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Dell Download Privacy Addendum

Privacy and data-sharing disclosure for the AirgapAI Dell AI PC trial download.

Document Legal Updated July 2026

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ITERNAL TECHNOLOGIES — PRIVACY AND DATA SHARING ADDENDUM

Dell AI PC Trial Download — Data Consent Disclosure

Version: v1.0 — July 2026

This Addendum supplements the Iternal Trial EULA and describes how Iternal, Dell Technologies, and authorized reseller partners collect, use, and share data in connection with the AirgapAI Dell AI PC trial program. By completing the download form, you accept the Trial EULA and acknowledge the disclosures below.

§A — Why We Collect Your Dell Service Tag

  • Your Dell Service Tag is required to activate the trial license. It is used to: (a) validate that your device is an eligible Dell AI PC model; (b) enforce the two-device-per-tag install limit; and (c) associate your activation with your authorized Dell reseller partner for commission tracking.
  • Data retained: Your Service Tag is retained for the duration of your trial license plus two (2) years for compliance-audit purposes.
  • Legal basis (GDPR): Legitimate interest — license enforcement and fraud prevention.
  • CCPA data category: Identifiers.

§B — How We Share Your Data with Dell Technologies and Your Reseller Partner

Data is shared in both directions between Iternal, Dell Technologies, and your authorized reseller partner, as described below:

Direction Data Shared Purpose Legal Basis
Iternal → Dell Technologies Activation count by Service Tag, license status, trial-to-paid conversion status Channel reporting; exclusivity-milestone tracking; AI Assist bundle validation Contractual performance
Dell Technologies → Iternal Service Tag validity confirmation, eligible-model status License validation at activation Contractual performance
Iternal → Your Reseller Partner Activation confirmation, your email address (if provided), deal status Partner commission reconciliation; partner-led nurture Contractual performance / Legitimate interest
Your Reseller Partner → Iternal Order number, deal-registration data Revenue attribution; Intel reimbursement tracking Contractual performance

Iternal does not sell your personal data to any party. Data sharing with Dell and partners is limited to the purposes described above.

§C — Analytics During Your Free Trial

  • During your free trial, Iternal automatically collects usage analytics as a condition of the free license. This helps us improve the product for paid customers.
  • What we collect: session frequency, feature-usage events, activation date, device identifiers (including your Dell Service Tag), Software version, and operating-system information.
  • What we do NOT collect: the content of your prompts, AI responses, conversations, or documents.
  • When you become a paid customer: analytics collection stops automatically and by default. You may opt in via the in-app settings.
  • Retention: Analytics data from your trial is deleted within ninety (90) days after your trial ends, or upon your conversion to a paid license.

See Trial EULA §2.10 for the full analytics terms.

§D — Rights for EU/EEA Residents (GDPR)

If you are located in the EU/EEA, you have the following rights with respect to your personal data:

  • Right to access your data.
  • Right to rectification — to correct inaccurate data.
  • Right to erasure (deletion) — note: Iternal may retain your Service Tag and activation logs for the two-year audit-retention period even after a deletion request.
  • Right to data portability.
  • Right to restrict processing.
  • Right to object to processing based on legitimate interests.
  • Right to withdraw consent (for analytics) — this ceases future analytics collection but does not delete historical data collected during the trial period prior to withdrawal.
  • Right to lodge a complaint with your national data-protection authority.

Contact for GDPR requests: privacy@iternal.ai
Data Controller: Iternal Technologies, Inc.
International transfers: Your data may be transferred to and processed in the United States under Standard Contractual Clauses (SCCs).

§E — Rights for California Residents (CCPA)

If you are a California resident, the following apply:

  • Categories of personal information collected:
    1. Identifiers — name, email, Dell Service Tag, device ID.
    2. Commercial information — license type, activation date, conversion status.
    3. Internet/electronic network activity — usage telemetry.
  • Iternal does NOT sell your personal information.
  • Your rights:
    1. Right to know what information we collect and how it is used.
    2. Right to request deletion (subject to the audit-retention period described in §A and §D).
    3. Right to opt out of sale — not applicable, because we do not sell your personal information.
    4. Right to non-discrimination for exercising any right.

Contact for CCPA requests: privacy@iternal.ai or gov@iternal.us

§F — Marketing Communications

  • By registering, you agree to receive trial onboarding emails from Iternal (download link, install instructions, usage tips, and offers).
  • You may opt out of marketing emails at any time by clicking "Unsubscribe" in any email we send.
  • To request deletion of your data, email privacy@iternal.ai.
  • Transactional emails (license key, billing notifications) cannot be opted out of while your license is active.