Privacy Policy

01Who we are

Ostrel Software LLC is a Washington limited liability company located at 522 W Riverside Ave, Ste N, Spokane, WA 99201 ("Lynqly," "we," "us," or "our"). We operate the Lynqly website at lynqly.com, the Lynqly mobile app, and the services described in our Terms of Service (together, the "Services").

Our main product is the Lynqly App Builder. You describe your business, an AI plans and builds a working app (pages, sign-ups, saved data, emails, texts, payments and more), and we host it for you. We also offer our Domain Finder and Domain Radar domain intelligence products, and domain name registration through our registrar partner, NameSilo, LLC.

02Privacy at a glance

• We keep your Lynqly account and projects private by default. Apps you publish are public websites, so anything you publish is visible to anyone.
• Two roles. For your Lynqly account, we decide how your data is used (we are the "controller"). For the data your customers put into the apps you build, you decide, and we process it on your behalf (we are a "processor" or "service provider").
• AI vendors. Your descriptions, plans and build requests are sent to AI companies so the Services can work. We list those companies below.
• We do not sell your personal information for money. We do share limited data with Google and Microsoft to measure our own ads. Some privacy laws call that "sharing," and you can opt out.
• You can take your app and leave. You can export your app and its data, and you can ask us to delete your account.

03How this policy applies

This Privacy Policy explains what information we collect, how we use it, who we share it with, how long we keep it, and the rights and choices you have. It applies to:

• Visitors to lynqly.com and anyone who uses our Services without an account, including people who start planning an app before signing up;
• Account holders, including people who build apps with Lynqly ("App Owners" or "Owners") and people who use Domain Finder or Domain Radar;
• Teammates that an App Owner invites into their app's back office; and
• End Users: people who visit or use an app that an App Owner built and hosts on Lynqly (for example, a salon's customers who book through the salon's app). The section "Our Two Roles" explains how this policy applies to End Users.

In this policy, "App" means a website or application built or hosted with the Lynqly App Builder, and "Customer Data" means the information that End Users and App Owners store in or send through an App (such as form submissions, member accounts, bookings, orders and messages). Other capitalized words not defined here have the meanings given in our Terms of Service.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. Your use of the Services is governed by our Terms of Service, which incorporates this Privacy Policy.

04Our two roles: controller and processor

When Lynqly Is the Controller

Lynqly is the controller (and, under U.S. state privacy laws, the "business") for personal information about visitors to lynqly.com, account holders, App Owners, people who use Domain Finder or Domain Radar, people who register domains through us, and people who contact us. Most of this policy describes that information.

When Lynqly Processes Data on an App Owner's Behalf

When an App Owner builds an App with Lynqly, the App Owner is the controller of the Customer Data in that App, and Lynqly is its processor or service provider. That means:

• The App Owner decides what the App collects, why, who can see it, and how long it is kept.
• We store, process and transmit Customer Data to host and run the App and to provide the Services to the App Owner, on the App Owner's instructions and under our Terms of Service.
• We do not sell Customer Data, and we do not use it to advertise to End Users or to build profiles about them.
• We do not send the contents of an App's records to our build AI. When an App Owner asks for a change, the build AI sees the App's pages, logic and data structure (such as field names and record counts), not the End Users' records.

We also use limited Customer Data for our own legitimate purposes as a controller where the law allows: to keep the Services secure, prevent fraud, spam and abuse, enforce our Terms, meet legal obligations, deliver and troubleshoot messages, and produce aggregated, de-identified statistics about how the Services perform.

If You Are an End User of an App Built on Lynqly

If you use an App built on Lynqly, the business that runs that App is responsible for your information. Please read that business's privacy notice, and contact that business directly to access, correct, delete or export your data, or to stop receiving its messages. Lynqly does not decide what information an App collects or how the App Owner uses it.

How We Handle Requests From End Users

If we receive a privacy request from an End User about an App:

1. We will tell the requester that the App Owner is responsible for the request and, where we can identify the App, give them a way to reach the App Owner;
2. Where we can identify the App Owner, we may forward the request to them;
3. We will help App Owners respond to requests about Customer Data as described in our Terms of Service; and
4. We will act on our own only where the law requires us to, where the request concerns data we control ourselves (for example, our own security logs), or where we receive a valid legal order.

App Owners can view, edit, export and delete their App's records from the Data tab and the App's back office, can suspend an End User's member account, and can contact us at privacy@lynqly.com for help with a request we can fulfill for them.

What App Owners Are Responsible For

If you build an App with Lynqly, you are responsible for the Customer Data your App collects, including:

• Publishing your own privacy notice for your App and telling your End Users what you collect, why, and who receives it (including the vendors listed in this policy that process data for your App);
• Having a lawful basis, and any consent the law requires, for the data you collect and the messages you send. This includes consent for text messages under the Telephone Consumer Protection Act and similar laws, and unsubscribe options for marketing email under CAN-SPAM and similar laws;
• Telling your End Users when they are interacting with AI features in your App where the law requires it;
• Choosing who can read each collection. Collections are private to you by default, and if you set one to be readable by "everyone," anyone on the internet can see it;
• Deciding who you invite as teammates, and what they can see;
• Responding to your End Users' privacy requests;
• Not collecting sensitive information that the Services are not designed for, such as payment card numbers (use the built-in Stripe payments instead), government ID numbers, protected health information subject to HIPAA, consumer health data regulated by laws such as Washington's My Health My Data Act, or information from children (see "Children's Privacy"); and
• Protecting any Customer Data you export from Lynqly. Once you export it, you alone are responsible for that copy.

05Information we collect

We collect information you give us, information collected automatically when you use the Services, and information from third parties.

Account and Registration Information

• Account creation: your email address, and your name and password if you choose to set them. Lynqly accounts sign in with a password or a one-time sign-in link or code sent to your email. We store passwords only as one-way hashes.
• Profile and settings: optional profile details, notification preferences, and marketing email preferences.
• Consent records: when you accept our Terms of Service and this Privacy Policy, we record which versions you accepted, the date and time, your IP address and your browser's user agent.

Planning Before You Create an Account

You can start describing and planning an App before you create an account. When you do, we create a temporary anonymous session and store what you type, the AI planning conversation, and any draft App, linked to a random session identifier kept in your browser or device. We also keep a random device identifier, and use your IP address, to prevent abuse and to limit free usage. If you later create or sign in to an account, we move that work into your account.

App Builder Content

When you use the App Builder, we collect and store:

• Descriptions and plans: what you tell us about your business and the App you want, your answers to the planner's questions, the resulting plan and checklist, and any quote;
• Build requests and conversations: the changes you ask for, messages you send while a build is running, answers to clarifying questions, and the AI's replies;
• Photos and media you upload: for example, a photo of a menu or storefront you attach to a plan, or images, logos and videos you add to your App. Uploaded images and videos are stored at public web addresses so they can appear on your App;
• Your App itself: its pages, text, design, brand choices, logic, data structure, settings, integrations you configure, and its version history;
• Build records: for each build, the request, what was delivered, a summary, a receipt, progress events, and how much it cost;
• Build memory: notes our build AI keeps about your App and your preferences so later builds stay consistent, plus saved transcripts of AI build sessions so work can resume;
• AI-generated material: content the AI writes for you, such as copy, brand names and palettes, page titles and descriptions, share images, suggested next features, and generated images;
• Delivery reports: for fixed-price builds, an automated checker opens the draft of your App with a test account and test data, and records screenshots, a checklist and, where available, a narrated video walkthrough; and
• Third-party credentials: where offered, API keys or other secrets you enter so your App can connect to other services, and, if you use the Mobile App add-on, the Apple or Google developer credentials you provide. We store these encrypted and do not display them back after you save them, other than the last few characters so you can recognize them.

Voice Input

Where our apps offer voice input (for example, "hold to talk" in the Lynqly mobile app), your voice is streamed to our speech-to-text provider, Deepgram, which returns a transcript. Lynqly does not store the audio recording. We keep the transcript as part of your description, plan or request. We do not use voice input to identify you or to create a voiceprint. Some voice features use your phone's built-in dictation instead, which Apple or Google provide under their own privacy terms.

Customer Data in Apps You Build

When your App runs, we store and process Customer Data on your behalf, which can include:

• Records your App collects, such as form submissions, bookings, orders, messages and anything else your App's collections hold. We do not store the End User's IP address or browser details on these records;
• Member accounts, if your App lets people sign up: email address, password hash, role, status, profile fields (such as phone number), last sign-in time and failed sign-in attempts, and session and verification tokens (stored as hashes), including text-message sign-in codes where two-step sign-in is used;
• Messages your App sends by email, text message or push notification, including recipients and contents, and replies that End Users send back to your App's text messages;
• In-app AI inputs: if your App includes AI features, the text and values those features send to AI vendors (see "How We Use AI");
• Payments: records of payments your App takes through your own Stripe account, such as amounts, fees and payment identifiers (the buyer's card details stay with Stripe);
• Push notification tokens for devices that opt in to your App's notifications, where offered;
• Activity logs: a record of what your App's automations did and when. We write these logs without field values, recipients or message contents; and
• Test data: messages your App would send from its draft version are recorded instead of delivered, so you can check them. Messages sent while people use an "invite testers" link are delivered.

Domain Finder and Domain Radar Information

• Project briefs: project descriptions, business information, target market details and other content you provide.
• Domain preferences: TLD preferences, industry focus, budget and other parameters you set.
• Decision activity: domains you track, lock, pass or analyze.
• Search and query data: search terms, filters and refinements.

Transaction and Billing Information

• Purchases: what you bought (for example, a Project Pass, a domain registration, an App plan, an add-on, a fixed-price build, or build funds), the date, amount and status.
• Build balance: your prepaid balance, top-ups, debits for builds and in-app AI use, credits, refunds, discounts, rewards points and referral activity.
• Payment methods: payments are processed by Stripe, or by Apple or Google for purchases made in the Lynqly mobile app through the app stores. We receive a payment reference, the card brand and last four digits, and similar details, not your full card number. If you save a card for automatic top-ups, Stripe stores it and we keep a reference to it and your top-up settings.
• Lynqly Payments: if you connect your own Stripe account so your App can take payments, we receive your connected account identifier, its status, and records of the payments and fees processed through it. When you accept our payment terms, we record the terms version, the fee rate you accepted, your IP address and the time.
• Refunds and disputes: information you give us in a refund request, and information from payment processors or app stores about refunds and chargebacks.

Technical and Usage Information

We automatically collect:

• Usage data: pages viewed, features used, clicks, navigation paths, and timestamps;
• Device information: device type, operating system, browser type and version, screen size and device identifiers;
• Location information: your IP address, which we may use to infer your approximate city, region, country and time zone. We do not ask for your device's precise location, but photos you upload may contain location details in their file data;
• Log data: access times, requests, errors and referring pages;
• Marketing attribution: how you arrived at our site, such as campaign tags and ad click identifiers from Google, Microsoft or Meta links; and
• Cookie and local storage data: see "Cookies and Similar Technologies."

Security and Fraud-Prevention Information

To protect the Services and our free offerings from abuse, we collect and assess signals such as your IP address and its network provider, whether it appears to belong to a VPN or data center, whether your email address uses a disposable email service, a browser fingerprint calculated in your browser, a technical fingerprint of your connection, and a fingerprint of your payment card provided by Stripe. We also use Cloudflare Turnstile to check that a visitor is not a bot.

Information From Other Users and Third Parties

• Referrals: if someone refers you, we record the referral link and connect it to your account.
• Invitations: if an App Owner invites you as a teammate, or someone shares a project with you, we receive your email address from them.
• Payment processors and app stores: payment confirmations, refunds, chargebacks and fraud signals from Stripe, Apple and Google.
• Advertising platforms: click identifiers that show which ad you clicked.
• Services you connect: information from services you or your App connect to, such as data received through your App's webhooks, or content from another platform you ask us to import.
• Public and commercial sources: information about domain names, such as availability, registration records and market data, that we use in Domain Finder and Domain Radar.

Communications With Us

We keep the content of your support requests, emails, feedback and survey responses, and our replies.

Optional Information

You can choose not to give us certain information, but that may limit which features you can use.

06How we use information

We use the information we collect to:

Provide the Services

• Plan, build, host, publish and run your Apps, including sending your App's emails, texts and notifications and running its automations;
• Produce domain suggestions, availability scans, rankings and reports in Domain Finder and Domain Radar, and register and connect domains you buy through us;
• Create and secure your account, sign you in, and move you between devices, for example from our mobile website into the Lynqly mobile app;
• Process payments, top-ups, automatic top-ups you turn on, subscriptions, refunds, rewards and referrals, and show you receipts and usage;
• Verify fixed-price builds and produce delivery reports;
• Export your App and its data when you ask; and
• Provide customer support.

Communicate With You

• Send service messages, such as sign-in links, receipts, build updates, questions from the AI during a build, low-balance and payment notices, security alerts, and changes to our Terms or this policy;
• Send push notifications to the Lynqly mobile app if you allow them; and
• With your consent where required, send marketing emails about our products. You can unsubscribe at any time.

Improve the Services

• Understand how the Services are used, fix problems, and test new features, designs and prices. When we test prices, the price you see at checkout is the price you pay;
• Evaluate and improve the quality of our AI planning, building, domain generation and ranking, for example by reviewing results and comparing prompts or vendors; and
• Create aggregated or de-identified statistics.

Keep the Services Safe and Lawful

• Automated screening: we automatically screen planning and build requests for clearly prohibited content (such as child sexual abuse material, malware or phishing). Some requests are blocked with an explanation. Others may be flagged for review by our staff without notice to you, and we may review the related App. If you believe a request was blocked by mistake, contact support@lynqly.com and a person will review it;
• Fixed-price scope checks: for fixed-price builds, an automated check compares messages you send during the build against the agreed plan to decide whether a request is a refinement or new work. You can ask a person to review that decision by contacting support@lynqly.com;
• Detect and prevent fraud, abuse of free offerings, spam, and security incidents;
• Enforce our Terms and respond to legal requests; and
• Keep records required by law, such as tax and payment records.

Advertising

We use limited information to measure and improve our own advertising on Google and Microsoft (see "Advertising Partners" below). We do not use Customer Data for advertising.

Aggregated and De-Identified Data

We may aggregate or de-identify information so that it can no longer reasonably be linked to you or your device, and use it for any lawful purpose, such as research, benchmarking and improving the Services. We will not attempt to re-identify it, and we require anyone we share it with to do the same.

07How we use AI and which AI vendors receive your data

The Services rely on AI models provided by other companies. To plan, build and run Apps and to generate domain ideas, we send the information described below to these vendors, who process it to return a result to us. We do not show vendor or model names in the product because we change them over time, but we list the companies here.

Training. Lynqly does not use your App Builder content, your Domain Finder projects, or Customer Data to train AI models. If that ever changes, we will update this policy first and ask for your consent where the law requires it.

Vendor retention. These vendors process data under their own terms with us. Some vendors' terms allow them to keep data for a limited time, for example to monitor for abuse, and some allow them to use data to improve their services unless that use is switched off. Requests routed through OpenRouter may be served by different model-hosting companies. Please do not put information into prompts, build requests or in-app AI features that you would not want a vendor to process.

In-app AI features. If an App Owner adds AI features to an App, End User input used by that feature is sent to the AI vendors above so the feature can work. The App's activity logs and AI usage records note the cost, level and outcome of each call, not the End User's text. App Owners are responsible for telling their End Users about these features.

AI output. AI output can be wrong or incomplete. See our Terms of Service for the rules that apply to AI-generated content.

08How this information is shared

Information That Is Shared Publicly

Your Lynqly account and projects are private by default. Some things become public because of what you choose to do:

• Published Apps: when you publish an App, its pages and anything else you publish are public on the internet, at a lynqly.com address or your own domain.
• Public collections: if you set a collection in your App to be readable by "everyone," anyone can read its records.
• Uploaded and generated media: images and videos you upload to your App, and images generated for it, are stored at public web addresses so your App can show them.
• Preview, tester and share links: anyone who has a draft preview link, an "invite testers" link, or a Domain Finder public share link can open what that link shows until it expires or you revoke it.
• Free-plan badge: Apps on the free plan show a "Made with Lynqly" badge. If a free App has used its monthly allowance, visitors who try to send a form see a message that it cannot be sent right now; that message does not mention your plan or your usage.

Information That Is NOT Shared Publicly

We do not publicly display or reveal to other users, without your permission:

• Payment information, billing details and your build balance
• Passwords, sign-in links and codes, and other credentials
• IP addresses and device identifiers
• Your email address and phone number
• Your App's unpublished drafts, plans, build conversations and build memory
• Customer Data in collections you have not made public
• Third-party credentials you save
• Private Domain Finder project briefs, domain selections, analysis and decisions
• Communications with customer support
• Usage and behavior data

Information You Choose to Share With Others (User-Initiated Sharing)

Project Sharing Features:

Lynqly provides features that allow you to voluntarily share your project results, domain intelligence, and analysis with specific individuals you choose. This sharing is entirely optional and controlled by you.

What You Can Share:

Through our sharing features, you can grant others access to:

• Your project briefs and business descriptions
• Domain name suggestions generated for your project
• AI analysis, rankings, and scores -Brand analysis dossiers
• Decision tracking (domains you've tracked, locked, or passed)
• Any other project-related content you created

How Sharing Works:

1. Invite by Email: You enter email addresses of people you want to invite; we send them an invitation link
2. Shareable Links: You generate a shareable link with access permissions you configure
3. Access Management: You control who has access and can revoke access through your account settings

Who Can See Your Shared Information:

• Only people you explicitly invite or share links with can access your shared projects
• We do not make your projects public - they are only accessible to recipients you authorize
• Recipients can view, copy, screenshot, or download information from shared projects during the period they have access
• Revoking access prevents future access but does not erase information already viewed or copied

Your Responsibility:

When you use sharing features, you are responsible for:

1. Vetting Recipients: Ensuring you trust the people you invite and that sharing with them is appropriate
2. Confidentiality Risks: Understanding that sharing reduces confidentiality and creates risks of information misuse
3. Data Privacy Compliance: If you share projects containing personal information of others (team members, collaborators), you must comply with applicable privacy laws and obtain necessary consents
4. Consequences of Sharing: Any consequences of your sharing decisions, including theft of ideas, competitive disadvantage, or confidentiality loss

What We Do NOT Do:

• We do NOT review, approve, or monitor who you share with
• We do NOT impose confidentiality obligations on recipients
• We do NOT control how recipients use or further share information you give them access to
• We do NOT mediate disputes between you and recipients

Recipients' Data:

When you invite someone via email:

• We collect their email address to send the invitation
• We create a temporary access token for their access
• We do not create accounts for them unless they separately register
• Their viewing activity may be logged for security purposes
• We do not share information about your recipients with third parties except as required by law

Shared Project Access Logs:

We maintain logs of who accessed shared projects for security and account management purposes. Access logs may include:

• Email addresses of invited recipients
• Access timestamps
• IP addresses of access (for security)
• Actions taken (viewed, copied link, etc.)

Privacy Recommendation:

🔴 IMPORTANT: Sharing exposes your information to others. Consider privacy implications before sharing projects containing:

• Sensitive business strategies
• Confidential domain ideas that could be registered by recipients
• Personal information of team members or collaborators
• Trade secrets or proprietary information

Your sharing decisions are irreversible in practice - once information is viewed, it cannot be "unshared."

Information Shared With Third-Party Service Providers

We share information with service providers that help us run the Services. Except as described in "Vendor retention" and "Advertising Partners," they may use it only to provide services to us. Our current providers include:

Service provider requirements. Except as described in "Vendor retention" and "Advertising Partners," we require our service providers to use personal information only to provide services to us, to protect it with reasonable security, and to comply with applicable data protection laws. When they process Customer Data, they act as our subprocessors in providing the Services to App Owners.

Advertising Partners. We use Google Analytics on lynqly.com. When you arrive from one of our ads and then sign up or buy something, we send Google Ads or Microsoft Advertising the ad click identifier, the conversion time and value, and a one-way hashed version of your email address so they can match the conversion to the ad. We may also use the Microsoft Advertising tag on our site to measure visits and build audiences for our ads. Under some U.S. state laws this may count as "sharing" personal information for cross-context behavioral advertising. See "Your Rights and Choices" to opt out.

Information Shared With Domain Registrar (NameSilo, LLC)

Domain Registration Through Authorized Reseller Partnership:

Lynqly facilitates domain name registration through our authorized reseller partnership with NameSilo, LLC (https://www.namesilo.com), an ICANN-accredited domain registrar. When you register a domain through Lynqly:

Registration Data We Collect and Transmit:

We collect and transmit the following domain registration information to NameSilo, LLC (the "Sponsoring Registrar"), applicable TLD registry operators, and other required parties:

• Registrant Contact Information: Full legal name (individual or organization), organization name (if applicable), complete mailing address (street, city, state/province, postal code, country), email address, phone number (with country code)
• Administrative Contact Information: Name, address, email, phone number (may be same as registrant contact)
• Technical Contact Information: Name, address, email, phone number (may be same as registrant contact)
• Billing Contact Information: Name, billing address for transaction records
• Domain Selection Data: The domain name(s) you wish to register, TLD selection, registration period
• Account Identifiers: Your Lynqly account ID correlated with your domain registrations
• Transaction Data: Registration date, expiration date, renewal status, auto-renewal preferences
• Authorization Data: Confirmation of your agreement to registrar terms and ICANN policies

Recipients of Your Domain Registration Data:

When you register a domain through our Services, your registration data is shared with:

1. NameSilo, LLC (Sponsoring Registrar)

   • Purpose: Process, maintain, and administer your domain registration
   • Data Received: Complete registration contact information, domain selection, transaction details
   • Privacy Policy: https://www.namesilo.com/support/privacy-policy
   • Legal Basis: Contractual necessity to provide domain registration services

2. TLD Registry Operators (e.g., Verisign for .com, Public Interest Registry for .org, etc.)

   • Purpose: Create and maintain domain registration in registry database
   • Data Received: Registrant and contact data as required by registry-registrar agreements
   • Legal Basis: Contractual necessity and regulatory compliance (ICANN requirements)

3. ICANN (Internet Corporation for Assigned Names and Numbers)

   • Purpose: Regulatory oversight, compliance monitoring, policy enforcement
   • Data Received: Registration data as required by ICANN accreditation agreements
   • Legal Basis: Regulatory compliance

4. ICANN-Designated Escrow Providers

   • Purpose: Data protection and continuity (registrar failure scenarios)
   • Data Received: Complete registration data for escrow/backup purposes
   • Legal Basis: Regulatory compliance (ICANN requirement)

5. WHOIS Privacy Service Provider (PrivacyGuardian.org or NameSilo-designated provider)

   • Purpose: Provide WHOIS privacy/proxy services where supported by TLD
   • Data Received: Your actual registration contact information (replaced in public WHOIS with privacy service contact information)
   • Legal Basis: Contractual necessity to provide requested privacy service
   • Note: Privacy service availability varies by TLD; some TLDs prohibit privacy services

6. Public WHOIS/RDDS Database

   • Purpose: Public directory service required by ICANN policy
   • Data Disclosed:
     • Without WHOIS Privacy: Your registrant name, organization (if applicable), mailing address, email,phone number, and domain registration/expiration dates are publicly accessible
     • With WHOIS Privacy: Privacy service contact information is displayed instead of your actual contact details (where supported by TLD)
   • Legal Basis: Regulatory compliance (ICANN WHOIS/RDDS requirements)
   • Access: Publicly accessible via WHOIS lookup services at https://www.internic.net/whois.html and other WHOIS providers

7. Third-Party Requesters (Under Specific Circumstances)

   • Purpose: Legal process, dispute resolution, law enforcement, abuse prevention
   • Data Disclosed: Registration data may be disclosed to:
     • Law enforcement agencies with valid legal process
     • Parties with court orders or subpoenas
     • UDRP complainants in domain dispute proceedings
     • Registry operators investigating abuse
     • ICANN compliance staff
   • Legal Basis: Legal obligation, contractual necessity (ICANN/registry policies)

WHOIS Privacy Service Details:

When WHOIS privacy is available for your TLD and enabled with your domain registration:

• How It Works: PrivacyGuardian.org (or designated privacy provider) replaces your public WHOIS contact information with privacy service contact details

• What's Protected: Your name, postal address, email address, and phone number are hidden from public WHOIS lookups

• What's NOT Protected:

  • Organization name may still be visible for some TLDs
  • Your actual registration data remains on file with NameSilo and the registry
  • Registry operators and ICANN can access your actual data
  • Your data may be disclosed under legal process or dispute resolution proceedings

• TLD Restrictions: WHOIS privacy is NOT available for domains registered in certain TLDs including but not limited to:

  • .us (requires U.S. presence; prohibits proxies for U.S. registrants)
  • .eu (requires European Economic Area presence verification)
  • .ca (prohibited for Canadian registrants under CIRA policy)
  • .in (prohibited by .IN registry)
  • .co.uk and other Nominet TLDs (limited privacy options)
  • .tickets, .healthcare, and other highly-regulated TLDs
  • Various country-code TLDs (ccTLDs) with local restrictions

• Privacy Service Limitations: WHOIS privacy may be suspended or disabled when:

  • Required by valid court order or legal process
  • Requested by ICANN for policy compliance investigation
  • Required by registry operator for abuse investigation
  • Needed to resolve a UDRP or other domain dispute
  • Your TLD registry changes privacy policies

ICANN Requirements and Your Consent:

By registering a domain through Lynqly, you acknowledge and consent to the following as required by ICANN policies:

1. Accurate Data Obligation: You must provide accurate, complete, and current contact information and update it within seven (7) days of any changes. Willfully providing false information may result in domain suspension or cancellation.

2. Data Processing Consent: You consent to the processing of your registration data by:

   • The Sponsoring Registrar (NameSilo, LLC)
   • The applicable TLD registry operator
   • ICANN and ICANN-designated parties
   • Escrow providers for data protection purposes
   • Privacy service providers (if privacy service is enabled)
   • WHOIS database administrators and public access

3. WHOIS Publication Consent: You consent to publication of your registration data in WHOIS/RDDS databases as required by ICANN policy, unless WHOIS privacy is available for your TLD and enabled.

4. Purpose of Data Processing: Your registration data is processed for purposes including:

   • Domain name registration and maintenance
   • Generating WHOIS/RDDS records for public access
   • Compliance with ICANN policies and registry requirements
   • Facilitating domain transfers between registrars
   • Resolving domain disputes (UDRP and similar proceedings)
   • Investigating and preventing abuse, fraud, and policy violations
   • Law enforcement and legal compliance
   • Communication regarding domain status, renewals, and policy matters

5. Recipients of Data: You acknowledge that your data will be accessible to the parties listed above and may be accessed by anyone who performs a WHOIS lookup (unless privacy service is enabled and supported).

6. International Data Transfers: You acknowledge that your registration data will be transferred internationally to:

   • NameSilo's servers in the United States
   • Registry operator servers (locations vary by TLD)
   • ICANN's systems and designated escrow providers
   • WHOIS database systems accessible globally

7. Data Retention: Your registration data will be retained:

   • By NameSilo for the duration of your domain registration plus retention periods required by ICANN (currently minimum 2 years after registration expiration or deletion)
   • By registry operators per their retention policies and ICANN requirements
   • By ICANN and escrow providers per regulatory requirements
   • In WHOIS history databases and archives potentially indefinitely

Your Rights Regarding Domain Registration Data:

• Access: You can access your registration data through your Lynqly account, WHOIS lookup, or by contacting NameSilo
• Correction: You must correct inaccurate registration data through your account or by contacting Lynqly or NameSilo
• Limited Deletion: Registration data generally cannot be deleted while domain is active (ICANN requirement); data is retained even after domain expiration per ICANN policies
• WHOIS Privacy: You can enable/disable WHOIS privacy where supported (included free with domain registrations through Lynqly)
• Complaints: You may file complaints regarding data processing with:
  • Names Il's privacy team: privacy@namesilo.com
  • ICANN: https://www.icann.org/resources/pages/complaints-2012-02-25-en
  • Your local data protection authority (for EU/EEA residents)

Data Processing Agreements:

By registering a domain through Lynqly, you acknowledge that:

1. Your registration data will be processed by NameSilo in accordance with their privacy policy: https://www.namesilo.com/support/privacy-policy

2. Registry operators will process your data according to their agreements with ICANN and registrars

3. ICANN policies govern registration data collection, use, and disclosure, including:

   • Registration Data Access Protocol (RDAP)
   • Temporary Specification for gTLD Registration Data (as applicable)
   • Consensus policies regarding WHOIS and data protection

4. You have reviewed, or had the opportunity to review, NameSilo's privacy policy and registration agreement before completing domain registration

5. You consent to this data processing and international transfer as necessary to provide domain registration services

Updates to Registration Data Practices:

ICANN policies regarding registration data handling are evolving. Notable recent developments:

• ICANN Registration Data Policy (effective August 21, 2025): Replaces previous WHOIS requirements with updated registration data processing framework
• RDAP (Registration Data Access Protocol): Replacing legacy WHOIS protocol for registration data access
• Evolving Privacy Frameworks: ICANN continues adapting policies to balance WHOIS transparency with data protection laws (GDPR, etc.)

We will update this Privacy Policy to reflect material changes to registration data handling requirements.

Questions About Domain Registration Data Processing:

• Lynqly Privacy Questions: privacy@lynqly.com
• NameSilo Privacy Questions: privacy@namesilo.com or https://www.namesilo.com/support
• ICANN Information: https://www.icann.org/privacy
• WHOIS Lookup: https://www.internic.net/whois.html

Information Shared to Protect Lynqly and Comply With Law

We may access, preserve and disclose information, including Customer Data, when we believe in good faith that doing so is reasonably necessary to:

• Legal compliance: comply with applicable law, regulation, legal process or governmental request;
• Law enforcement: respond to valid requests from law enforcement or government authorities;
• Enforce our Terms: enforce our Terms of Service, investigate possible violations, or protect our rights and property;
• Protect safety: protect the safety, security, rights or property of Lynqly, our users, End Users or the public;
• Prevent fraud: detect, prevent or address fraud, security or technical issues; or
• Corporate transactions: carry out a merger, acquisition, financing, bankruptcy, reorganization or sale of assets, in which case we will require the recipient to honor this Privacy Policy.

Where we receive a legal demand for Customer Data, we will try to redirect it to the App Owner and, where the law allows, notify the App Owner before disclosing it. We will make reasonable efforts to notify you of disclosures about you unless the law or a court order prohibits it.

Information Shared at Your Direction

We share information when you tell us to, including when:

• Your App sends data out: your App sends emails, texts, notifications or webhook calls, or connects to other services you configure. Those services receive the data you set your App to send, under their own terms;
• You take payments: your App's buyers pay through your own Stripe account, and Stripe processes their information as your payment processor;
• You publish to the app stores: if you use the Mobile App add-on, we use the developer credentials you provide to submit and manage your store apps with Apple and Google;
• You invite others: teammates you invite can see the parts of your App's back office you choose to share with them, including Customer Data in those areas;
• You export your App: the export file contains your App and its Customer Data, including End Users' email addresses and profile details. It includes member password hashes only if you choose to include them and accept responsibility for protecting them. We deliver the export as a one-time link sent to your account email and, if you confirm your password, also shown in the editor;
• You import from another platform: where we offer imports on request, you give our automation account access to your app on that platform so we can copy it into Lynqly; and
• You share projects or links: see "Information You Choose to Share With Others."

Links to Other Websites and Services

The Services link to other websites and services whose privacy practices differ from ours. Their own privacy policies govern your use of them, and we are not responsible for their practices.

09Data retention

We keep personal information for as long as we need it for the purposes in this policy, unless the law requires or allows us to keep it longer. Specifically:

Deleting an App. An App you move to Trash can be restored for 30 days and is then permanently deleted; "Delete forever" deletes it right away. Permanent deletion removes its pages, versions, plans and build history, build memory, brand, logic, the records in its collections, uploaded files, member accounts and their sign-in sessions, message and notification logs, push tokens, member purchases and credits, and export files. We keep billing, payment and tax records with member details removed, consent and security records, and a basic record that the App existed and was deleted (its name, address, owner and item counts). Working copies of build sessions on our build systems may not be removed automatically; you can ask us to delete them by emailing privacy@lynqly.com.

Deleting your account. You can request deletion from your account settings on lynqly.com or by emailing privacy@lynqly.com. When you request deletion, we sign you out and give you 7 days to change your mind, after which the account is locked. About 30 days after your request, we permanently delete your account information, every App you own and its Customer Data, and your access to Apps others shared with you, and your subscriptions end. We keep information we must keep for legal, tax, security or dispute purposes; billing and tax records are kept with your contact details removed, linked only to an internal account number. Export anything you want to keep before you request deletion. Domain registrations are governed by our registrar partner's retention rules, described in the domain registrar section above.

Backups and residual copies. Deleted information may remain for a limited time in logs and in systems our providers operate before it is overwritten. We do not guarantee backups of your App or Customer Data, so please export anything you cannot afford to lose.

10International data transfers

Lynqly is based in the United States. We and our service providers store and process information in the United States and in other countries where our providers operate, which may include countries in the European Union. The data protection laws of those countries may differ from the laws where you live.

If you are in the European Economic Area, the United Kingdom or Switzerland, we transfer your personal data outside those regions only with appropriate safeguards, such as the European Commission's Standard Contractual Clauses (with the UK Addendum where applicable) in our agreements with service providers, or a provider's certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions where available. You can ask us for more information about these safeguards at privacy@lynqly.com.

11Your rights and choices

Choices Available to Everyone

Wherever you live, you can:

• Access and update your information in your account settings;
• Export your Apps and their data from the App Builder;
• Delete Apps from your account, and delete your account as described in "Data Retention";
• Opt out of marketing emails using the unsubscribe link in any marketing email or your account settings;
• Turn off push notifications in the Lynqly mobile app or your device settings;
• Turn off automatic top-ups in your billing settings;
• Control cookies through your browser settings; and
• Contact us with questions about your data.

Rights in the European Economic Area, United Kingdom and Switzerland

If data protection law in these regions applies to you, you have the right to:

• Access a copy of your personal data;
• Rectify inaccurate or incomplete personal data;
• Erase your personal data;
• Restrict our processing of your personal data;
• Port your personal data to another controller in a structured, machine-readable format;
• Object to processing based on our legitimate interests, and to direct marketing at any time;
• Withdraw consent at any time, without affecting processing that took place before you withdrew it;
• Not be subject to a decision based solely on automated processing that has legal or similarly significant effects on you, and to ask for a person to review an automated decision; and
• Lodge a complaint with your local data protection authority.

Rights Under U.S. State Privacy Laws

Depending on where you live, including California, Colorado, Connecticut, Virginia, Oregon, Texas and other states with comprehensive privacy laws, you may have the right to:

• Know and access the personal information we have collected about you, including the categories of sources, purposes and recipients;
• Correct inaccurate personal information;
• Delete personal information, subject to legal exceptions;
• Obtain a portable copy of your personal information;
• Opt out of the sale or sharing of personal information, and of targeted advertising;
• Opt out of profiling that produces legal or similarly significant effects (we do not engage in such profiling);
• Limit the use of sensitive personal information where applicable (see "California-Specific Disclosures"); and
• Not be discriminated against for exercising your rights.

Opting Out of Sharing for Advertising

To opt out of the "sharing" or "sale" of your personal information and of targeted advertising, email privacy@lynqly.com with the subject line "Do Not Sell or Share My Personal Information." We will stop including your information in the advertising conversion data we send to Google and Microsoft. You can also block advertising and analytics cookies in your browser. We are working on support for browser opt-out preference signals, such as Global Privacy Control; until that is available, please use the email method.

How to Exercise Your Rights

1. Account settings: use the controls in your account settings on lynqly.com;
2. Email: send a request to privacy@lynqly.com with the subject line "Privacy Rights Request"; or
3. Mail: write to us at the address in "Contact Information."

If your request concerns Customer Data in an App you use as an End User, please contact the App Owner (see "Our Two Roles").

Verification. We will verify your identity before acting on a request, usually by confirming control of the email address on your account. We may ask for more information if needed.

Authorized agents. You may use an authorized agent to make a request for you. We will ask for proof of the agent's authority and may ask you to verify your identity directly.

Response time. We respond within the time the law requires: generally within one month under European law and within 45 days under U.S. state laws. Where the law allows, we may extend that period and will tell you if we do.

Appeals. If we decline your request, you may appeal by replying to our decision or emailing privacy@lynqly.com with the subject line "Privacy Request Appeal." We will respond to your appeal within the time the law requires. If you are not satisfied, you may contact your state attorney general.

No fee. We do not charge a fee to respond to a verifiable request unless it is excessive, repetitive or manifestly unfounded.

12Email, text messages and push notifications

Emails From Lynqly

Service emails. We send emails that are needed to provide the Services, such as sign-in links and codes, account and security notices, receipts, low-balance and payment notices, notices about your Apps' usage and plan limits, build updates, export links, and notices about changes to our Terms or this policy. You cannot opt out of these while you have an account.

Marketing emails. With your consent where required, we may send product news, tips and offers. You can opt out at any time by clicking "unsubscribe" in any marketing email, changing your email preferences in account settings, or emailing support@lynqly.com with "Unsubscribe" in the subject line.

Messages Sent by Apps

Emails, text messages and push notifications that an App sends to its End Users are sent by us on the App Owner's behalf. Unless the App Owner has connected their own sending domain, App emails come from a Lynqly address, usually using the App's name, with replies going to the App Owner. App text messages are sent from a phone number that Lynqly operates for Apps, and replies may be delivered to the App or forwarded to the App Owner. To stop receiving messages from an App, follow the instructions in the message or contact the App Owner.

Push Notifications From the Lynqly Mobile App

If you allow notifications in the Lynqly mobile app, we register your device's push token, platform and device model with your account and send notifications about your Apps, such as build progress, questions from the AI, low balance, your App's usage of its plan, and new activity in your App. These notifications may include details from your App, such as a customer's name on a new booking. You can choose which notifications you receive in the app, or turn them off in your device settings.

13The Lynqly mobile app

If you use the Lynqly mobile app for iPhone or Android, the rest of this policy applies, and in addition:

• Permissions. The app asks for permission before using your microphone (voice input), speech recognition (your phone's dictation), your camera and photo library (photos you attach to a plan), and notifications. You can change these permissions at any time in your device settings.
• Signing in from our mobile website. If you start an App on our mobile website and then install the app, we pass a one-time sign-in code into the app so you land signed in on your App. On Android, the app reads this code from the Google Play install referrer and may check your clipboard for it. On iPhone, the app checks your clipboard for the code only after asking you, and iOS may show a "paste" permission prompt. The app looks only for our sign-in code and does not keep other clipboard contents.
• Device storage. The app stores your sign-in session in your device's secure storage and keeps copies of recent data on your device so it opens quickly.
• App store purchases. If you buy build funds through the Apple App Store or Google Play, Apple or Google processes your payment and sends us the purchase and refund details we need to credit or adjust your balance. We may also give Apple information about how you used a purchase if you ask Apple for a refund. Where we offer links to buy on our website instead, we may be required to report those purchases to the app store operator.
• Updates. The app checks for updates through our provider Expo, which receives your device's IP address and basic device information when it does.
• Deleting your account. You can delete your account from your account settings on lynqly.com or by emailing privacy@lynqly.com.

14Security

We use administrative, technical and physical safeguards designed to protect personal information, including:

• Encryption in transit using HTTPS/TLS;
• Hashed credentials: Lynqly passwords and End User passwords are stored only as one-way hashes, and End User sign-in sessions and tokens are stored as hashes;
• Encrypted secrets: third-party API keys and developer credentials you save are encrypted, and we do not display them back after you save them, other than the last few characters;
• Protected exports: export files are encrypted, delivered by a one-time link that expires, rate-limited, and require you to confirm your identity;
• Separation between Apps: each App's data is kept separate from other Apps' data, and records are private to the App Owner unless the App Owner chooses otherwise;
• Access controls: our personnel may access Customer Data only when needed to provide support you request, keep the Services running and secure, investigate abuse, or comply with law; and
• Abuse prevention: bot checks, rate limits and automated screening.

No system is perfectly secure. We cannot guarantee the security of information transmitted over the internet or stored in our systems. If we learn of a security incident that affects your personal information, we will notify you and, where required, the authorities, as the law requires. If an incident affects Customer Data, we will notify the affected App Owners so they can meet their own obligations.

Your responsibility. Please use a strong, unique password, keep your sign-in links and codes private, do not share your account, protect any export files you download, and tell us promptly at security@lynqly.com if you suspect unauthorized access.

Reporting vulnerabilities. If you find a security vulnerability, please email security@lynqly.com with details. We welcome responsible disclosure.

15Cookies and similar technologies

What We Use

Cookies are small text files stored by your browser. We also use similar technologies, such as your browser's local storage, secure storage in our mobile app, and tags that send information to analytics and advertising providers.

Apps built on Lynqly do not include Lynqly's analytics or advertising tags. An App's sign-in session is kept in the End User's browser storage. App Owners who add their own analytics or tracking are responsible for any notices and consents it requires.

Managing Cookies

Most browsers let you view, delete and block cookies, including third-party cookies. If you block essential cookies or storage, parts of the Services, including signing in and saving work, may not work. You can also opt out of Google Analytics with Google's browser add-on, and adjust ad settings in your Google and Microsoft accounts.

Do Not Track

Browsers' "Do Not Track" signals have no common standard, and we do not respond to them. For browser opt-out preference signals under U.S. state law, see "Opting Out of Sharing for Advertising."

16Children's privacy

Lynqly Accounts

The Services are intended for people 18 and older, and we do not knowingly collect personal information from children under 18 for Lynqly accounts. If we learn that we have, we will delete it. If you believe a child has given us personal information, contact privacy@lynqly.com.

Apps Built on Lynqly

App Owners must not use the Services to build Apps directed to children under 13, or knowingly collect personal information from children under 13 (or a higher age where local law requires, such as under 16 in parts of Europe), unless the App Owner fully complies with the Children's Online Privacy Protection Act (COPPA) and similar laws, including obtaining verifiable parental consent. The App Owner, not Lynqly, is responsible for that compliance. We may suspend or remove an App that we believe collects children's information unlawfully.

17California-specific disclosures

This section applies to California residents and supplements the rest of this policy. It describes our practices over the past 12 months as a business. It does not cover Customer Data that we process as a service provider for App Owners.

Categories of Personal Information

Sources. We collect these categories from you, from your devices, from payment processors and app stores, from advertising platforms (click identifiers), from people who refer or invite you, and from public and commercial sources about domain names.

Purposes. We collect and use these categories for the purposes described in "How We Use Information," including providing and improving the Services, communications, security and fraud prevention, legal compliance and advertising our own Services.

Retention. We keep each category for the periods described in "Data Retention."

Sale and sharing. We do not sell personal information for money. We "share" identifiers, commercial information and internet activity with Google and Microsoft for cross-context behavioral advertising as described in "Advertising Partners." You can opt out as described in "Opting Out of Sharing for Advertising." We do not knowingly sell or share the personal information of consumers under 16.

Sensitive personal information. We use sensitive personal information only to provide the Services, keep them secure and for other purposes permitted by Cal. Code Regs. tit. 11, § 7027(m), and not to infer characteristics about you. The right to limit its use therefore does not apply.

Your California rights and how to use them are described in "Your Rights and Choices."

California Shine the Light

California residents may ask whether we disclosed personal information to third parties for their own direct marketing purposes. We do not. To ask, email privacy@lynqly.com with "California Shine the Light Request" in the subject line.

18European Economic Area, United Kingdom and Switzerland

Legal Bases for Processing

Where European data protection law applies, we rely on these legal bases:

• Contract: to provide the Services you request, including planning, building and hosting your Apps, Domain Finder, domain registration, payments and support;
• Legitimate interests: to secure the Services and prevent fraud and abuse, screen content, improve and test the Services, measure our advertising, and communicate with you about the Services. We balance these interests against your rights, and you can object;
• Consent: for marketing emails where required, optional cookies and similar technologies where required, device permissions in the mobile app, and push notifications. You can withdraw consent at any time; and
• Legal obligation: to keep tax and payment records and respond to lawful requests.

Controller and Processor

Ostrel Software LLC is the controller of the personal data described in this policy, except Customer Data, for which the App Owner is the controller and Lynqly is a processor (see "Our Two Roles").

Automated Decisions

Our automated screening of build requests, scope checks for fixed-price builds, and fraud-prevention checks may limit what you can do on the Services. You can ask for a person to review any such decision by contacting support@lynqly.com.

Complaints

You can lodge a complaint with your local data protection authority. In the UK, this is the Information Commissioner's Office (https://ico.org.uk). We would appreciate the chance to address your concern first, so please contact us at privacy@lynqly.com.

19Nevada residents

Nevada residents may opt out of the sale of certain covered information. Lynqly does not sell covered information as defined under Nevada law. To submit a request, email privacy@lynqly.com with "Nevada Opt-Out Request" in the subject line.

20Contact information

For questions about this Privacy Policy or to exercise your privacy rights, contact us at:

Privacy requests and questions: privacy@lynqly.com
Support: support@lynqly.com
Security issues: security@lynqly.com

Mailing address:
Ostrel Software LLC
Attn: Privacy
522 W Riverside Ave, Ste N
Spokane, WA 99201

If you are an End User of an App built on Lynqly, please contact the business that runs that App first.

21Changes to this privacy policy

We may update this Privacy Policy to reflect changes in our Services, our practices or the law. When we do, we will update the "Last Updated" date at the top. If we make material changes, we will notify you by email or through a notice in the Services before the changes take effect, and where the law requires, we will ask for your consent. Changes do not apply retroactively. If you keep using the Services after the changes take effect, the updated policy applies to you.

22Effective date

This Privacy Policy is effective as of the Effective Date listed at the top of this document.

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End of Privacy Policy