DNA's Policies, Terms and Legal Stuff
The rough print and the fine print. We try to make all our policies as clear, fair, and readable as possible.
Last updated: 11 May 2020
The privacy of your data — and it is your data, not ours! — is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.
This policy applies to all products build and maintained by DNA, DNA Cleaning Products, Old School Games.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for a DNA service, we typically ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.
When you pay for a DNA service, we ask for your credit card and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in South Africa, to detect fraudulent credit card transactions, and to print on your invoices.
We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.
We also log full IP addresses used to sign up a product account. We keep this record forever because they are used to mitigate spammy signups.
Web analytics data — described further below — are also tied temporarily to IP addresses to assist with troubleshooting cases. We blind all web analytics data after 30 days.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services. We blind all of these individual identifiers after 30 days.
Historically — including within the last 12 months — we have used third-party web analytics software. We are in the process of removing third party web analytics software from our other products and web properties.
Cookies and Do Not Track
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to see which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write DNA with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
Information we do not collect
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, or gender expression. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. You can see the list of third-party services we use in each service. Having subprocessors means we are using technology to access your data. No DNA human looks at your data for these purposes.
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.
Your Rights With Respect to Your Information
At DNA, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US and elsewhere. DNA recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
Right to Correction. You have the right to request correction of your personal information.
Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Basecamp services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to
Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data).
Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
Right to Non-Discrimination. This right stems from the CCPA. We do and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at or at Basecamp, LLC, 30 North Racine Avenue, Suite 200, Chicago, IL 60607 USA. To identify your specific authority to file a complaint or find out more about GDPR, EU individuals should go to
When you delete data in your service accounts
In many of our applications, we give you the option to trash data. Anything you trash on your product accounts while they are active will be kept in an accessible trash can for up to 30 days (it varies a little by product). After that, the trashed data are no longer accessible via the application and are deleted from our active servers within the next 30 days. We also have some backups of our application databases, which are kept for up to another 30 days. In total, when you trash things in our applications, they are purged within 90 days from all of our systems and logs. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome so if you change your mind you’ll need to do so before your data are deleted from our active servers.
We also delete your data after an account is cancelled. In this case, there is no period of data being kept in an accessible trash can so your data are purged within 60 days. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts. Please refer to our Cancellation policy for more details.
EU-US and Swiss-US Privacy Shield policy
The GDPR requires that data transfer out of the EU must only happen to countries deemed as having adequate data protection laws. The United States generally doesn’t meet that requirement. Privacy Shield is an agreement between certain European jurisdictions and the United States that allows for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary.
We comply with the frameworks for EU, UK, and Swiss data that are transferred into the United States
DNA is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Privacy Shield Frameworks.
The Privacy Shield Frameworks uphold specific principles, many of which are already outlined in the section on Your Rights. For clarity, pursuant to the Privacy Shield Frameworks, the following principles apply to all EU, UK, and Swiss data that has been transferred into the United States:
Individuals have the right to access their personal data and to update, correct, and/or amend information that is incomplete. Individuals also have the right to request erasure of personal information that has been processed in violation of the principles. Individuals wishing to exercise these rights may do so by by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at or at Basecamp, LLC, 30 North Racine Avenue, Suite 200, Chicago, IL 60607 USA.
We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
We do not sell personal data nor do we permit it to be used for reasons other than those for which it was originally provided. If this practice should change in the future, we will update this policy accordingly and provide individuals with opt-out or opt-in choice as appropriate.
We may be required to release personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements
We commit to resolving all complaints
Basecamp (the company) has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. This service is provided at no cost to you. Please do not submit GDPR complaints to BBB EU Privacy Shield.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. To learn more, please see the Privacy Shield Annex 1 at
Location of Site and Data
Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our company blog.
Terms of Service
Last updated: 11 May, 2020
From everyone at DNA, thank you for using our services! We create them to help you do your best work. Because we don’t know every one of our clients personally, we have to put in place some Terms of Service to help keep the ship afloat.
When we say “Company”, “we”, “our”, or “us” in this document, we are referring to DNA.
When we say “Services”, we mean any product created and maintained by DNA.
We may update these Terms of Service in the future. Typically these changes have been to clarify some of these terms by linking to an expanded related policy. Whenever we make a significant change to our policies, we will also announce them on our company blog.
When you use our Services, now or in the future, you are agreeing to the latest Terms of Service. That’s true for any of our existing and future products and all features that we add to our Services over time. There may be times where we do not exercise or enforce any right or provision of the Terms of Service; in doing so, we are not waiving that right or provision. These terms do contain a limitation of our liability.
If you violate of any of the terms, we may terminate your account. That’s a broad statement and it means you need to place a lot of trust in us. We do our best to deserve that trust by being open about who we are, how we work, and keeping an open door to your feedback.
You are responsible for maintaining the security of your account and password. The Company cannot and will not be liable for any loss or damage from your failure to comply with this security obligation.
You may not use the Services for any purpose outlined in our Use Restrictions policy.
You are responsible for all content posted and activity that occurs under your account. That includes content posted by others who either: (a) have access to your login credentials; or (b) have their own logins under your account.
You must be a human. Accounts registered by “bots” or other automated methods are not permitted.
Payment, Refunds and Plan Changes
If you are using a free version of one of our Services, it is really free: we do not ask you for your credit card and — just like for customers who pay for our Services — we do not sell your data.
For paid Services that offer a free trial, we explain the length of trial when you sign up. After the trial period, you need to pay in advance to keep using the Service. If you do not pay, we will freeze your account and it will be inaccessible until you make payment. If your account has been frozen for a while, we will queue it up for auto-cancellation. See our Cancellation policy for more details.
If you are upgrading from a free plan to a paid plan, we will charge your card immediately and your billing cycle starts on the day of upgrade. For other upgrades or downgrades in plan level, the new rate starts from the next billing cycle.
All fees are exclusive of all taxes, levies, or duties imposed by taxing authorities. Where required, we will collect those taxes on behalf of the taxing authority and remit those taxes to taxing authorities. Otherwise, you are responsible for payment of all taxes, levies, or duties.
We process refunds according to our Fair Refund policy.
Cancellation and Termination
You are solely responsible for properly canceling your account. Within each of our Services, we provide a simple no-questions-asked cancellation link. You can find instructions for how to cancel your account in our Cancellation policy. An email or phone request to cancel your account is not automatically considered cancellation. If you need help cancelling your account, you can always contact our Support team.
All of your content will be inaccessible from the Services immediately upon cancellation. Within 30 days, all content will be permanently deleted from active systems and logs. Within 60 days, all content will be permanently deleted from our backups. We cannot recover this information once it has been permanently deleted.
If you cancel the Service before the end of your current paid up month, your cancellation will take effect immediately, and you will not be charged again. We do not automatically prorate unused time in the last billing cycle. See our Fair Refund policy for more details.
We have the right to suspend or terminate your account and refuse any and all current or future use of our Services for any reason at any time. Suspension means you and any other users on your account will not be able to access the account or any content in the account. Termination will furthermore result in the deletion of your account or your access to your account, and the forfeiture and relinquishment of all content in your account. We also reserve the right to refuse the use of the Services to anyone for any reason at any time. We have this clause because statistically speaking, out of the hundreds of thousands of accounts on our Services, there is at least one doing something nefarious. There are some things we staunchly stand against and this clause is how we exercise that stance. For more details, see our Use Restrictions policy.
Verbal, physical, written or other abuse (including threats of abuse or retribution) of Company employee or officer will result in immediate account termination.
Modifications to the Services and Prices
We make a promise to our customers to support our Services until the end of the Internet. That means when it comes to security, privacy, and customer support, we will continue to maintain any legacy Services. Sometimes it becomes technically impossible to continue a feature or we redesign a part of our Services because we think it could be better or we decide to close new signups of a product. We reserve the right at any time to modify or discontinue, temporarily or permanently, any part of our Services with or without notice.
Sometimes we change the pricing structure for our products. When we do that, we tend to exempt existing customers from those changes. However, we may choose to change the prices for existing customers. If we do so, we will give at least 30 days notice and will notify you via the email address on record. We may also post a notice about changes on our websites or the affected Services themselves.
Uptime, Security and Privacy
Your use of the Services is at your sole risk. We provide these Services on an “as is” and “as available” basis. We do not offer service-level agreements for our Services.
We reserve the right to temporarily disable your account if your usage significantly exceeds the average usage of other customers of the Services. Of course, we’ll reach out to the account owner before taking any action except in rare cases where the level of use may negatively impact the performance of the Service for other customers.
We take many measures to protect and secure your data through backups, redundancies, and encryption. We enforce encryption for data transmission from the public Internet. There are some edge cases where we may send your data through our network unencrypted.
To help you with support requests you make. We’ll ask for express consent before accessing your account.
To safeguard DNA. We’ll look at logs and metadata as part of our work to ensure the security of your data and the Services as a whole. If necessary, we may also access accounts as part of an abuse report investigation.
To the extent required by applicable law.
We use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Services.
Copyright and Content Ownership
All content posted on the Services must comply with U.S. copyright law.
We claim no intellectual property rights over the material you provide to the Services. All materials uploaded remain yours.
We do not pre-screen content, but reserve the right (but not the obligation) in our sole discretion to refuse or remove any content that is available via the Service.
You agree not to reproduce, duplicate, copy, sell, resell or exploit any portion of the Services, use of the Services, or access to the Services without the express written permission by the Company.
You must not modify another website so as to falsely imply that it is associated with the Services or the Company.
Features and Bugs
We design our Services with care, based on our own experience and the experiences of customers who share their time and feedback. However, there is no such thing as a service that pleases everybody. We make no guarantees that our Services will meet your specific requirements or expectations.
We also test all of our features extensively before shipping them. As with any software, our Services inevitably have some bugs. We track the bugs reported to us and work through priority ones, especially any related to security or privacy. Not all reported bugs will get fixed and we don’t guarantee completely error-free Services.
We mention liability throughout these Terms but to put it all in one section:
You expressly understand and agree that the Company shall not be liable, in law or in equity, to you or to any third party for any direct, indirect, incidental, lost profits, special, consequential, punitive or exemplary damages, including, but not limited to, damages for loss of profits, goodwill, use, data or other intangible losses (even if the Company has been advised of the possibility of such damages), resulting from:
(i) the use or the inability to use the Services;
(ii) the cost of procurement of substitute goods and services resulting from any goods, data, information or services purchased or obtained or messages received or transactions entered into through or from the Services;
(iii) unauthorized access to or alteration of your transmissions or data;
(iv) statements or conduct of any third party on the service;
(v) or any other matter relating to this Terms of Service or the Services, whether as a breach of contract, tort (including negligence whether active or passive), or any other theory of liability.
In other words: choosing to use our Services does mean you are making a bet on us. If the bet does not work out, that’s on you, not us. We do our darnedest to be as safe a bet as possible through careful management of the business; investments in security, infrastructure, and talent; and in general giving a damn. If you choose to use our Services, thank you for betting on us.
If you have a question about any of the Terms of Service, please contact our Support team.
Terms of Service
Last updated: 11 May 2020
We want satisfied customers, not hostages. That’s why we make it easy for you to cancel your account directly in all of our apps — no phone calls required, no questions asked.
Our legal responsibility is to account owners, which means we cannot cancel an account at the request of anyone else. If for whatever reason you no longer know who the account owner is, contact us. We will gladly reach out to any current account owners at the email addresses we have on file.
What happens when you cancel?
You won’t be able to access your account once you cancel, so make sure you download everything you want to keep beforehand.
We’ll permanently delete your account data within 30 days from our servers and logs, and within 60 days from our backups. Retrieving data for a single account from a backup isn’t possible, so if you change your mind you’ll need to do it within the first 30 days. Data can’t be recovered once it has been permanently deleted.
We won’t bill you again once you cancel. We don’t automatically prorate any unused time you may have left but if you haven’t used your account in months or just started a new billing cycle, contact us for a fair refund. We’ll treat you right.
We may cancel accounts if they have been inactive for an extended period:
For trial accounts: 30 days after a trial has expired without being upgraded
For frozen accounts: 180 days after being frozen due to billing failures
For free accounts: after 365 days of inactivity
We also retain the right to suspend or terminate accounts for any reason at any time, as outlined in our Terms of Service. In practice, this generally means we will cancel your account without notice if we have evidence that you are using our products to engage in abusive behaviour.
A Fair Refund Policy
Bad refund policies are infuriating. You feel like the company is just trying to rip you off. We never want our customers to feel that way, so our refund policy is simple: If you’re ever unhappy with our products* for any reason, just contact our support team and we’ll take care of you.
Examples of full refunds we'd grant.
If you were just charged for your next month of service but you meant to cancel, we’re happy to refund that extra charge.
If you forgot to cancel your account a couple months ago and you haven’t used it since then, we’ll give you a full refund for a few back months. No problem.
If you tried one of our products for a couple months and you just weren’t happy with it, you can have your money back.
Examples of partila refunds or credits we'd grant.
If you forgot to cancel your account a year ago, and there’s been activity on your account since then, we’ll review your account usage and figure out a partial refund based on how many months you used it.
If you upgraded your account a few months ago to a higher plan and kept using it in general but you didn’t end up using the extra features, projects, or storage space, we’d consider applying a prorated credit towards future months.
If we had extended downtime (multiple hours in a day, or multiple days in a month) or you emailed customer service and it took multiple days to get back to you, we’d issue a partial credit to your account.
Get in Touch
At the end of the day, nearly everything on the edges comes down to a case-by-case basis. Send us a note, tell us what’s up, and we’ll work with you to make sure you’re happy.
*This policy applies to any product and or service created and owned by DNA.
Last updated: 11 May, 2020
We are proud to help people like you and us to a better way of doing business. We also recognize that technology is an amplifier: it can enable the helpful and the harmful. That’s why we’ve established this policy. If you have an account with any of our services, you can’t use them for any of the restricted purposes listed below. If we find out you are, we will take action.
Child exploitation, sexualization, or abuse: We don’t tolerate any activities that create, disseminate, or otherwise cause child abuse. Keep away and stop. Just stop.
Doxing: If you are using DNA's services to share other peoples’ private personal information for the purposes of harassment, we don’t want anything to do with you.
Infringing on intellectual property: You can’t use DNA's services to make or disseminate work that uses the intellectual property of others beyond the bounds of fair use.
Malware or spyware: Code for good, not evil. If you are using our products to make or distribute anything that qualifies as malware or spyware — including remote user surveillance — begone.
Phishing or otherwise attempting fraud: It is not okay to lie about who you are or who you affiliate with to steal from, extort, or otherwise harm others.
Spamming: No one wants unsolicited commercial emails. We don’t tolerate folks (including their bots) using DNA's services for spamming purposes. If your emails don’t pass muster with CAN-SPAM or any other anti-spam law, it’s not allowed.
Violence, or threats thereof: If an activity qualifies as violent crime in the South Africa or where you live, you may not use DNA's services to plan, perpetrate, or threaten that activity.
We’ve outlined these restrictions to be clear about what we won’t stand for. That said, this list is by no means exhaustive. We will make changes over time.
How to Report Abuse
See someone using a DNA's services for one of the restricted purposes? Let us know by emailing and we will investigate. If you’re not 100% sure, report it anyway.
Please share as much as you are comfortable with about the account, the content or behaviour you are reporting, and how you found it. Sending us a URL or screenshots is super helpful. If you need a secure file transfer, let us know and we will send you a link. We will not disclose your identity to anyone associated with the reported account. For copyright cases, we’ve outlined extra instructions on how to notify us about infringement claims.
Someone on our team will respond within one business day to let you know we’ve begun investigating. We will also let you know the outcome of our investigation (unless you ask us not to or we are not allowed to under law).
*This policy and process applies to any product created and owned by DNA.