Terms of Service

1. Reading and accepting these Terms

(a) Welcome to DS160.io. DS160.io is operated by Galah Enterprises Pty Ltd ACN 682 927 779, trading as DS160.io (“we”, “our” or “us”). We provide a software tool for DS-160 data intake and for filling in the U.S. Department of State’s online DS-160 form (the “Software”). We do not provide immigration or legal advice and do not guarantee visa outcomes, and the person or business preparing an application remains solely responsible for checking its accuracy before submission.

(b) These terms (the “Terms”) govern your access to the Software and any other goods and services we provide to you under them (your “Subscription”). The current version is at ds160.io/terms. Please read them carefully before proceeding with your Subscription.

(c) Capitalised words and phrases have the meanings given to them where they are followed by bolded brackets, or in the Definitions at the end of these Terms.

(d) If there is any inconsistency, this order of precedence applies: (1) for personal data, our Data Processing Agreement (the “DPA”); (2) any Subscription Package or written agreement between us; (3) the package description on our Website at the time of purchase; (4) these Terms; (5) the Documentation. Our Privacy Policy describes how we handle personal data as a controller.

(e) By signing an agreement with us, ticking the box or clicking the “I accept these Terms” button on our Website, paying for your Subscription, or otherwise accepting the benefit of any part of your Subscription, you agree to be bound by these Terms, which form a binding contract between us and you, the person acquiring a Subscription or the company you represent and are acquiring it for (“you” or “your”). For a business workspace, accepting these Terms also accepts the DPA.

(f) We may update these Terms from time to time. We will give you at least 30 days’ prior written notice of any material change that adversely affects you. If you do not agree to the change, you may end your Subscription before it takes effect.

2. Eligibility

(a) By accepting these Terms, you represent and warrant that you have the legal capacity and authority to enter into a binding contract with us; that you are authorised to use the payment method you provide; and that neither you nor your affiliates, owners or directors are subject to trade sanctions, export restrictions or similar prohibitions under applicable laws (including US, Australian, UK or EU laws).

(b) The Software is not intended for unsupervised use by anyone under 18 or by anyone who has been suspended or prohibited from using it. By using the Software you represent and warrant that you are either over 18 and using it for personal or commercial purposes, or using it on behalf of someone under 18 and consenting to that person’s use. Do not use the Software if you are under 18 without your parent or guardian’s consent, if you are under 16, or if you have been suspended or prohibited from using it.

(c) If you sign up on behalf of a company, employer, organisation, government or other legal entity (a “Represented Entity”), “you” and “your” mean the Represented Entity and you bind it to these Terms. You represent and warrant that you are authorised to do so.

3. Duration of your Subscription

(a) Your Subscription and these Terms start when you open a business workspace or first purchase (through our Website or by written agreement with us) and continue for as long as you use the Solution under them.

(b) A business workspace is billed for use, as set out in clause 7.1, and continues until either of us ends it under clause 13.

(c) An individual purchase is a package of a set number of application forms (a “Subscription Package”). The Subscription Package ends when its forms have been used. Subscription Packages do not renew automatically; to continue, you purchase a new one.

(d) Any renewal, new Subscription Package or continued use is subject to the Terms and Fees current at the time, unless we agree otherwise in writing.

4. The Solution

4.1 Scope of your Subscription and the Solution

(a) We will give you access to the features of the Software described on our Website or agreed with you, including the workspace dashboard, client intake links and questionnaire, review and editing, and filing of the DS-160 (the “Solution”). We may update or improve the Solution, provided such changes do not materially reduce core functionality during your Subscription unless the law or changes to the U.S. Government’s DS-160 system require it.

(b) Your Subscription includes the benefits and limitations set out on our Website or otherwise communicated to you when you subscribe, as amended from time to time by notice to you.

4.2 Accounts

(a) To use the Solution you may need to sign up for an account on the Website (an “Account”). You must ensure that each User has their own login, that administrator accounts use multi-factor authentication, and that login details are kept secure. You are responsible for all activity under your Accounts.

(b) When you register and while you use the Solution, you will provide personal information such as your name, email address, password or Google sign-in, and billing details. The Privacy Policy sets out what we collect.

(c) You warrant that the information you give us when registering is accurate, honest, correct and up to date.

(d) We may, in our absolute discretion, choose to accept you as a registered user and provide you with an Account.

4.3 Disclaimer

You acknowledge and agree that:

(a) the Solution is a data intake and form-filling tool only. We are not a law firm and do not provide immigration, legal or professional advice. You remain solely responsible for verifying the accuracy and completeness of all information before submission, for compliance with all immigration laws and procedures, and for all decisions and outcomes relating to visa applications;

(b) any information provided to you through the Solution is general in nature, may not suit your circumstances, and is not financial, legal or any other kind of professional advice;

(c) you are responsible for complying with the laws that apply to your business, including privacy laws; and

(d) you will not, and will ensure your Personnel do not, rely on the Solution as legal or immigration advice or hold us out as providing it. You will ensure a suitably qualified person reviews and approves every submission. You indemnify us against any claim that your use of the Solution is the unauthorised practice of law.

4.4 Licence

(a) While your Subscription continues, we grant you a non-exclusive, non-transferable licence to access and use the Solution for your internal business or personal purposes. There is no limit on the number of Users in a workspace. You must not use the Solution to build a competing product, benchmark it without our written consent, or use it for unlawful or fraudulent activity.

(b) We may release upgraded, improved, modified or new versions of the Software (“Enhancements”) at our discretion. Enhancements do not limit or otherwise affect these Terms. They may cause downtime or delays from time to time, and no credits are given for that downtime.

(c) We may change any feature of the Solution at any time on notice to you.

4.5 Support Services

We provide general support where reasonably necessary to resolve technical issues with the Software (“Support Services”). Unless otherwise agreed in writing:

(a) we will take reasonable steps to provide Support Services where necessary; you must first try to resolve issues internally, and we will not assist with issues beyond our reasonable control;

(b) we will use our best endeavours to respond to support requests, and you acknowledge we may not be available 24/7;

(c) you are responsible for your internal administration and managing access, including helping your Users access and use the Software;

(d) you have no claim for delayed access to the Software caused by any failure or delay in Support Services; and

(e) we will use commercially reasonable efforts to respond to support requests during business hours (AEST): Critical within 4 hours, High within 1 Business Day, Normal within 2 Business Days. Delays caused by the U.S. DS-160 website are excluded.

5. Data hosting and security

(a) We host the Solution and User Data on our own servers, at our headquarters in the United States. No third-party hosting provider holds User Data.

(b) We implement security measures appropriate to the nature of User Data, including: encryption in transit; encryption at rest of application data (AES-256), with the key held apart from the database and its backups; access to production systems limited to our team; multi-factor authentication available on every account; role-based access within a workspace; logging and monitoring; vulnerability management and timely patching; database backups kept for 7 days; and disaster recovery with a target recovery point and recovery time of 24 hours. The DPA (Annex II) describes them in full.

(c) We may engage Subprocessors to help deliver the Solution. We remain responsible for their acts and omissions and impose on them data protection obligations no less protective than these Terms. We keep the current Subprocessor list in the DPA (Annex III) and the Privacy Policy, and give notice of changes as the DPA sets out. You may object on reasonable grounds; if we cannot address your objection in good faith, you may discontinue the affected Subscription and receive a pro-rata refund of any unused prepaid Fees.

(d) If we become aware of a Security Incident affecting User Data, we will notify you without undue delay and in any event within 48 hours, describing its nature and scope, its known or suspected impact, and the steps taken or proposed to mitigate and remedy it. We will keep you reasonably informed and cooperate as the law requires.

(e) If a government or law-enforcement request seeks disclosure of User Data, we will, to the extent the law permits, notify you before disclosure, limit disclosure to what the law requires, and challenge overbroad requests where reasonably practicable.

(f) We keep backups under our backup processes. After termination, deleted data may remain in backups for up to 7 days; we protect those copies and they are deleted in the normal cycle.

6. Client obligations

(a) You agree to give us the documentation, information and assistance we reasonably need to provide the Solution.

(b) You warrant that you have obtained all necessary authorisations and consents from your clients to enter their data into the Solution, including for its transfer to the United States.

(c) You must review and approve all visa application data before submission. We are not responsible for inaccurate, incomplete, fraudulent or unlawful data provided by you or your clients.

(d) You warrant that all information and other Material you provide to us is complete, accurate and up to date, and you release us from liability for loss or damage caused or contributed to by Material you provide being incomplete, inaccurate or out of date.

(e) You indemnify us against all claims and losses arising from (i) your breach of applicable privacy or immigration laws, (ii) a lack of consents for the use of client data, or (iii) allegations of the unauthorised practice of law based on your use of the Solution.

(f) You must, and must ensure that all Users, comply with these Terms at all times. We have no liability for damage, loss or expense arising from your, your Personnel’s or any User’s breach of these Terms, and you indemnify us for it.

(g) You may upload Sensitive Information only where you have a lawful basis and all necessary notices, authorisations and consents, including for the cross-border transfers needed to provide the Solution. You must not, and must not encourage or permit any User, your Personnel or any third party to, without our prior written approval:

• use the Software other than for its intended purpose, or in a way that is illegal or fraudulent or facilitates illegal or fraudulent activity;
• upload material owned or copyrighted by a third party, or use the Software in a way that infringes anyone’s Intellectual Property Rights;
• copy, adapt, modify, tamper with, translate or create derivative works from the Software or Documentation, or remove any copyright, trade mark or other notice on them;
• publish the Software or Documentation, or sell, loan, transfer, sub-licence, hire or otherwise dispose of them, other than giving Users access as these Terms permit;
• integrate the Software with third-party data or software, or add to or change it (including through APIs), other than as our Documentation or written instructions allow;
• decompile or reverse engineer the Software or try to derive its source code, or circumvent any technological protection or security feature;
• make automated use of the Solution other than through the interfaces we provide;
• intimidate, harass, impersonate, stalk, threaten, bully or endanger any other User, or send unsolicited commercial content, spam or harassment through the Software;
• act in a way that may harm our reputation or that of associated parties, or is contrary to our interests or those of the Software; or
• share an Account or its login details with anyone else. You must tell us immediately of any unauthorised use of your Account, password or email, or any other actual or potential breach of the Solution’s security.

(h) If you become aware of misuse of your Subscription, errors in material on your Subscription, or difficulty accessing or using it, please contact us immediately using the details on our Website.

(i) You agree, and must ensure all Users agree, that information given through the Software, by us or another User, is general in nature and we take no responsibility for actions taken in reliance on it; and that we may cancel any Account at any time if we consider, in our absolute discretion, that it is being used in breach, or likely breach, of this clause 6.

7. Fees and payment

7.1 Fees

(a) You must pay the fees on our Website or in a written agreement between us (the “Fees”). Fees are in US dollars unless otherwise agreed.

(b) A business workspace is billed for the application forms created in it. For each billing month we issue an invoice for the forms created in that month, at the per-form price on our Website unless a written agreement between us sets a different plan, and charge it to the card you register through our Online Payment Partner. Any free forms we offer are described on our Website.

(c) An individual Subscription Package is paid in advance.

(d) Fees are non-refundable except as the law requires or these Terms provide.

(e) You are responsible for all applicable taxes (sales, use, VAT, GST, withholding) other than our Australian income tax. If taxes are withheld, you must gross up payments so we receive the full Fees.

(f) Late payments accrue interest at 1.5% per month and we may suspend access until payment is made.

7.2 GST

Unless otherwise stated, the Fees do not include GST. For any GST payable on a taxable supply by us, you must pay the GST, subject to our providing a tax invoice.

7.3 Card surcharges

We may charge a surcharge for payments made by credit, debit or charge card (including Visa, Mastercard or American Express).

7.4 Online Payment Partners

(a) We use third-party online payment partners, currently Stripe (card payments for business workspaces) and PayPal (individual purchases) (each an “Online Payment Partner”), to collect Fees.

(b) You acknowledge and agree that:

• payments processed by an Online Payment Partner are also subject to its terms, conditions and privacy policy, including Stripe’s and PayPal’s;
• you release us and our Personnel from all liability for loss, damage or injury arising from any act or omission of an Online Payment Partner, including any issue with the security or performance of its platform or any error in processing your payment; and
• we may correct, or instruct an Online Payment Partner to correct, any error in collecting your payment.

(c) You may reject an Online Payment Partner’s terms. If you do, we cannot provide the Subscription, and clause 13 applies.

8. Intellectual property and data

8.1 Software Content

(a) We retain ownership of all Materials provided to you in connection with the Software, including text, graphics, logos, design, icons, images, recordings, pricing, downloads and software (“Software Content”), and reserve all Intellectual Property Rights in the Software Content not expressly granted to you.

(b) We grant you a licence to use the Software Content for the purposes of the Software, including to make a temporary electronic copy of materials we provide for viewing and using them. You must not otherwise reproduce, transmit, adapt, distribute, sell, modify or publish them without our prior written consent or as the law permits.

8.2 User Data

(a) You remain the owner of all User Data. You grant us (and our Personnel) a non-exclusive, royalty-free, non-transferable, worldwide licence to use User Data only to the extent reasonably required to: (i) provide the Solution; (ii) comply with the law; (iii) detect and prevent security incidents and abuse; and (iv) produce aggregated and anonymised statistics for analytics and improving the Solution, without attempting to re-identify anyone.

(b) We will not sell User Data or use it for advertising or unrelated commercial purposes.

(c) We may remove any User Data at any time, including where we consider it inappropriate, offensive, illicit, illegal, pornographic, sexist, homophobic or racist.

(d) We may use material for marketing, testimonials, case studies and promotional materials as follows: material that is anonymised and does not identify you or your clients, without further consent; and identifiable material (including your name, logo, business details or client stories) only with your prior written consent, which may be given by email or electronic acceptance. By accepting these Terms you consent in principle to our requesting such material, but we will always seek approval for identifiable use.

(e) You are responsible for sharing User Data only with intended recipients and for ensuring it is appropriate and does not contravene these Terms. You warrant that our use of User Data as these Terms allow will not infringe any third party’s Intellectual Property Rights, and you indemnify us against all losses, claims, expenses, damages and liabilities (including taxes, fees or costs) arising from such an infringement or from your breach of this clause 8.2.

9. Government system dependency and sanctions

(a) You acknowledge that the Solution interacts with the U.S. Government’s DS-160 website. We do not control that system and are not responsible for its downtime, outages, interface changes, captchas or rejections. We will use commercially reasonable efforts to adapt the Solution to its changes, but we disclaim liability for delays, errors or refusals caused by it.

(b) You represent that you and your end users are not located in, organised under the laws of, or ordinarily resident in any jurisdiction subject to comprehensive sanctions, and are not on any applicable sanctions list. You will not use the Solution in breach of export control or sanctions laws. We may suspend or end the Solution immediately for a suspected breach of this clause.

10. Confidentiality

(a) Except as these Terms contemplate, a party must not, and must not permit its Personnel to, use or disclose to anyone Confidential Information disclosed to it by the other party without the other party’s prior written consent.

(b) Each party must promptly tell the other if it learns of any potential, actual or suspected loss, misappropriation, unauthorised access to, or disclosure or use of, the other party’s Confidential Information, or any other compromise of its security, confidentiality or integrity. The notifying party will investigate and help the other party with any related investigation.

(c) On request or termination, each party will promptly return or securely destroy the other’s Confidential Information, except copies kept in backups or as the law requires, which remain confidential.

11. Privacy and data protection

(a) Roles. For User Data in a business workspace, you are the controller (or equivalent) and we are the processor (or equivalent). You determine the purposes and means of the processing; we process only on your documented instructions, which include these Terms, the DPA and your normal use of the Solution. For personal data subject to the GDPR or the UK GDPR, the DPA applies and prevails. We handle account holders’ account and billing data, and individual accounts, as a controller under our Privacy Policy.

(b) Compliance. Each party will comply with the Data Protection Laws that apply to it, including the Australian Privacy Act 1988 (Cth). You are responsible for giving the required notices and obtaining all consents and authorisations needed for processing User Data and disclosing it across borders.

(c) Confidentiality of Personnel. Everyone we authorise to process User Data is bound by a written confidentiality obligation and receives appropriate privacy and security training.

(d) Assistance. Taking into account the nature of the processing, we will give you reasonable assistance, at your cost where substantial effort is needed, with (i) data subject requests and (ii) your obligations on security, breach notification, privacy impact assessments and consultation with regulators.

(e) Return and deletion. On termination, we make an export of your User Data available for 30 days, and then delete it, subject to clause 5(f) and to retention the law requires.

(f) Cross-border transfers. You instruct us to process and transfer User Data to the United States, where our servers and our Subprocessors are, as listed in the DPA and the Privacy Policy. You will ensure you have all permissions needed for those transfers.

(g) Audits. No more than once in any 12-month period, on written request, we will provide a summary of our security controls (such as an independent audit report or answers to a security questionnaire). Where the GDPR or UK GDPR applies, you also have the audit rights in the DPA.

12. Liability

12.1 Warranties and limitations

(a) We warrant that during your Subscription the Software will perform substantially in accordance with the Documentation; the Solution will be provided as described to you in, and subject to, these Terms; and, to our knowledge, using the Software in accordance with these Terms will not infringe any third party’s Intellectual Property Rights.

(b) We will correct errors, bugs or defects in the Software that arise during your Subscription and that you tell us about, unless they result from the Software’s interaction with any solution, hardware, software or service we have not approved in writing; from misuse of the Software; or from your use of it other than in accordance with these Terms or the Documentation.

(c) While we use our best endeavours to keep the Solution working for its intended purpose, you acknowledge that from time to time it may have errors or defects; may not be accessible; may not deliver messages promptly or at all; and may carry information that is not accurate or true.

(d) To the maximum extent the law permits, all express or implied representations and warranties not stated in these Terms are excluded.

(e) Nothing in these Terms limits the operation of the Australian Consumer Law in the Competition and Consumer Act 2010 (Cth) (the “ACL”). Under the ACL you may be entitled to remedies such as a refund, replacement or repair if there is a failure with the goods or services we provide.

12.2 Liability

(a) To the maximum extent the law permits, each party’s total liability arising out of or in connection with these Terms is limited to the Fees you paid in the 12 months before the event giving rise to the liability.

(b) Despite clause 12.2(a), our liability for direct losses arising from a proven Security Incident caused by our breach of clause 5(b) is capped at twice the amount in clause 12.2(a).

(c) These caps do not apply to (i) your payment obligations; (ii) your indemnities under clauses 4.3(d) and 6(e); or (iii) either party’s liability for fraud or wilful misconduct.

12.3 Consequential loss

To the maximum extent the law permits, neither party is liable for indirect or consequential loss, including lost visa opportunities, travel or accommodation costs, loss of profits, revenue or goodwill, or business interruption, except for a party’s liability for fraud, personal injury, death or loss of or damage to tangible property, or to the extent the Competition and Consumer Act 2010 (Cth) does not allow the liability to be excluded.

13. Cancellation

13.1 Cancellation at any time

Either party may end a Subscription by written notice. A Subscription Package may be cancelled before its forms are used; we refund Fees for unused forms only where the law requires or we agree in writing. For a business workspace, Fees for forms created before cancellation remain payable.

13.2 Cancellation for Breach

Either party may cancel your Subscription immediately by written notice if there has been a Breach of these Terms. A “Breach” occurs where a party (the “Notifying Party”) considers that the other party (or its Personnel or Users) is in breach of these Terms and notifies it; the other party is given 10 Business Days to remedy the breach; and the breach has not been remedied within those 10 Business Days or another period the parties agree in writing.

13.3 Effect of termination

On termination:

(a) your access to the Software and your Account ends, and your User Data remains available for export for 30 days under clause 11(e), after which we have no responsibility to store it, and you release us from loss or damage arising from our not keeping it after that;

(b) unless agreed in writing, Fees that have accrued, or that would otherwise have been payable for the rest of a committed period, remain payable, and to the maximum extent the law permits no Fees already paid are refundable; and

(c) each party must comply with the obligations that by their nature are intended to survive the end of these Terms.

14. Dispute resolution

(a) A party claiming that a dispute has arisen under or in connection with these Terms must not start court proceedings about it, other than for urgent interlocutory relief, without first complying with this clause.

(b) A party that requires a dispute to be resolved must give the other party written notice with reasonable details of the dispute, requiring its resolution under this clause.

(c) Once that notice is given, each party must use its best efforts to resolve the dispute in good faith. If it is not resolved within 14 days (or another period the parties agree in writing), either party may take legal proceedings.

15. Force majeure

(a) We are not liable for any delay or failure to perform our obligations under these Terms caused by a Force Majeure Event, and our affected obligations are suspended while it lasts, to the extent it affects them.

(b) If a Force Majeure Event occurs, we will use reasonable endeavours to tell you of its reasonable details and, so far as known, how far we will be unable to perform, or be delayed in performing, our obligations.

(c) A “Force Majeure Event” means any act of God, lightning strike, meteor strike, earthquake, storm, flood, landslide, explosion or fire; strike or other industrial action outside our control; war, terrorism, sabotage, blockade, revolution, riot, insurrection, civil commotion, epidemic or pandemic; any decision of a government authority about COVID-19, or threat of COVID-19, beyond our reasonable control; and U.S. Government website outages, changes to the DS-160 portal, and captchas or anti-bot measures beyond our control.

16. Notices

(a) A notice or other communication under these Terms must be in writing and in English, and sent by email to the other party’s email address: for you, the address on your Account or in your written agreement with us; for us, privacy@ds160.io for privacy matters, or the address on our Website. Either party may change its address by notice.

(b) Unless the sender knows or reasonably ought to suspect that an email was not delivered, notice is taken to be given 24 hours after it was sent (or, if that falls on a Saturday, Sunday or public holiday in New South Wales, on the next business day there), or when the other party replies, whichever is earlier.

17. General

17.1 Governing law and jurisdiction

These Terms are governed by the law of New South Wales, Australia. Each party irrevocably submits to the exclusive jurisdiction of the courts of New South Wales, Australia, and the courts of appeal from them, for any proceedings arising out of or in connection with these Terms, and waives any objection to the venue of any legal process on the basis that it has been brought in an inconvenient forum.

17.2 Waiver

No party may rely on the words or conduct of another party as a waiver of any right unless the waiver is in writing and signed by the party granting it.

17.3 Severance

Any term of these Terms that is wholly or partly void or unenforceable is severed to that extent, without affecting the validity and enforceability of the rest.

17.4 Joint and several liability

An obligation or liability assumed by, or a right conferred on, two or more persons binds or benefits them jointly and severally.

17.5 Assignment

A party may not assign, novate or otherwise transfer any of its rights or obligations under these Terms without the other party’s prior written consent.

17.6 Entire agreement

These Terms, together with the DPA and any written agreement between us, are the entire agreement between the parties and supersede any prior negotiation, conduct, arrangement, understanding or agreement about their subject matter.

17.7 Interpretation

In these Terms: the singular includes the plural and vice versa; ”$” and “dollar” mean US dollars; words of one gender include every gender; any grammatical form of a defined word has a corresponding meaning; “person” and “you” include an individual, an individual’s estate, a corporation, an authority, an association, consortium or joint venture, a partnership, a trust and any other entity; a party includes its executors, administrators, successors and permitted assigns; a clause, schedule or annexure means one of these Terms, and these Terms include their schedules and annexures; a document means that document as varied, novated, ratified or replaced; headings and bold type are for convenience only; “includes” is not a word of limitation; and no provision is interpreted against a party because that party prepared it.

Definitions

Term	Definition
Business Day	a day other than a Saturday, Sunday or public holiday in New South Wales.
Confidential Information	information of or provided by a party that is by its nature confidential, is designated by that party as confidential, or that the other party knows or ought to know is confidential, but not information that is or becomes public knowledge without a breach of confidentiality.
Data Protection Laws	the privacy and data protection laws that apply to a party’s processing of Personal Information in connection with the Solution.
Documentation	all manuals, help pages and other documents we supply to you about the Software, electronic or printed.
DPA	our Data Processing Agreement at ds160.io/dpa.
Intellectual Property Rights	all present and future intellectual and industrial property rights throughout the world, registered or not, including copyright, trade marks, designs, patents, moral rights, circuit layout rights, trade, business, company and domain names, other proprietary rights, trade secrets, know-how, technical data, confidential information and the right to have information kept confidential, and any rights to register them.
Material	tangible and intangible information, documents, reports, software (including source and object code), inventions, data and other materials in any media.
Personnel	a party’s officers, employees, contractors (including subcontractors) and agents.
Personal Information	information about an identified or reasonably identifiable individual, as defined under the applicable Data Protection Laws.
Security Incident	unauthorised access to or disclosure of User Data in our systems leading to its accidental or unlawful destruction, loss, alteration, or unauthorised disclosure or access.
Sensitive Information	information given special protection under applicable Data Protection Laws, including government identifiers, passport and visa details, biometric data, health information, racial or ethnic origin, criminal records, and information about minors.
Subprocessor	a third party we engage to process User Data on our behalf.
User	you and anyone you give access to the Software, including your staff and the clients you send intake links to.
User Data	any files, data, documents, information or other Materials uploaded to the Software by you or any other User, or that you, your Personnel or Users otherwise provide to us under or in connection with these Terms, including the Intellectual Property Rights in them.
Website	ds160.io and any other website we operate in connection with the Solution.