Data Policy

DATA POLICY

Effective Date: September 7, 2026
Last Updated: September 7, 2026

This Data Policy explains how TheUnder.us, including Underlinks, Stream Apps, creator pages, applications, analytics, commerce features, advertising services, and related tools (collectively, the “Services”), collects, uses, processes, discloses, sells, shares, and protects data.

TheUnder.us is owned and operated by KLM Enterprises, accessible at klmenter.xyz.

This Data Policy supplements our Privacy Policy and Terms of Use.


1. IMPORTANT NOTICE ABOUT SALE AND SHARING OF DATA

As of September 7, 2026, TheUnder.us may sell or share certain personal information.

For purposes of applicable privacy laws, including laws that define “sale” or “sharing” broadly, some transfers of information to advertising partners, marketing partners, analytics providers, data partners, social media platforms, or other third parties may constitute the sale or sharing of personal information.

Sale or sharing may occur in connection with:

  • Advertising

  • Personalized or interest-based advertising

  • Cross-context behavioral advertising

  • Marketing

  • Audience measurement

  • Campaign measurement

  • Analytics

  • Audience development

  • Customer acquisition

  • Platform monetization

  • Advertising attribution

  • Business partnerships

  • Data matching

  • Improving advertising effectiveness

Where applicable law provides a right to opt out, users may exercise that right as described in this Data Policy.


2. DATA WE COLLECT

Depending on how you interact with TheUnder.us, we may collect information including:

Account and Identity Information

  • Name

  • Display name

  • Username

  • Email address

  • Telephone number

  • Account identifier

  • Profile information

  • Creator or business name

  • Account preferences

Profile and Creator Information

Information creators voluntarily publish or provide may include:

  • Biography

  • Profile photograph

  • Logo

  • Artwork

  • Social media accounts

  • Websites

  • Music links

  • Videos

  • Products

  • Events

  • Business information

  • Contact links

  • Creator content

Device and Technical Information

We may automatically collect:

  • IP address

  • Browser type

  • Device type

  • Operating system

  • Device identifiers

  • Advertising identifiers

  • Session identifiers

  • Language settings

  • Referring URLs

  • Network information

  • Error logs

  • Security information

Usage and Engagement Data

We may collect information regarding how users and visitors interact with the Services, including:

  • Pages visited

  • Underlinks pages viewed

  • Stream Apps viewed

  • Links clicked

  • Buttons clicked

  • Products viewed

  • Content viewed

  • Session duration

  • Visit frequency

  • Referral source

  • Search activity

  • Interaction history

  • Advertising interactions

  • Conversion events

Location Information

We may derive approximate location information from IP addresses or other technical information.

This may include:

  • Country

  • State or region

  • City or general metropolitan area

Unless separately disclosed and authorized, approximate location information is not intended to represent precise GPS-level location.

Commercial Information

When applicable, we may collect:

  • Products viewed

  • Products purchased

  • Subscription information

  • Transaction history

  • Purchase interests

  • Creator purchases

  • Offers interacted with

  • Advertising conversion information

Analytics Information

We may collect or generate information including:

  • Page views

  • Unique or estimated visitors

  • Link clicks

  • Traffic sources

  • Device categories

  • General geographic information

  • Campaign performance

  • Conversion information

  • Audience engagement

  • Usage patterns

  • Aggregated trends


3. INFORMATION WE MAY SELL OR SHARE

Beginning September 7, 2026, TheUnder.us may sell or share certain categories of personal information where permitted by law.

These categories may include:

Identifiers

Examples may include:

  • IP address

  • Device identifiers

  • Advertising identifiers

  • Cookie identifiers

  • Online identifiers

Internet or Electronic Activity

Examples may include:

  • Pages visited

  • Links clicked

  • Content viewed

  • Referral information

  • Advertising interactions

  • Engagement information

  • Browsing activity within the Services

Commercial Information

Examples may include:

  • Products or services viewed

  • Purchase activity

  • Subscription activity

  • Advertising conversion information

  • General consumer or creator interests

Approximate Location Information

Approximate location information may be derived from IP addresses or similar technologies.

Advertising and Marketing Information

This may include:

  • Advertising identifiers

  • Audience segments

  • Campaign interactions

  • Conversion events

  • Advertising preferences

  • Marketing engagement

  • Attribution information

Inferences

We or our partners may generate general inferences relating to:

  • Interests

  • Content preferences

  • Creator interests

  • Product interests

  • Advertising interests

  • Likely audience categories


4. WHAT “SELL” MEANS

The word “sell” may have a broader meaning under privacy laws than an ordinary exchange of information for cash.

Depending on applicable law, a sale may include making personal information available to a third party in exchange for:

  • Money

  • Services

  • Advertising benefits

  • Analytics benefits

  • Business benefits

  • Other valuable consideration

Therefore, a transaction may legally qualify as a sale even when TheUnder.us does not directly receive cash for an individual user's information.


5. WHAT “SHARE” MEANS

Under certain privacy laws, “sharing” may include making personal information available to another company for advertising purposes, particularly cross-context behavioral advertising.

For example, information about activity on TheUnder.us may be shared with an advertising or technology platform to:

  • Deliver relevant advertisements

  • Build advertising audiences

  • Measure advertising performance

  • Attribute conversions

  • Limit repeated advertising

  • Understand campaign effectiveness

  • Reach users on other services


6. WHO MAY RECEIVE DATA

Personal information may be sold, shared, or otherwise disclosed to categories of third parties including:

  • Advertising networks

  • Advertising technology providers

  • Marketing companies

  • Analytics providers

  • Measurement providers

  • Social media platforms

  • Audience-development providers

  • Data-management platforms

  • Business partners

  • Technology partners

  • Commerce providers

  • Customer-acquisition providers

  • Fraud-prevention services

  • Security providers

  • Cloud and hosting providers

  • Payment processors

  • Service providers and contractors

Not every disclosure constitutes a legal “sale” or “sharing.”

For example, information provided to a service provider solely to perform services for TheUnder.us may be treated differently under applicable privacy law.


7. WHY WE SELL OR SHARE CERTAIN DATA

Information may be sold or shared for purposes including:

  • Supporting free or lower-cost Services

  • Monetizing the platform

  • Advertising

  • Personalized advertising

  • Marketing

  • Audience development

  • Measuring advertisements

  • Understanding campaign performance

  • Improving products and Services

  • Identifying trends

  • Developing features

  • Measuring engagement

  • Customer acquisition

  • Promoting TheUnder.us

  • Promoting participating creators or businesses

  • Business analysis

  • Market research

  • Attribution and conversion measurement


8. PERSONALIZED ADVERTISING

TheUnder.us or third-party partners may use information regarding your interaction with the Services to select or measure advertising.

Information used for these purposes may include:

  • Cookies

  • Device identifiers

  • Advertising identifiers

  • IP addresses

  • Page activity

  • Link activity

  • Referral information

  • Approximate location

  • Advertising interactions

Third-party advertising partners may combine information received through TheUnder.us with information obtained from other websites, applications, devices, or services, subject to their own privacy practices and applicable law.


9. COOKIES AND TRACKING TECHNOLOGIES

TheUnder.us and participating third parties may use:

  • Cookies

  • Pixels

  • Tags

  • SDKs

  • Local storage

  • Session storage

  • Advertising identifiers

  • Tracking links

  • Conversion tags

  • Similar technologies

These technologies may be used for:

  • Authentication

  • Security

  • Preferences

  • Analytics

  • Advertising

  • Attribution

  • Fraud prevention

  • Personalization

  • Measurement

  • Platform functionality

Certain advertising or tracking technologies may result in personal information being considered sold or shared under applicable law.


10. DO NOT SELL OR SHARE MY PERSONAL INFORMATION

Where applicable law gives you the right to opt out, you may direct TheUnder.us not to sell or share your personal information.

TheUnder.us should provide a privacy control identified as:

Do Not Sell or Share My Personal Information

or:

Your Privacy Choices

You may also submit an opt-out request by contacting:

Email: info@klmenter.xyz
Phone: 818-278-0879

You do not need to purchase anything to exercise an applicable privacy right.

Where required by law, you will not be required to create an account solely to exercise an opt-out right.

After a valid opt-out request is processed, TheUnder.us will stop covered sale or sharing of the applicable personal information unless:

  • You later authorize it;

  • The activity is legally exempt; or

  • The disclosure does not legally constitute sale or sharing.


11. GLOBAL PRIVACY CONTROL

Where required by applicable law, TheUnder.us will recognize qualifying browser or device-based opt-out preference signals, including Global Privacy Control (“GPC”), as a request to opt out of sale or sharing.

When a valid GPC or similar legally recognized opt-out signal is detected, we will apply the preference as required by applicable law.

A privacy preference signal may apply to the browser or device from which the signal is received.

Logged-in users may receive broader account-level application of an opt-out where technically and legally appropriate.


12. OPTING OUT DOES NOT MEAN ALL DATA COLLECTION STOPS

Opting out of the sale or sharing of personal information does not necessarily prevent TheUnder.us from collecting or processing information needed to:

  • Operate your account

  • Provide requested Services

  • Maintain security

  • Prevent fraud

  • Process payments

  • Maintain sessions

  • Provide analytics that are not legally considered sale or sharing

  • Comply with the law

  • Maintain business records

  • Debug or maintain the platform

  • Protect users and systems

You may also continue to see advertisements after opting out.

Those advertisements may be less personalized.


13. SENSITIVE PERSONAL INFORMATION

TheUnder.us does not intend to use sensitive personal information for purposes inconsistent with the reason it was collected without appropriate notice or authorization.

Sensitive personal information may receive additional protections under applicable law.

Depending on the jurisdiction, sensitive personal information may include things such as:

  • Government identifiers

  • Account credentials

  • Financial account information

  • Precise geolocation

  • Racial or ethnic origin

  • Religious beliefs

  • Health information

  • Sexual orientation

  • Biometric information

Where applicable law provides a right to limit certain uses or disclosures of sensitive personal information, TheUnder.us will provide a method for exercising that right where required.


14. PAYMENT INFORMATION

Payments may be processed by third-party payment processors.

TheUnder.us may receive transaction-related information such as:

  • Customer name

  • Billing email

  • Transaction identifier

  • Payment status

  • Amount

  • Currency

  • Limited payment-method information

  • Refund or dispute information

Full credit or debit card information may be processed directly by the applicable payment processor.

Payment providers operate under their own privacy and security policies.


15. PUBLIC CREATOR DATA

TheUnder.us is designed to allow creators to publish information publicly.

Information intentionally published on a public Underlinks page, Stream App, creator profile, product listing, event, or other public area may be accessible to:

  • Visitors

  • Search engines

  • Social media services

  • Web crawlers

  • Analytics systems

  • Other websites

  • Third-party services

Information intentionally made public may receive different legal treatment from non-public personal information.

Creators should not publish information they wish to keep confidential.


16. CREATOR ANALYTICS

Creators may receive analytics about visitors to their pages or applications.

Analytics may include:

  • Page views

  • Link clicks

  • Referral source

  • Device category

  • Approximate location

  • Engagement

  • Conversion data

  • Traffic trends

We may limit or aggregate analytics to protect visitors and comply with applicable law.


17. DATA WE RECEIVE FROM THIRD PARTIES

We may receive information from:

  • Social platforms

  • Advertising partners

  • Analytics providers

  • Payment processors

  • Business partners

  • Authentication providers

  • Marketing partners

  • Creators

  • Public sources

Information received from third parties may be combined with information collected directly through TheUnder.us.


18. SERVICE PROVIDERS

We may disclose information to vendors and contractors that process information on our behalf.

These may include providers of:

  • Hosting

  • Databases

  • Email

  • Security

  • Customer support

  • Payments

  • Analytics

  • Fraud prevention

  • Infrastructure

  • File storage

  • Content delivery

Disclosures made solely to qualifying service providers or contractors may not constitute a sale or sharing under applicable privacy law.


19. LEGAL DISCLOSURES

We may disclose information when reasonably necessary to:

  • Comply with laws

  • Respond to court orders

  • Respond to subpoenas

  • Respond to warrants

  • Cooperate with lawful government requests

  • Investigate fraud

  • Investigate security incidents

  • Protect users

  • Protect KLM Enterprises

  • Protect property

  • Enforce our Terms

  • Establish or defend legal claims


20. BUSINESS TRANSACTIONS

Information may be transferred as part of:

  • A merger

  • Acquisition

  • Reorganization

  • Financing

  • Investment

  • Sale of assets

  • Bankruptcy

  • Business restructuring

  • Transfer of part or all of TheUnder.us

Any successor may receive information subject to applicable law and any applicable privacy obligations.


21. USERS UNDER 16

TheUnder.us does not knowingly sell or share the personal information of individuals under 16 without any affirmative authorization required by applicable law.

Where required, authorization must come from:

  • The individual when legally permitted; or

  • A parent or guardian.

If we determine that information involving a minor was sold or shared contrary to applicable requirements, we may take reasonable steps to stop that activity and address the information involved.


22. STATE PRIVACY RIGHTS

Residents of certain U.S. states may have rights regarding their personal information.

Depending on applicable law, these rights may include:

  • Right to know

  • Right to access

  • Right to correct

  • Right to delete

  • Right to obtain a portable copy

  • Right to opt out of sale

  • Right to opt out of sharing

  • Right to opt out of targeted advertising

  • Right to opt out of certain profiling

  • Right to limit certain uses of sensitive personal information

  • Right to appeal certain privacy decisions

  • Right to non-discrimination for exercising privacy rights

Rights vary by jurisdiction and are subject to exceptions.


23. CALIFORNIA PRIVACY NOTICE

California residents may have additional rights under the California Consumer Privacy Act and related law when those laws apply to TheUnder.us.

These rights may include:

  • Knowing what personal information we collect

  • Knowing how personal information is used

  • Knowing whether personal information is sold or shared

  • Requesting access

  • Requesting correction

  • Requesting deletion

  • Opting out of sale or sharing

  • Limiting certain uses of sensitive personal information where applicable

  • Using an authorized agent

  • Exercising rights without unlawful discrimination

TheUnder.us currently may sell or share personal information as described in this Data Policy.

California residents may submit an applicable opt-out request through the site's Do Not Sell or Share My Personal Information or Your Privacy Choices control.


24. AUTHORIZED AGENTS

Where permitted by applicable law, you may appoint an authorized agent to submit certain privacy requests on your behalf.

We may request documentation showing that the agent is authorized to act for you.

We may also contact you directly where verification or confirmation is permitted or required.


25. NON-DISCRIMINATION

Where prohibited by law, TheUnder.us will not unlawfully discriminate against you because you exercised a privacy right.

Exercising a privacy right will not, by itself, result in:

  • Denial of Services

  • Unlawful pricing differences

  • Unlawful reduction in service quality

  • Retaliation

Different services or benefits may be permitted where authorized under applicable privacy law.


26. DATA RETENTION

We retain information for periods reasonably necessary for purposes including:

  • Providing Services

  • Maintaining accounts

  • Analytics

  • Advertising operations

  • Security

  • Fraud prevention

  • Transactions

  • Tax and accounting obligations

  • Legal compliance

  • Dispute resolution

  • Enforcement

  • Backups

Retention periods may vary based on the type of information and why it was collected.


27. DATA SECURITY

We use reasonable technical, administrative, and organizational safeguards intended to protect information.

Security measures may include:

  • Encryption where appropriate

  • Authentication

  • Access controls

  • Logging

  • Monitoring

  • Network protections

  • Secure infrastructure

  • Backups

  • Fraud prevention

No internet-based service or storage system can guarantee absolute security.


28. DATA DELETION

Users may request deletion of certain personal information, subject to legal exceptions.

We may retain information where necessary for:

  • Security

  • Fraud prevention

  • Tax requirements

  • Accounting requirements

  • Legal obligations

  • Transactions

  • Dispute resolution

  • Exercise or defense of legal claims

  • Enforcement of agreements

Deletion from active systems may not immediately remove information from secure backups.


29. INTERNATIONAL DATA PROCESSING

TheUnder.us may be accessible internationally.

Information may be processed or stored in the United States and other locations where KLM Enterprises or its service providers operate.

Different jurisdictions may have different privacy laws and protections.

Where legally required, appropriate mechanisms will be used for international data transfers.


30. THIRD-PARTY PRIVACY PRACTICES

Third parties receiving or collecting information may have their own privacy policies.

This includes:

  • Advertising platforms

  • Social networks

  • Payment processors

  • Analytics providers

  • Embedded services

  • External websites

Once you interact directly with a third-party service, that third party's privacy practices may govern its independent use of your information.


31. DATA POLICY CHANGES

We may modify this Data Policy as:

  • Our Services evolve

  • Data practices change

  • Advertising practices change

  • Technology changes

  • Laws or regulations change

The updated policy will display a revised “Last Updated” date.

If a material change requires additional notice or consent, we will provide it as required by applicable law.


32. CURRENT DATA-SHARING STATUS

As of the effective date shown above:

Does TheUnder.us collect personal information? — YES

Does TheUnder.us use analytics? — YES

Does TheUnder.us use or permit advertising/marketing data processing? — YES

Does TheUnder.us sell or share certain personal information as those terms may be defined by applicable privacy laws? — YES

Can eligible users opt out where required by law? — YES

Does opting out prevent all necessary operational data processing? — NO

This section is intended to provide users with a straightforward description of TheUnder.us's current data practices.


33. OWNER AND OPERATOR

TheUnder.us and the Underlinks platform are owned and operated by:

KLM Enterprises

Website: klmenter.xyz

TheUnder.us, Underlinks, Stream Apps, and associated services are part of the KLM Enterprises digital platform portfolio.


34. CONTACT AND PRIVACY REQUESTS

For data questions, privacy requests, opt-out requests, or other concerns, contact:

KLM Enterprises
TheUnder.us / Underlinks

Email: info@klmenter.xyz
Phone: 818-278-0879
Website: klmenter.xyz

Requests should provide enough information for us to understand the request and locate the applicable information where reasonably necessary.

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