Privacy Policy
Last updated: October 2, 2026 • Effective immediately
SurgeDL is an offline-first desktop software application. We do not track, log, analyze, or sell your personal downloads, media URLs, or files. What you download stays strictly on your local computer.
1. Roles of Data Controllers (Paddle & BizmoLabs)
Under global privacy legislation including the European Union General Data Protection Regulation (EU GDPR), United Kingdom Data Protection Act, and California Consumer Privacy Act (CCPA):
- Paddle.com Market Ltd (Merchant of Record): Acts as an independent Data Controller for personal and financial information collected during order checkout (buyer full name, email address, billing postal address, payment card details, IP address, and transaction records for tax compliance and fraud prevention).
- BizmoLabs (Software Developer): Acts as an independent Data Controller for software license issuance, machine activation count records, and customer technical support communications.
2. Information We Do NOT Collect
When you run the SurgeDL desktop application:
- We do NOT collect, inspect, or log the URLs, links, or filenames of any files you download.
- We do NOT monitor or store clipboard content beyond transient local in-memory string matching for URL detection.
- We do NOT log or store media streams or converted audio/video files (all FFmpeg conversions happen 100% locally on your device).
- We do NOT use third-party analytics trackers, tracking cookies, or advertising SDKs inside the desktop app.
- We do NOT sell, rent, or trade your personal information to data brokers or advertisers.
3. Information Collected During Purchase & Activation
When you purchase a commercial license for SurgeDL PRO:
- Order & Billing Data: Managed securely by Paddle.com. Your credit card numbers and banking details never touch BizmoLabs servers.
- Registration Records: Paddle provides BizmoLabs with your purchase email address, purchaser name, and transaction identifier. We store this strictly to generate your serial key and enable self-service lost key recovery.
- Device Activation Telemetry: When you register SurgeDL, the application sends a one-way cryptographic hash of your system identifier (Machine GUID) to our licensing server to verify compliance with the 2-PC personal license limit. No personally identifiable hardware attributes (MAC address, IP geolocation, or serial numbers) are retained.
4. Website Cookies & Server Logs
When you visit our website (surgedl.com):
- We use standard HTTP server access logs (recording client IP address, user-agent, and requested page URL) strictly for DDoS mitigation, load balancing, and server security. These logs are automatically purged after thirty (30) days.
- We do not use invasive third-party cross-site tracking cookies.
5. Your Rights Under GDPR and CCPA
Depending on your location, you have the right to:
- Request access to the personal data we hold about you (your registered email and license key records).
- Request rectification of inaccurate registration details.
- Request deletion of your licensing records (note: revoking registration data will disable future license key recovery).
- Lodge a complaint with a supervisory data protection authority in your country.
6. Data Retention & Security
We employ industry-standard TLS 1.3 cryptographic protocols for all client-server communications. License database records are maintained on secured cloud infrastructure with strict access controls.
7. Contact the Data Protection Officer
To exercise any privacy rights or submit questions regarding this policy, contact our data protection desk:
BizmoLabs Data Protection
Operating Location: Makandura, Sri Lanka
Email: privacy@bizmolabs.com or support@surgedl.com
For transaction data managed by Paddle, please visit: paddle.com/legal/privacy