Introduction

Last Updated: May 24, 2026
This Privacy Policy explains how SP09, Inc., a Delaware corporation ("SP09," "we," "us," or "our"), collects, uses, and shares information in connection with the Dirt platform, websites, and related services (collectively, the "Service"). Dirt is a business-to-business platform for land development pre-development workflows, sold to businesses in the United States.
This Policy is written for a US audience. If you are an individual interacting with us (for example, a representative of a customer or a website visitor), this Policy describes your rights, including under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA").

1. Scope and the Two Kinds of Data We Handle

It helps to distinguish two categories:

• Customer Data — the proprietary data that customers and their authorized users upload into the Service (such as site information, deal pipeline, and project files). Our handling of Customer Data is governed primarily by our Terms of Service and any agreement with the customer. We act as a service provider / processor for this data, handling it on the customer's behalf and under their instructions.
• Personal information we collect directly — information about the individuals who visit our sites, create accounts, communicate with us, or use the Service. This Policy focuses on this category.

2. Information We Collect

Information you provide:

• Account and contact details (name, business email, phone, company, role).
• Billing information (billing contact, address; payment card details are collected and processed by our payment processor, not stored by us — see Section 5).
• Communications you send us (support requests, emails, survey responses).

Information collected automatically:

• Usage and device data (log data, IP address, browser type, pages viewed, features used, timestamps).
• Cookies and similar technologies (see Section 7).

Information from third parties:

• Public records and third-party data providers that supply parcel, zoning, environmental, utility, and related data used to build Platform Data. This data generally concerns properties and parcels rather than individuals, but may incidentally include names associated with public property records.

3. How We Use Information

We use information to: provide, operate, secure, and improve the Service; create and manage accounts; process payments and send invoices; respond to inquiries and provide support; send service and transactional communications; send product updates and marketing (subject to your choices); monitor for fraud, abuse, and security incidents; comply with legal obligations; and compile and maintain Platform Data.
AI and model training. We do not use Customer Data to train, fine-tune, or improve machine learning models, except where data has been fully aggregated and de-identified such that it cannot reasonably be associated with any customer, user, or project. We do not sell Customer Data or personal information.

4. How We Share Information

We share information with:

• Service providers / subprocessors that help us operate (hosting, analytics, payment processing, email, customer support, and AI model providers), bound by contracts limiting their use of the information.
• Professional advisors (lawyers, accountants, auditors) as needed.
• Authorities or others when required by law, to enforce our agreements, or to protect rights, safety, and security.
• In a business transfer (merger, acquisition, financing, or sale of assets), subject to this Policy.

5. Payments

When you pay by card, payment is processed by our third-party payment processor (currently Stripe). Card details are provided directly to the processor and handled under its terms and privacy policy; we do not store full card numbers. When you pay by invoice and bank transfer, we collect billing contact and remittance details necessary to process the transaction.

6. Data Retention

We retain personal information for as long as needed to provide the Service, maintain your account, comply with legal obligations, resolve disputes, and enforce agreements. Customer Data is retained and deleted according to our Terms of Service and customer instructions (default export window of 30 days after termination, then deletion in the ordinary course, subject to legal retention needs).

7. Cookies and Analytics

We use cookies and similar technologies to operate the sites, remember preferences, and understand usage. You can control cookies through your browser settings; disabling some cookies may affect functionality.

8. Your Privacy Rights (California / CCPA-CPRA)

Depending on your state of residence, you may have rights to:

• Know / access the personal information we have collected about you.
• Delete personal information, subject to exceptions.
• Correct inaccurate personal information.
• Opt out of sale or sharing for cross-context behavioral advertising (note: we do not sell or share as defined).
• Limit use of sensitive personal information (we do not use sensitive personal information for purposes requiring this right).
• Non-discrimination for exercising your rights.

9. Security

We use administrative, technical, and physical safeguards designed to protect personal information. No system is perfectly secure, and we cannot guarantee absolute security. If you have a security concern, contact us at the address below.

10. Children

The Service is not directed to individuals under 18 and is intended for business use. We do not knowingly collect personal information from children.

11. Changes to This Policy

We may update this Policy from time to time. We will revise the "Last Updated" date and, for material changes, provide additional notice (such as by email or in-product notice).

12. Contact Us

For privacy questions or to exercise your rights, contact:
Email: legal@godirt.ai
SP09 Inc. 6 Liberty Square, #266 Boston, MA 02109