Privacy Policy — KeplerPI

The plain-English version first: your portfolio data stays on your devices and in your own cloud. We never see it.

Kepler Technology Pty Ltd ("Kepler", "we", "us") makes KeplerPI III, a local-first portfolio-management application. We respect your privacy. This policy explains, in plain terms, what personal information we do and do not handle, and why. It is written to align with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. THE SHORT VERSION

KeplerPI III runs on your own device and keeps your data there. We do not collect, upload, or store your portfolio information. The only personal information we handle is the email address and billing details you provide when you start a trial or buy a licence, and those are processed by our payment and licensing provider. We do not sell your data, and we do not track you.

2. YOUR PORTFOLIO DATA STAYS WITH YOU

The application is local-first. Your assets, valuations, documents, photos, contacts, actions and all other records are stored on your own device (in your browser's local storage) and, if you choose to run the optional host, in a file in a folder you nominate on your own computer or network. This information is never sent to Kepler. We cannot see it, and we do not hold a copy of it. You are responsible for backing it up.

3. PERSONAL INFORMATION WE HANDLE

(a) Email address. When you start a trial or purchase a licence, you provide an email address so your licence key can be sent to you and so we can contact you about your licence and support. (b) Billing details. If you purchase, your payment information (such as card details) is collected and processed by our payment and licensing provider as merchant of record. Kepler does not receive or store your full card number. (c) Licence-validation data. To activate and validate a licence, your licence key and a machine identifier (a value derived from your device, used only to bind a licence to a machine and enforce activation limits) are sent to the licensing provider. The machine identifier is not used to profile, track, or identify you personally beyond licence enforcement.

4. THIRD-PARTY SERVICES

(a) Payment and licensing. We use Lemon Squeezy (a Lemon Squeezy / Stripe service) as our merchant of record to take payment, issue and validate licence keys, and handle applicable taxes (including Australian GST). Your email and billing details are handled under their privacy terms. (b) Optional price feeds. If you choose to fetch live prices, the application sends the relevant security symbols (not personal information) to the third-party price provider you select. This happens only when you request it. We are not responsible for the privacy practices of these third parties; please review

KeplerPI III — Privacy Policy

their policies.

5. WHAT WE DO NOT DO

- We do not collect your portfolio, document, photo, or contact data. - We do not include analytics, telemetry, advertising, or tracking in the application. - We do not sell, rent, or trade your personal information. - We do not build advertising or behavioural profiles about you.

6. HOW WE USE THE INFORMATION WE HANDLE

We use your email and licence information only to: issue and validate your licence; deliver your licence key; provide support you request; send essential notices about your licence or the software; and meet our legal, tax and accounting obligations.

7. DISCLOSURE

We disclose personal information only to our payment and licensing provider for the purposes above, to professional advisers under confidentiality, and where required or authorised by law. We do not otherwise disclose your personal information.

8. OVERSEAS TRANSFER

Our payment and licensing provider and its sub-processors may store or process information outside Australia (for example, in the United States or European Union). By purchasing or starting a trial you consent to this transfer for the purposes described above.

9. STORAGE AND SECURITY

Your portfolio data is held on your device under your control. For the limited personal information we and our provider handle, we take reasonable steps to protect it from misuse, loss, and unauthorised access. The licence design uses asymmetric signing so the shipped application cannot forge or extract a usable signing secret. No method of transmission or storage is completely secure.

10. RETENTION

We retain licence and billing records for as long as needed to provide the licence and to meet legal, tax and accounting requirements, after which they are deleted or de-identified. Your portfolio data is retained by you, on your device, for as long as you keep it.

11. COOKIES AND LOCAL STORAGE

The application uses your browser's local storage to hold your data and settings on your own device. This is not used to track you and is not shared. We do not set third-party tracking cookies.

12. YOUR RIGHTS

Subject to law, you may ask us to access or correct the personal information we hold about you (your email and licence records), and you may ask us to delete it where we are not required to keep it. To exercise these rights, contact us using the details below.

KeplerPI III — Privacy Policy

13. CHILDREN

KeplerPI III is intended for adults managing their own or their entity's investments. It is not directed at children, and we do not knowingly collect personal information from children.

14. CHANGES TO THIS POLICY

We may update this policy from time to time. The current version is included with the software and dated above. Material changes will be notified through the software or by email.

15. CONTACT AND COMPLAINTS

For privacy questions, requests, or complaints, contact: Kepler Technology Pty Ltd — keplertechnology1@gmail.com If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.