Protecting your private information is our priority. This Privacy Policy governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to DAASS include daass.com, other website(s) operated by us, any of our mobile applications (collectively the "Site") and DAASS LLC, its subsidiaries and affiliates ("DAASS," "We," or "Us").

The terms "You" or "Your" refer to You, the user(s) of the Site, regardless of whether you are a sole natural person, using the Site jointly with another person or people, or an entity.

DAASS is a learning platform focused on the Jewish community (the "Services"), though we reserve the right to change our business or the Services at any time at our sole discretion.

Collection of Your Personal Information

DAASS may collect personal information about you, including but not limited to your:

• Full Name
• Contact information (e.g., email, address, phone number)
• Date of Birth
• Any other information you voluntarily provide to us, including but not limited to information you provide while registering on the Site or informing us of your preferences.

Most personal information we collect is information you voluntarily provide to us. However, certain information (such as IP address, device identifiers, and usage data) may be collected automatically when you interact with the Site, as described in the "Automatically Collected Information" section below. You may be required to provide certain personal information when you elect to use the Services available on the Site, including when you: (a) register for an account on our Site; (b) enter information for a link sponsored by us or one of our partners; (c) sign up for special offers from selected third parties; (d) send us an email message; or (e) submit your credit card or other payment information for payment processing by a third party (e.g., without limitation, Stripe). We will use your information for, but not limited to, communicating with you in relation to your use of the Services. We also may gather additional personal or non-personal information in the future.

Sharing Information

DAASS may share data with trusted partners to help you use the Services, perform statistical analysis, send you email or postal mail, provide customer support, or otherwise optimize your use of the Services. We may learn more about your use of the Site and preferences using a variety of tools including but not limited to artificial intelligence and machine learning applications we may use at our sole discretion. We will make commercially reasonable efforts to ensure all third parties we associate with safeguard your personal information.

DAASS may disclose potentially personal information and personally-identifying information to its employees, contractors, and affiliated organizations that (i) need to know that information in order to process it on DAASS's behalf or to provide services available on the Site, and (ii) have agreed, to the best of our knowledge, not to disclose it to others. Some of those employees, contractors, and affiliated organizations may be located outside of your home country or jurisdiction; by using the Site, you consent to the transfer of such information to them.

DAASS may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on DAASS or the Site; (b) protect and defend the rights or property of DAASS; and/or (c) act under exigent circumstances to protect the personal safety of users of DAASS or the public.

Data Retention

We retain your personal information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. When personal information is no longer needed, we will take reasonable steps to delete or anonymize it. Specific retention periods vary based on the type of information and the purpose for which it was collected.

Tracking User Behavior

DAASS may, at its sole discretion, keep track of the websites and pages our users visit within DAASS, whether by desktop or mobile device, in order to determine what DAASS services are the most popular. This data is used to deliver customized content and advertising within DAASS to customers whose behavior indicates that they are interested in a particular subject area.

Automatically Collected Information

Information about your computer hardware, mobile devices, and software may be automatically collected by DAASS. This information can include: your IP address, browser type, domain names, access times, and referring website addresses. This information is used for the operation of the Service, to maintain quality of the Service, and to provide general statistics regarding use of the Site.

Use of Cookies

The DAASS website may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize DAASS pages or subdomains, register with DAASS, or use the Services, a cookie helps DAASS recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the Site, the information you previously provided can be retrieved, so you can easily use the DAASS features that you customized.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Site or the Services.

Third-party vendors may also use cookies to serve ads based on a user's past visits to our Site.

Web Beacons

We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.

Business Transfers

If DAASS undergoes a Change of Control (as defined herein), your personal information may become an asset of such a transaction. You acknowledge that such transfers may occur, and that any acquirer of DAASS may continue to use your personal information as set forth in this policy. As used herein, "Change of Control" means (i) a consolidation or merger of DAASS with or into any other corporation or other entity or person, or any other corporate reorganization, other than any such consolidation, merger, or reorganization in which the shares of capital stock of DAASS immediately prior to such consolidation, merger, or reorganization continue to represent a majority of the voting power of the surviving entity immediately after such consolidation, merger, or reorganization; (ii) any transaction or series of related transactions to which DAASS is a party in which in excess of 50% of DAASS's voting power is transferred; or (iii) the sale or transfer of all or substantially all of DAASS's assets, or the exclusive license of all or substantially all of DAASS's material intellectual property; provided that a Change of Control shall not include any transaction or series of transactions principally for bona fide equity financing purposes in which cash is received by DAASS or any successor, indebtedness of DAASS is cancelled or converted, or a combination thereof.

Links

The Site may contain links to other third-party sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our Site and to read the privacy policy of any other site that collects personally identifiable information.

Security of Your Personal Information

DAASS secures your personal information from unauthorized access, use, or disclosure. DAASS uses the following methods for this purpose:

• SSL Protocol

When personal information (such as name and date of birth) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

Minors

The Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without verifiable parental consent as required by the Children's Online Privacy Protection Act ("COPPA"). If we learn that we have collected personal information from a child under 13 without such consent, we will delete that information as soon as reasonably possible.

If you are a parent or legal guardian and you believe your child under 13 has provided personal information to us without your consent, please contact us at support@daass.com so that we can take appropriate action.

Minors between the ages of 13 and 18 (or the age of majority in their jurisdiction) may use the Site and the Services only with the consent and supervision of a parent or legal guardian. By enrolling a minor in our Services or allowing them to use the Site, you, as the parent or legal guardian, represent that you have the authority to consent on their behalf, consent to the collection, use, and disclosure of that minor's personal information as described in this Privacy Policy, and agree to be bound by this Privacy Policy on their behalf.

E-mail Communications

From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. You may opt out of such communication by contacting us.

SMS / Mobile Messaging Communications

DAASS LLC may communicate with you via SMS or MMS (collectively, "text messages") in connection with your use of the Services, including but not limited to responding to customer support inquiries, sales questions, account-related communications, and service updates. The following terms govern our collection, use, and protection of mobile phone numbers and related text messaging data.

Collection of Mobile Phone Numbers

We may collect your mobile phone number when you voluntarily provide it to us, including when you contact us directly via text message, initiate a conversation through our published contact channels, register for our Services, or otherwise share your number with us in the course of using the Services. You are not required to provide a mobile phone number to use the Site, but certain communications may only be available through this channel.

Consent to Receive Text Messages

By providing your mobile phone number to DAASS LLC or by initiating a text message conversation with us, you consent to receive text messages from us in response to your inquiries and in connection with the Services. Message frequency varies based on the nature of your conversation with us. Message and data rates may apply, depending on your mobile carrier and plan.

Opting Out and Help

You may opt out of receiving text messages from DAASS LLC at any time by replying "STOP" to any message you receive from us. Once you reply "STOP," you will receive a confirmation message and will not receive further text messages from us unless you opt back in. You may also reply "HELP" at any time to receive information on how to contact our support team.

No Sharing or Sale of Mobile Data

DAASS LLC will not share, sell, rent, lease, or otherwise transfer your mobile phone number, SMS opt-in data, or the content of any text message communications to any third party for marketing or promotional purposes. Mobile information collected for the purposes of SMS communications is used solely to facilitate communication between you and DAASS LLC in connection with your inquiries and the Services.

We may share mobile phone numbers with service providers that help us deliver text messaging services (for example, our telecommunications provider), solely for the purpose of operating the SMS channel on our behalf. These service providers are contractually restricted from using your information for any purpose other than providing those services to DAASS LLC, and may not share or sell such information to any other party.

Security of Mobile Information

DAASS LLC applies the same security measures described elsewhere in this Privacy Policy to the protection of mobile phone numbers and text message data. However, please be aware that the content of SMS messages is transmitted through mobile carrier networks, which are outside of our direct control, and that such transmissions may not be fully encrypted end-to-end.

Questions About Our Text Messaging Practices

If you have any questions about how DAASS LLC handles your mobile phone number or text message data, please contact us at support@daass.com or at the address listed in the Contact Information section of this Privacy Policy.

External Data Storage Sites

We may store your data on servers provided by third-party hosting vendors with whom we have contracted.

GDPR and Designated Countries Privacy Rights

This Section only applies to Users and Customers of the Services that are located in the European Economic Area, United Kingdom, and/or Switzerland (collectively, the "Designated Countries") at the time of data collection. We may ask you to identify which country you are located in when you use some of the Services, or we may rely on your IP address to identify which country you are located in. Where we rely only on your IP address, we cannot apply the terms of this Section to any User or Customer that masks or otherwise obfuscates their location information so as not to appear located in the Designated Countries. If any terms in this Section conflict with other terms contained in this Policy, the terms in this Section shall apply to Users and Customers in the Designated Countries.

DAASS is a data controller with regard to any personal information collected from customers or users of its Services. A "data controller" is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are "data processors" that handle your personal information in accordance with our instructions.

If you are located in the Designated Countries, you have the following rights with respect to your personal information, subject to applicable law:

• Right of access: You may request confirmation of whether we process your personal information and obtain a copy of it.
• Right to rectification: You may request that we correct inaccurate or incomplete personal information.
• Right to erasure ("right to be forgotten"): You may request that we delete your personal information in certain circumstances.
• Right to restrict processing: You may request that we limit how we process your personal information in certain circumstances.
• Right to data portability: Where processing is based on your consent or a contract and is carried out by automated means, you may request to receive your personal information in a structured, commonly used, and machine-readable format, and to have it transferred to another controller where technically feasible.
• Right to object: You may object to our processing of your personal information where we rely on consent, contract, or legitimate interests as our legal basis. We may continue processing if necessary for the defense of legal claims or as otherwise permitted by law.
• Right to withdraw consent: Where we rely on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.

Our legal bases for processing your personal information include your consent, the performance of a contract with you, compliance with legal obligations, and our legitimate interests in operating and improving the Services.

To exercise any of these rights, please contact us at the information provided in the Contact Information section. If you believe we have infringed your privacy rights, you have the right to lodge a complaint with a competent supervisory authority in the Member State of your habitual residence, place of work, or place of alleged infringement.

California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA)

The CCPA, as amended by the CPRA, provides California residents with specific rights regarding their personal information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

You have the right to request that DAASS disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, 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.
• The specific pieces of personal information we collected about you (also called a data portability request).
• 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.

Additional Rights Under the CPRA

In addition to the rights described above, California residents have the following rights under the California Privacy Rights Act:

• Right to correct: You have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to limit use of sensitive personal information: To the extent we collect or process sensitive personal information (as defined under the CPRA), you have the right to direct us to limit our use of that information to purposes necessary to provide the Services or as otherwise permitted by law.
• Right to opt out of sale or sharing: You have the right to opt out of the "sale" of your personal information or the "sharing" of your personal information for cross-context behavioral advertising purposes (as those terms are defined under the CPRA). DAASS does not sell your personal information, and does not share your personal information for cross-context behavioral advertising purposes.
• Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

CCPA Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and make reasonable efforts to direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or 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.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
• 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.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at support@daass.com or sending a letter to the contact information listed below.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Changes to This Statement

We reserve the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our Site, and/or by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

DAASS welcomes your questions or comments regarding this Privacy Policy. If you believe that DAASS has not adhered to the protocols herein, please contact us at:

DAASS LLC 

18 Spencer St., STE 10D 

Brooklyn, NY 11205 

support@daass.com

Effective as of April, 2026