Terms of Service

Effective Date: August 8, 2026 · Version 1.0

These Terms of Service ("Terms") form a binding agreement between Ellis Intelligence LLC, a Colorado limited liability company doing business as DSAR Engine ("DSAR Engine", "we", "us", "our"), and the business subscribing to or using the Service ("Customer", "you"). The Service is for use by businesses managing their own consumer privacy requests. It is not a consumer product. Consumers who submit privacy requests through a Customer's intake page are data subjects whose requests the Customer fulfills — they are not parties to these Terms and are not customers of DSAR Engine.

1. The service

DSAR Engine is a software-as-a-service application that helps a company run its consumer privacy requests — access, deletion, opt-out, and correction requests under U.S. state privacy laws — end to end: intake, identity verification, fulfillment tracking, and closure, each on the applicable statutory clock, with a tamper-evident chain-of-custody record for every request. The Service includes a Customer-configurable public intake page, a request cockpit, per-jurisdiction deadline clocks and reminders, and a downloadable audit export.

Tier-specific features and limits (including request-volume bands) are described at the pricing page. Self-serve subscription tiers (Starter, Growth, Scale) serve mid-market companies managing their own consumer privacy requests.

Business use only. The Service is intended for use by businesses for their own internal privacy-operations purposes. It is not a consumer product.

DSAR Engine is not a law firm and does not provide legal advice. DSAR Engine is a software vendor providing request-tracking, identity-verification workflow, deadline-clock, reminder, and audit-record tooling, together with built-in response and verification templates. DSAR Engine does not:

• Provide legal advice or render compliance opinions
• Determine whether any consumer request is valid, exempt, or must be fulfilled
• Decide what any privacy law requires in your specific circumstances
• Guarantee that any request handling, timing decision, notice, or workflow satisfies any state privacy law
• Fulfill requests on your behalf, except where you or your staff direct and complete that step
• Represent you in any regulatory proceeding, investigation, or litigation

Your own staff review and fulfill every request; DSAR Engine keeps it on the clock and on the record. You remain solely responsible for your compliance with applicable privacy law — engage qualified counsel for legal advice specific to your circumstances.

2. Account

Account creation requires an authorized representative of the Customer entity. By creating an account you represent that you are authorized to manage the Customer's consumer privacy requests and that you have a lawful basis to process the consumer data you submit to or collect through the Service. Each seat is for a single named individual; multi-factor authentication is required; seat-sharing is prohibited.

3. Subscriptions, pricing, billing

Standard auto-renewing subscription with cancellation per §14. 30 days' notice for material pricing changes. Stripe (card) or invoice for Scale and annual tiers. State privacy laws, response deadlines, exemptions, and required-response content change — the per-jurisdiction rule content in the Service is informational and updated periodically; we do not guarantee that any seeded rule, deadline, or template reflects every current requirement at any given moment. You must independently verify that your use of the Service satisfies applicable law in each jurisdiction in which you receive consumer requests. Subscription fees are non-refundable for the current period; annual prepayments are refundable pro rata only on our material breach or on a regulatory withdrawal (§7).

4. Customer data; consumer data; roles

As between us, you own all data you submit or collect through the Service ("Customer Data"), including consumer request records, requester contact and verification data, fulfillment-step records, deadline and clock state, generated correspondence, and chain-of-custody event logs.

Controller / processor roles. With respect to the consumer data processed through the Service to receive, verify, track, and fulfill privacy requests, you are the controller (or "business") and we are the processor (or "service provider"), processing on your documented instructions. The consumers who submit requests are your data subjects, not ours.

The public intake page. The Service includes a Customer-configurable public intake page at which a consumer submits a privacy request and, where you enable it, completes identity verification. DSAR Engine hosts and renders that page and collects the information the consumer enters as your processor and on your behalf — the consumer's relationship is with you. You are responsible for the lawfulness of the requests you accept through that page and for the content of any Customer-configured copy, logo, or branding you apply to it.

Identity-verification data — minimization. The Service is designed to collect the minimum needed to verify a requester and deliver a response. We do not use Customer Data to train any model or improve a Service used by other customers. Each Customer is a single tenant; consumers who file requests are records within that tenant, not sub-tenants — the Service does not offer nested tenancy or full reseller white-label. The chain-of-custody event log is append-only and tamper-detected.

5. Acceptable use

Use is governed by the Acceptable Use Policy, including the DSAR Engine addendum covering the consumer-intake-page representations, the prohibition on collecting verification PII beyond what the chosen method requires, and the prohibition on using the Service for any request workflow you lack a lawful basis to process. No reverse engineering, no scraping, no building a competing product, no resale. The Service permits a per-tenant logo and accent color on the public intake page only (light white-label); it does not permit white-labeling the application itself or any reseller/sub-tenant rights. Your staff review and complete each fulfillment step — the Service tracks the deadline and logs each step; it does not gather, redact, or transmit consumer data on your behalf, and it does not decide whether a request is valid.

6. Privacy-law disclaimers and software behavior

Notice and response templates and per-state rule content are informational and may not reflect subsequent changes to any law — you are responsible for reviewing every output and every rule the Service surfaces before reliance.

No validity determination. The Service never renders a determination of a consumer request's validity. No code path emits "this request is valid / invalid" or "the law requires X." The Service surfaces the workflow stages (verify → gather → redact → fulfill → close); your staff decide at each stage — this is a deliberate software design choice and a core risk-management control.

No compliance guarantee. Deadline countdowns, reminders, rule flags, audit records, and any other Service artifacts are software-generated outputs to assist your privacy operations. They are not legal advice and not compliance opinions. DSAR Engine does not guarantee compliance with any specific law for any specific request. The tamper-evident audit export proves that the record of a request's handling was not altered — it does not certify that you are compliant with any law. You will not represent to any consumer, regulatory body, court, or third party that DSAR Engine is privacy counsel or a compliance advisor, and you will not represent that DSAR Engine "guarantees" compliance, "ensures" you "never miss a deadline" as an absolute guarantee, or is "set-and-forget."

7-9. Regulatory contingency, intellectual property & privacy

We operate subject to an evolving U.S. state privacy-law landscape and to FTC and state-attorney-general enforcement. If a regulatory body issues guidance or a rule that affects our lawful operation in a particular state or use case, we may modify, restrict, or withdraw the Service, with at least 30 days' notice and pro rata refund of prepaid fees for the withdrawn period. We own the Service, including the rule overlays, deadline-clock and reminder logic, identity-verification workflow, template compilations, and chain-of-custody architecture. Our Privacy Policy and Data Processing Addendum apply under standard triggers; where the DPA and these Terms conflict as to Customer Data processing, the DPA controls.

12-13. Warranties and limitation of liability

Except for the limited warranty that the Service performs substantially per documentation, the Service is provided "as is" and "as available." We disclaim all other warranties, express or implied, including merchantability, fitness for a particular purpose, non-infringement, and any warranty about rule currentness, deadline-calculation accuracy, template legal sufficiency, or compliance with any privacy law for any specific request.

To the maximum extent permitted by law, neither party will be liable for indirect, incidental, consequential, special, or punitive damages, and we will not be liable for any damages arising from a consumer request outcome, a regulatory action, or a claim by a consumer or data subject. Our total cumulative liability will not exceed the greater of the fees you paid us in the twelve months preceding the claim or USD $1,000.

Indemnification. Both indemnities — ours for IP infringement and yours — are stated in full on the face of the Order Form you accept when you subscribe to a paid tier, rendered above the agree control before your subscription completes. These Terms state no indemnification obligation separate from, additional to, or narrower than the Order Form, and nothing in these Terms enlarges or limits it.

14-15. Termination and general provisions

You may cancel anytime, effective end of the current period. We may terminate for material breach, AUP violation, or non-payment (30 days' notice with pro rata refund for discontinuation other than for cause). On termination or suspension, Customer Data enters read-only for 30 days for Customer-led export; open requests with running statutory clocks will be flagged, and you are responsible for managing those requests through other means. Customer Data is deleted within 30 days of termination unless retention is required by law, an active litigation hold, or export has been requested within that window.

Governing law. Colorado; the CISG does not apply. Disputes are resolved by binding arbitration via JAMS in Boulder County, Colorado, with a class-action waiver; either party may seek injunctive relief in court for breaches of the acceptable-use, no-counsel-representation/banned-representations, IP, or confidentiality provisions.