, maintaining, protecting, and disclosing that information and tells you about your privacy rights. By submitting information through our Website, you agree to the terms of this Privacy Policy, our Terms of Use as well as any other documentation referenced herein. If you do not agree you should discontinue use of the services immediately.

This policy applies to information we collect:

• On this Website.
• In email, SMS text, and other electronic messages between you and this Website.

Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by us or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

2. Information We Collect About You and How We Collect It

We collect the following types of information from and about users of our Website:

• That is about you but individually does not identify you; and/or
• By which you may be personally identified, such as name, e-mail address, age, mailing address, telephone number, username and password, or any other identifier by which you may be contacted online or offline (“personal information“);
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, referring URL, and information collected through cookies, pixel tags, web beacons, social media connectors and other tracking technologies, such as Google Analytics and Google Search Console.
• Directly from you when you provide it to us.
• From third parties, for example, our business partners.

3. Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at registration, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.
• Any other data not specifically listed above regarding your use of the Website.

You may also provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

4. Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• When accessing the Website through a mobile device, the type of mobile device, your IP address, mobile operating system, unique device identifiers and browser type you use, and other diagnostic data.

This information does not reveal your specific identity (like your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not sell your personal information to third parties. However, like many companies, we use services that may collect your information (to deliver advertisements to you for example) and this may classify this use as a “sale” of your personal information, you can request to opt-out here by submitting your request to support@distro.io.

The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

5. Information about Minors

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at supprt@distro.io. To learn about the Children’s Online Privacy Act (COPPA), please visit https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see your California Privacy Rights for more information.

6. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Distro does not control these third parties’ tracking technologies or how they may be used. Distro which pays for and authorizes this Website, is not responsible for the content or privacy policies of such third-party sites. When you access a third-party site through the links on this Website, the use of any information you provide is governed by the privacy policy of the operator of the third party site you are visiting. We encourage you to carefully review the privacy policies of any third party site you access so you know how they will use and share your information. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

7. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• For marketing and advertising purposes to be used by third party analytics providers.
• To respond to requests by government authorities, court orders and regulations, or to perform other reporting obligations as required by applicable law.
• To provide you with notices about your account, including expiration and renewal notices and manage your requests.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Website.
• 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 products and services is among the assets transferred.
• To deliver and facilitate delivery of services to you.
• To gather data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our products and services, marketing and your experience and create anonymous, aggregated data.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ services that may be of interest to you. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

8. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy.

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Distro’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Distro about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Distro, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

9. Retention of Your Information

• We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy unless otherwise required by law. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
• We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website or we are legally obligated to retain this data for longer time periods.

10. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by submitting a request to support@distro.io.
• Correspondence from Distro. If you do not wish to have your email address used by us to promote our own or third parties’ products or services, you can opt-out by submitting a request to support@distro.io or at any other time by sending us a request to support@distro.io. If we have sent you an email, you may send us a return email asking to be omitted from future email distributions with the option to unsubscribe. This opt out does not apply to information provided to Distro as a result of a prior transaction.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by submitting your request to support@distro.io.
• SMS Text Messaging. By opting into SMS text messages from Distro, you authorize us and our service providers to receive text messages using automated means. You can opt out anytime by replying “STOP” or contacting support@distro.io. Message and data rates may apply.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website http://www.networkadvertising.org/choices/.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to support@distro.io. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

11. Data Transfers

Distro is based in the United States. Depending on where you are located and the information provided to us, the information may be transferred to and maintained by us on servers located in the United States, which may not have the same data protection laws. However, we take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. By providing such information through the Website, you hereby expressly consent to such transfer and processing of your data into the United States.

To our European Union residents, it is sometimes necessary for us to share your personal information outside of the European Economic Area (“EEA“), as our offices are outside the EEA. The following circumstances may apply when these transfers are subject to special rules under European and UK data protection Law:

• With your and our service providers located outside the EEA;
• If you are based outside the EEA; or
• Where there is an international dimension to the services we are providing to you. 

We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. If you would like further information, please contact us or our Data Protection Officer (see “How to Contact Us” below).

12. Legal Basis for Processing Personal Data under General Data Protection Regulation (GDPR)

To our European residents, we may process Personal Data (any personal information that may that relates to or identifies you as an individual) under the following conditions:

• Consent: You have given your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
• 14.Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which Distro is subject.
• Vital Interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in Distro.
• Legitimate Interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Distro.

In any case, Distro will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

Distro undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. 

You have the right under this Privacy Policy, and by law if you are within the EEA, to:

• Request access to your Personal Data. The right to be provided with a copy of your personal information.
• Request rectification of the Personal Data. You have the right to correct any mistakes in your personal information.
• Object to processing of you Personal Data. The right to require us to restrict processing of your personal information – in certain circumstances, e.g. if you contest the accuracy of the data.
• Request restriction of your Personal Data. The right to require us to delete your personal information – in certain situations including processing your personal information for direct marketing purposes or automated processing of your personal information.
• Request the transfer of your Personal Data. The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.
• Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the services that we provide.

Exercising Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to lodge a complaint with a supervisory authority in the EEA where you work, normally live, or where any alleged infringement of data protection laws occured. For more information, please contact your local data protection authority in the EEA.

13. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us a request at support@distro.io to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or they might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

14. Your California 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, visit CCPA Privacy Notice for California Residents.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits our users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please submit your request in writing using the contact information provided below.

15. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology and third-party payment processors.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out such information to others.

Unfortunately, the transmission of information via the interest is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

16. Changes to Our Privacy Policy

We may update this privacy policy periodically. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we may notify you either by posting a prominent notice of such changes or by email to the email address specific in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to change for any changes.

17. How to Contact Us

If you have any questions or comments about this privacy policy and our privacy practices, contact us at support@distro.io.

Privacy Policy for California Residents

Updated: August 4, 2025

This Privacy Policy for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you“). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CRPA) and any terms defined in the CCPA and CPRA have the same meaning when used in this policy. For more information see https://oag.ca.gov/privacy/ccpa.

This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably by linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Billey Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

• Category: Identifiers.
  • Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers
    • Collected: Yes
• Category: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
    • Collected: Yes
• Category: Protected classification characteristics under California or federal law.
  • Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
    • Collected: No
• Category: Commercial information.
  • Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
    • Collected: No
• Category: Biometric information.
  • Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
    • Collected: No
• Category: Internet or other similar network activity.
  • Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
    • Collected: Yes
• Category: Geolocation data.
  • Examples: Physical location or movements.
    • Collected: No
• Category: Sensory data.
  • Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
    • Collected: No
• Category: Professional or employment-related information
  • Examples: Current or past job history or performance evaluations.
    • Collected: No
• Category: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  • Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student scheduled, student identification codes, student financial information, or student disciplinary records.
    • Collected: No
• Category: Inferences drawn from other personal information.
  • Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    • Collected: No

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing you actions on our website (“Website“).
• From Service providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that we use to provide the Service to you. 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
• To provide, support, personalize, and developer our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• 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 Site users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Distro has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding twelve (12) months, Distro has not sold personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights. 

Category of Third-Party Recipients

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. 

• Personal Information Category: Identifiers.
  • Business Purpose Disclosures: THIRD-PARTY RECIPIENTS
    • Sales: None
• Personal Information Category: California Customer Records personal information categories.
  • Business Purpose Disclosures: THIRD-PARTY RECIPIENTS
    • Sales: None
• Personal Information Category: Protected classification characteristics under California or federal law.
  • RightBusiness Purpose Disclosures: None
    • Sales: None
• Personal Information Category: Commercial information.
  • Business Purpose Disclosures: None
    • Sales: None
• Personal Information Category: Biometric information.
  • Business Purpose Disclosures: None
    • Sales: None
• Personal Information Category: Internet or other similar network activity.
  • Business Purpose Disclosures: THIRD-PARTY RECIPIENTS
    • Sales: None
• Personal Information Category: Geolocation data.
  • Business Purpose Disclosures: None
    • Sales: None
• Personal Information Category: Sensory data.
  • Business Purpose Disclosures: None
    • Sales: None
• Personal Information Category: Professional or employment-related information.
  • Business Purpose Disclosures: None
    • Sales: None
• Personal Information Category: Non-public education information.
  • Business Purpose Disclosures: None
    • Sales: None
• Personal Information Category: Inferences drawn from other personal information.
  • Business Purpose Disclosures: None
    • Sales: None

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you. 
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good of service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, 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 products 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.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by emailing us at support@distro.io.

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 also make a request to know or delete on behalf of your child by submitting a request via support@distro.io.

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

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
• 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.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within a reasonable business time frame. If you do not receive confirmation, please contact support@distro.io.

We endeavor to 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.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

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 useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a feee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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.

Right to Correct

You have the right to request that we correct any inaccurate personal information that we collected. Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies.

Right to Restrict Sensitive Personal Information

You have the right to request that we restrict the use or disclosure of your sensitive personal information to just actions necessary to perform specific purposes listed in the statute. Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. To perform services or provide goods that an average consumer requesting those goods or services would reasonably expect.
2. To help ensure security and integrity, if that use is reasonably necessary and proportionate.
3. To perform short-term, transient uses, including but not limited to non-personalized advertising shows as part of your current interaction with the business, if we do not:
   1. disclose the sensitive personal information to another third party; or
   2. use it to build a profile about the consumer or otherwise alter your experience outside their current interaction with our business.
4. To perform services for our business.
5. To perform other actions that CPRA regulations authorize.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time, including your personal information for cross-context behavioral advertising (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you may submit a request to support@distro.io.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. however, you may change your mind and opt back into personal information sales at any time by submitting a request to support@distro.io.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Website that sells personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform: http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interest:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOs devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services.

“Do Not Track” Policy

Our Website does not respond to Do Not Track signals.

However, some third-party Websites do keep track of your browsing activities. If you are visiting such Websites, you can set your preferences in your web browser to inform Websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Other California Privacy Rights

California Online Privacy Protection Act (“CalOPPA”) requires businesses operating in California or serving California residents to post a conspicuous privacy policy on its website stating the categories of personal information collected, purposes of collection, disclose those individuals or companies with whom it is being shared, and outline procedures for users to review and request changes to their personal information. Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the main page of the Website via a hyperlink and comply with the CCPA. You will be notified of any Privacy Policy changes on our Privacy Policy page. Additionally, users can change their personal information by contacting us at support@distro.io.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send a request via support@distro.io.

California Privacy Rights for Minor Users (California Business and Professions Code Section § 22581) allows California residents under the age of 18 who are registered users of online Websites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below and include the email address associated with your account. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Executed collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: support@distro.io.

If you need to access this Policy in an alternative format due to having a disability, please contact support@distro.io.