Softonic

Summary

The provided diff does not include the actual amended contract language. It only states:

> “Added approximately 96 words to the document”

Because the additions, deletions, and replacements are not shown, it is not possible to determine:

• What contractual terms changed;
• Whether customer data may be used to train, fine-tune, or improve AI models;
• Whether data may be shared with affiliates, service providers, or third parties;
• Whether the customer retains ownership or control of its data;
• Whether confidential information or personal data may be included in model training;
• Whether the provider must delete or return data;
• Whether new consent, opt-out, or notice requirements apply;
• Whether liability, security, indemnity, or regulatory obligations changed.

AI Training Risk Assessment

No conclusion can be reached regarding AI-model training because the actual 96 added words are missing. The added language should be reviewed specifically for phrases such as:

• “train,” “fine-tune,” “develop,” “improve,” or “enhance” models;
• “inputs,” “customer content,” “usage data,” or “de-identified data”;
• rights granted to use data “in perpetuity,” “irrevocably,” or on a “worldwide” basis;
• rights to retain data after termination;
• permission to combine customer data with other customers’ data;
• exclusions for confidential information or personal data;
• opt-out, consent, deletion, or data-retention mechanisms.

Required Information

Please provide the full diff, including the text inside the {}, [], and []{} markers. Without that language, a substantive legal-risk analysis would be speculative.

Summary

The provided diff does not include the actual amended language. It only states:

> “Added approximately 341 words to the document”

Because the specific additions, deletions, and replacements are missing, it is not possible to reliably identify:

• Changes to customer data rights or permitted uses
• Whether customer data may be used to train, fine-tune, validate, or improve AI models
• Whether data may be shared with affiliates, vendors, or model providers
• New consent, opt-out, or deletion rights
• Changes to confidentiality, security, retention, or anonymization obligations
• Allocation of intellectual-property rights in data, inputs, outputs, or trained models
• New liability exclusions, indemnities, or limitations of liability
• Whether the changes apply retroactively to previously collected data

AI Training Review

No conclusion can be reached about AI-model training because the relevant contractual language is not included. In particular, the missing text should be reviewed for terms such as:

• “train,” “fine-tune,” “improve,” or “develop” models
• “inputs,” “prompts,” “customer content,” or “usage data”
• “de-identified,” “aggregated,” or “anonymized” information
• Use by “service providers,” “third-party model providers,” or “affiliates”
• Customer opt-out, deletion, or restriction mechanisms
• Ownership or licensing rights relating to customer data and model outputs

Required Information

Please provide the full marked-up diff, including the text inside the addition, deletion, and replacement markers. Without the actual language, any legal-risk assessment would be speculative.

Summary of Important Changes and Risks

1. Broader acceptance of terms

• Acceptance is now framed as implied acceptance of all sections of the Terms, not only the terms relating to the particular service being used.
• Merely accessing, browsing, or downloading content from Softonic websites may constitute acceptance.
• Users are told to review the Terms each time they access or use different services.
• Softonic expressly reserves the right to amend the Terms from time to time, including provisions relating to services the user may not currently use.

Risk: Users may be bound by provisions they have not actively accepted or do not yet use. The drafting also appears repetitive and contains apparent typographical errors, including “lmplied” and inconsistent references to “Publishing Centre” and “Publishing Center.”

2. Account and eligibility provisions

• The account section is reorganized and now states that users must create an account through Softonic’s registration process to access certain features.
• A new or clarified requirement states that users must be of legal age to form a contract.

Risk: The change may restrict access for minors and creates a clearer contractual eligibility requirement, but the interaction with parental consent and local age-of-majority rules is not addressed.

3. AI-related provisions

• The Publishing Center section continues to define content generated by or assisted by artificial intelligence as “AI Content.”
• AI Content is expressly provided on an “as is” and “as available” basis, with all faults.
• Softonic disclaims warranties concerning the accuracy, reliability, or suitability of AI Content.

No express AI-training change identified: The supplied diff does not add or remove language expressly allowing Softonic to use customer data, Developer Content, Apps, submissions, prompts, personal information, or usage data to train, fine-tune, evaluate, or improve AI models.

Risk: Although no training right is stated here, the absence of a restriction means the Terms alone do not clearly confirm that customer or Developer Content will never be used for AI training. The Privacy Policy or other incorporated policies may contain relevant rights or disclosures and should be reviewed separately.

4. Developer indemnity expanded

The indemnity now expressly covers:

• Intellectual-property, privacy, publicity, and other proprietary-rights claims;
• Defamatory, misleading, harmful, unlawful, or infringing Developer Content;
• Data-protection, cybersecurity, consumer-protection, export-control, and digital-services violations;
• Security vulnerabilities, inaccuracies, behavior, and interactions or disputes involving an App and its end users.

Risk: This materially broadens the Developer’s potential liability and may cover operational or third-party claims beyond direct infringement.

5. Suspension, termination, and data deletion

• Softonic may suspend or terminate Marketplace access at any time, for any reason, with or without prior notice.
• Grounds expressly include government requests, inactivity, technical issues, unlawful or fraudulent activity, and conduct Softonic considers harmful.
• Softonic may delete or restrict access to account data, content, and Apps and disclaims liability for resulting losses.
• Developers remain responsible for maintaining backups.

Risk: Significant loss-of-access and data-retention risk, with limited procedural protection or recovery rights.

6. Security obligations

Developer duties are clarified to include secure development, testing, timely patching, and reporting suspected vulnerabilities, malware, compromise, or unauthorized access.

Risk: These obligations may increase compliance costs and support indemnity claims if not met.

Structured Summary of Important Changes

1. Broader acceptance and application of terms

• Acceptance is now framed as implied acceptance of all sections of the Terms, rather than acceptance of only the terms applicable to the service being used.
• Browsing Softonic websites, downloading content, or using the Publishing Center may bind the user to the entire agreement, including sections relating to services they do not use.
• Users are directed to review the Terms each time they access or use different services.
• Softonic expressly reserves the right to amend the Terms over time, including provisions concerning services not currently used by the customer.

Risk: Customers may become contractually bound to additional provisions without a separate acceptance process, including future amendments and terms for unrelated services. The wording should be checked for clarity and enforceability, particularly for consumer users.

2. Account registration and age requirement

• The account section is reformatted and now states that users must create an account through Softonic’s specified registration process.
• A new requirement states that users must be of legal age to form a contract.

Risk: The Terms should clarify how age is verified and what happens to accounts created by minors.

3. AI-related provisions

• The Publishing Center section now defines content generated or assisted by artificial intelligence as “AI Content.”
• Softonic disclaims all representations, warranties, and guarantees concerning AI Content and supplies it on an “as is” and “as available” basis.

Training-data analysis:

The diff does not visibly add an express right for Softonic to use customer data, Developer Content, prompts, Apps, or other submissions to train, fine-tune, evaluate, or improve AI models. It also does not add an express prohibition on such use. Therefore, the customer’s AI-training position remains unclear and should be confirmed against the Privacy Policy and any data-processing terms.

Risk: The broad definitions of Developer Content and general service-use rights could potentially be argued to cover AI-related processing, but the diff alone does not establish that permission. Customers should seek an explicit statement addressing:

• whether submitted data is used for model training;
• whether training is opt-in or opt-out;
• whether data is anonymized or retained;
• whether third-party AI providers receive the data; and
• how confidential or personal information is protected.

4. Expanded developer indemnity

The indemnity now expressly covers:

• Intellectual-property, privacy, publicity, and other proprietary-rights claims;
• Defamatory, misleading, harmful, unlawful, or deceptive Developer Content;
• Data protection, cybersecurity, consumer protection, export-control, and digital-services violations;
• Security vulnerabilities, inaccuracies, and behavior of Developer Content; and
• Disputes or claims involving App end users.

Risk: This materially expands developers’ potential financial exposure, including for privacy and cybersecurity incidents and third-party user disputes.

5. Suspension, termination, and data deletion

• Softonic may suspend or terminate Marketplace access at any time, for any reason, with or without notice.
• Grounds include government requests, technical issues, inactivity, and conduct Softonic considers harmful.
• Softonic may delete or restrict access to associated data, content, and Apps and disclaims liability for resulting damages.
• Developers are responsible for maintaining their own backups.

Risk: There is no clear retention, export, notice, cure period, or recovery obligation. Developers could lose access to Apps and related data without meaningful opportunity to retrieve them.

6. Security obligations

• Developers must implement reasonable security measures, secure development practices, testing, timely patching, and incident notification.
• The obligation now expressly includes unauthorized access to systems used to build, sign, package, or distribute Developer Content.

Risk: These obligations are broad and largely uncapped, while Softonic’s corresponding responsibilities are not clearly specified.

Summary

The provided diff does not include the actual contractual language. It only states:

> “Added approximately 341 words to the document”

Accordingly, it is not possible to determine:

• What provisions were added, deleted, or replaced;
• Whether the customer’s data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether such use requires customer consent or may occur automatically;
• Whether data is anonymized, aggregated, de-identified, or retained;
• Whether the provider may share customer data with affiliates, subprocessors, or third-party AI providers;
• Whether the customer can opt out or require deletion; or
• Whether new confidentiality, ownership, security, liability, or indemnity risks were introduced.

AI-Training Review

No conclusions can be drawn about AI-model training because the actual additions and deletions are missing. The relevant language should be reviewed for terms such as:

• “train,” “fine-tune,” “improve,” “develop,” or “optimize” models;
• “inputs,” “outputs,” “customer data,” or “content”;
• “de-identified,” “aggregated,” or “anonymized” data;
• “service improvement” or “research and development”;
• rights granted to affiliates, vendors, or subprocessors;
• opt-out, consent, or configuration mechanisms; and
• retention and deletion obligations.

Information Needed

Please provide the full redline using the stated notation—for example:

• Additions: {new language}
• Deletions: [deleted language]
• Replacements: [old language]{new language}

Without the underlying text, a legal-risk analysis would be speculative.

Summary of Changes

The diff states only that approximately 96 words were removed from the document. The actual deleted language is not provided.

Customer Data and AI Training

• No determination can be made about whether the deleted text addressed:
• Use of customer data to train, fine-tune, or improve AI models;
• Whether customer data may be used for generalized model training;
• Whether data is anonymized, aggregated, or de-identified before use;
• Restrictions on using customer prompts, inputs, outputs, or personal information;
• Opt-out rights or consent requirements;
• Data retention, deletion, or isolation commitments; or
• Whether third-party AI providers may access or train on the data.

• Because the deleted language is unavailable, it is impossible to determine whether the change:
• Expands the provider’s rights to use customer data;
• Removes a customer protection or limitation;
• Restricts AI training or secondary use; or
• Is unrelated to data use.

Potential Legal and Commercial Risk

The removal of language could create material risk if it eliminated commitments concerning confidentiality, data ownership, permitted processing, or AI training. In particular, deleting an explicit prohibition or limitation on model training could leave the provider’s rights governed only by broader language elsewhere in the agreement, which may be less protective or ambiguous.

Conversely, the deletion may have no practical impact if the removed language was redundant or administrative.

Recommended Review

Obtain the actual 96 deleted words and compare them with:

1. Data-use and confidentiality provisions;

2. AI or machine-learning terms;

3. Definitions of “Customer Data,” “Usage Data,” and “Aggregated Data”;

4. Data retention and deletion obligations;

5. Subprocessor and third-party provider rights; and

6. Any opt-out, consent, or audit provisions.

Conclusion: The available diff is insufficient to identify the substantive legal changes or determine whether customer data may now be used to train AI models.

Executive Summary

The diff substantially reorganizes and expands Softonic’s Terms, particularly for website users, developers, and the Publishing Center. It also adds Mobile Application Terms and clarifies how acceptance occurs. No express provision was identified that authorizes Softonic to use customer, user, or developer data to train AI models.

AI and Data-Training Changes

• No express AI-training authorization appears in the diff. The changes do not state that Softonic may use customer data, Developer Content, user submissions, prompts, usage data, or other information to train, fine-tune, or improve AI models.
• The Publishing Center now defines “AI Content” as content generated by or assisted by artificial intelligence.
• The revised language provides that AI Content is supplied “as is” and “as available,” with all faults, and disclaims representations, warranties, and guarantees regarding its accuracy, reliability, or suitability.
• Risk: Although no training right is added here, the absence of a clear data-use restriction leaves uncertainty about whether training or model-improvement practices may be addressed elsewhere—particularly in the Privacy Policy, Cookies Policy, or a separate developer/data agreement. Those documents should be reviewed together with these Terms.
• Developers remain responsible for Developer Content and related legal issues, potentially including privacy, intellectual-property, publicity, and other proprietary-rights claims. This could create exposure if Developer Content is later processed by AI systems, even though no such processing right is expressly granted in this diff.

Acceptance and Scope

• Acceptance is broadened from service-specific acceptance to implicit agreement to all sections of the Terms, including provisions relating to services the user may not currently use.
• Browsing, accessing, and/or downloading content from Softonic websites now constitutes acceptance of the User & Business Terms; use of the Publishing Center triggers the Publishing Center Terms.
• Softonic expressly reserves the right to amend the Terms, and users are directed to review them when using different services. This creates a risk of notice and enforceability disputes, particularly for material changes accepted only through continued use.

Developer and Publishing Center Risks

• Developer indemnity language is expanded substantially to cover:
• Intellectual-property, privacy, publicity, and other proprietary-rights claims;
• Defamatory, misleading, harmful, unlawful, or deceptive Developer Content;
• Data-protection, cybersecurity, consumer-protection, export-control, and digital-services violations;
• Security vulnerabilities, inaccuracies, malfunction, and behavior of Developer Content;
• Disputes or claims involving App end users.
• Softonic may immediately suspend or terminate Marketplace access for any reason, with or without prior notice, including conduct it considers harmful.
• After termination, Softonic may delete or restrict access to associated data, content, and Apps, with no liability for resulting loss. Developers—not Softonic—are responsible for backups.
• Developer security duties are clarified and include secure development, testing, patching, and incident notification.

Other Changes

• Copyright and legal-reporting procedures are made more detailed and structured.
• Subscription terminology and formatting are cleaned up.
• New Mobile Application Terms govern the Softonic Hub application and related device-information access.

Structured Summary of Important Changes

1. Data protection terminology and legal references

• The policy title was changed from “Softonic Privacy Policy” to “SoftonicPrivacy Policy”, which appears to be a formatting or typographical error.
• References to privacy laws were standardized, including:
• GDPR
• UK GDPR and UK DPA
• Swiss FADP
• CCPA and other U.S. state privacy laws
• Defined terms and punctuation were generally cleaned up without materially changing the applicable legal framework.

2. Data controller and contact information

• Softonic International, S.A. remains identified as the data controller.
• A Data Protection Officer contact email was added: dpo@softonic.com.
• This gives users a clearer channel for exercising rights, raising objections, and contacting Softonic about privacy matters.

3. Legal basis and user objections

A significant wording change affects processing previously described as based on “explicit, free and unequivocal consent.”

• The revised wording states that users who do not wish their data to be processed for these purposes may object at any time by contacting Softonic at the DPO email address.
• The policy still refers to consent being given when data is collected and retains language about withdrawing consent for cookies.

Potential risk or ambiguity

• The change may blur the distinction between:
• withdrawing consent;
• objecting to processing based on legitimate interests; and
• objecting to specific processing purposes.
• It is unclear whether the listed processing activities now rely on consent, an objection mechanism, or both. This could create compliance and user-understanding risks, particularly under the GDPR, where consent withdrawal and objection have different legal consequences.
• Requiring users to contact the DPO may be less straightforward than providing a direct opt-out or consent-management mechanism, especially for cookies or advertising.

4. Cookies and third-party disclosures

• References to the Cookies Policy and Cookie Banner were corrected and standardized.
• The policy continues to disclose sharing with programmatic advertising vendors.
• No substantive expansion or reduction of third-party data sharing is apparent from this diff.

5. Complaints and regulatory references

• Links and formatting for the UK ICO, Swiss FDPIC, and Spanish AEPD were standardized.
• No apparent change was made to users’ complaint rights.

6. AI model training

• The diff contains no express change addressing the use of customer data to train, fine-tune, evaluate, or improve AI models.
• It does not add an AI-training purpose, identify AI vendors, authorize use of customer content for model development, or provide an AI-specific opt-out.
• On the face of this diff, there is therefore no new express authorization or restriction concerning AI training. The broader purposes and third-party disclosure language should nevertheless be reviewed in the full policy to determine whether existing wording could be interpreted to cover AI-related processing.

7. Publication and formatting issue

• The policy states that it was reviewed and published on 9 June 2026.
• A large block of section headings was appended without spacing or formatting. This appears to be an unintended table-of-contents or publication error and could reduce readability and legal clarity.

Summary

The diff only states that approximately 96 words were removed from the document. The actual deleted language is not provided, so the legal and commercial impact cannot be determined reliably.

AI Training and Data Use

• There is no visible language showing whether the deleted text addressed:
• Use of customer data to train, fine-tune, or improve AI models;
• Whether customer data may be shared with model providers or subprocessors;
• Whether prompts, inputs, outputs, or usage data are retained;
• Opt-out or consent requirements;
• Ownership or licensing of data and model outputs;
• De-identification, aggregation, or anonymization standards; or
• Restrictions on using customer data for product development.

• Accordingly, it is not possible to determine whether the revision:
• Expands or narrows the provider’s rights to use customer data;
• Removes a customer protection or opt-out right;
• Adds a restriction on AI training; or
• Has no effect on AI-related data practices.

Other Potential Legal Effects

Removing approximately 96 words could affect important terms such as:

• Confidentiality obligations;
• Data security or privacy commitments;
• Data retention and deletion;
• Intellectual-property ownership;
• Liability limitations or indemnities;
• Warranties and disclaimers;
• Compliance obligations; or
• Termination and post-termination data handling.

The significance depends entirely on the content and location of the removed language.

Risk Assessment

Current assessment: Indeterminate. The deletion itself is not enough to identify a specific legal change or risk. If the removed language concerned customer-data use or AI training, deleting it could materially weaken the customer’s protections or clarify that the provider has broader rights. If it was redundant or administrative language, the practical impact may be minimal.

The full redline or the deleted 96 words are needed for a meaningful legal analysis.

Summary

The supplied diff does not include the actual contractual language that was added, deleted, or replaced. It only states:

> “Added approximately 341 words to the document”

Accordingly, there is not enough information to identify substantive legal changes or assess new risks.

AI Training and Customer Data

• No language is provided addressing whether customer data may be:
• Used to train, fine-tune, or improve AI models;
• Used to develop products or services;
• Shared with affiliates, contractors, or third-party AI providers;
• Retained after termination;
• Aggregated, anonymized, or de-identified for model training; or
• Excluded from model training by default or only upon opt-out.

• Because the underlying wording is missing, it is not possible to determine whether the changes expand the provider’s rights to use customer data or create new confidentiality, privacy, intellectual-property, or regulatory risks.

Information Needed

Please provide the full redlined text, using the stated notation:

• {new text}
• [deleted text]
• [old text]{new text} for replacements

Once provided, the changes can be analyzed for issues such as data-use permissions, AI-training rights, ownership, confidentiality, security, retention, subprocessors, opt-out rights, and liability.

Summary of Important Changes

1. AI model training

• No express reference to artificial intelligence, machine learning, generative AI, or training AI models appears in the diff.
• The revised text does not add permission to use customer data to train, fine-tune, evaluate, or improve AI models.
• It also does not expressly prohibit such use. Any AI-training rights would therefore need to be located elsewhere in the unchanged policy, Terms of Service, or another referenced document.
• The general-purpose processing language remains broad enough that any existing provisions concerning analytics, service improvement, or automated processing should be reviewed separately to determine whether they could be interpreted to cover AI training.

2. Consent and objection mechanism

A potentially significant change concerns processing previously described as being based on:

> “the explicit, free and unequivocal consent that you give us”

The revised wording instead states that users who do not want their data processed for these purposes may object by contacting Softonic at dpo@softonic.com.

Risks and implications

• This appears to shift the presentation from prior, affirmative consent to an objection or opt-out mechanism.
• The change may affect whether processing is treated as consent-based or based on another legal basis, such as legitimate interests.
• The revised text is internally ambiguous because it later retains wording referring to consent given “at the time of collecting your data.”
• If consent remains the legal basis, an objection process should not replace a clear withdrawal-of-consent mechanism. If legitimate interests are the basis, the policy should identify that basis and explain the balancing assessment.
• Users may face a less direct method of control because they must contact Softonic rather than use an apparent consent-management tool.

3. Data protection contact details

• The Data Protection Officer/contact email dpo@softonic.com has been added in multiple locations.
• This improves accessibility and provides a clear channel for objections, consent withdrawal, and rights requests.
• The policy should use consistent wording to distinguish the DPO, privacy contact, and rights-request process.

4. Regulatory terminology and presentation

• Formatting and spacing around legal references, including the GDPR, UK DPA, FADP, CCPA, and US State Privacy Laws, have been standardized.
• References to the Cookies Policy, Cookie Banner, Terms of Use, and Terms of Service have been cleaned up.
• Complaint authority links and punctuation have been normalized. These appear non-substantive.

5. Publication and navigation

• The policy now states that it was reviewed and published on 9 June 2026.
• A list of policy-question headings has been appended, apparently for navigation or a table of contents. This does not itself create new processing rights or obligations, but the headings should link correctly and match the substantive sections.

Executive Summary

The revised Terms reorganize and expand the contractual framework. They now expressly cover Softonic Accounts, User & Business services, the Publishing Center, Mobile Applications, and general provisions. Acceptance is broadened substantially: merely accessing, browsing, or downloading content may constitute agreement to all sections of the Terms, including provisions for services the user does not currently use.

AI and Customer Data

• No express new authorization to use customer data to train AI models is identifiable in this diff.
• The changes do add or clarify provisions concerning AI-generated or AI-assisted content (“AI Content”) in the Publishing Center:
• Softonic provides no representations or warranties regarding the accuracy, reliability, or suitability of AI Content.
• AI Content is supplied on an “as is” and “as available” basis, with all faults.
• These provisions address disclaimers and allocation of risk, not AI training, model development, data retention, or licensing.
• The diff does not appear to grant Softonic a specific license to use customer data, Developer Content, prompts, inputs, outputs, or account information for training or fine-tuning AI models. Any such permission may instead appear in the Privacy Policy or another provision not included here and should be reviewed separately.

Important Legal Changes and Risks

1. Broader implied acceptance

Accessing or browsing Softonic websites, downloading content, or using the Publishing Center may now constitute acceptance of all Terms, including terms relating to services not immediately used. Users are directed to review the Terms repeatedly, while Softonic reserves the right to amend them over time. This creates notice and enforceability risks, particularly for infrequent users and developers.

2. Expanded developer indemnity

Developer responsibility is broadened to cover:

• Intellectual-property, privacy, publicity, and proprietary-rights claims;
• Defamatory, misleading, harmful, unlawful, or deceptive Developer Content;
• Data-protection, cybersecurity, consumer-protection, export-control, and digital-services compliance;
• Security vulnerabilities, inaccuracies, malfunction, and behavior of Developer Content;
• Interactions, disputes, and claims involving App end users.

The indemnity survives termination and may expose developers to substantial uncapped costs.

3. Wider suspension and termination powers

Softonic may immediately suspend or terminate Marketplace access at any time, for any reason, with or without prior notice, including conduct Softonic considers harmful. It may delete or restrict access to associated data, content, and Apps, with no liability for resulting losses. Developers bear responsibility for maintaining backups.

4. Reduced remediation for complaints

The revised infringement-reporting process is more detailed and extends beyond DMCA claims to broader legal violations. However, restoration after mistaken removal is discretionary rather than mandatory, increasing the risk of prolonged loss of access.

5. Increased developer security obligations

Developers must maintain reasonable security measures, secure development practices, testing, timely patching, and incident awareness/reporting obligations. These duties may increase operational and compliance costs.

Summary

The provided diff does not include the actual amended legal language. It only states:

> “Added approximately 341 words to the document”

Accordingly, it is not possible to identify:

• The specific contractual changes;
• New obligations, rights, or liabilities;
• Changes to data ownership, confidentiality, or security;
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether such use is subject to consent, opt-out rights, anonymization, aggregation, or restrictions;
• Any changes to data retention, deletion, subprocessors, or third-party disclosures.

AI Training and Data-Use Review

No conclusion can be reached regarding AI-model training because the added wording itself has not been provided. The key terms to review include language stating that customer data, prompts, inputs, outputs, usage data, or personal information may be used to:

• Train or fine-tune machine-learning or AI models;
• Improve, develop, test, or evaluate products and services;
• Create aggregated, de-identified, or derived data;
• Share data with affiliates, vendors, or model providers.

Important risks may arise if the language:

• Grants broad or perpetual rights to use customer data;
• Applies automatically without customer consent or an opt-out;
• Covers confidential information or personal data;
• Permits use of data to train models made available to other customers;
• Does not require deletion after termination;
• Does not prohibit re-identification or disclosure;
• Conflicts with confidentiality, privacy, regulatory, or data-processing obligations.

Required Information

Please provide the actual 341-word addition and, preferably, the complete marked-up diff using the stated notation. Once provided, the changes can be analyzed clause by clause, including the specific impact on AI training and customer-data rights.

Summary of Important Changes

1. AI-model training

• No express provision has been added or removed concerning the use of customer data to train, fine-tune, evaluate, or improve AI models.
• The diff does not identify:
• whether customer data may be provided to AI vendors;
• whether prompts, files, usage data, or account information may be used for training;
• whether data is anonymized or de-identified before AI use;
• whether customers can opt out of AI training; or
• how long AI-related data is retained.
• If Softonic uses customer data for AI-related purposes, the absence of a specific disclosure may create transparency, purpose-limitation, consent, and regulatory-risk concerns, particularly under the GDPR, UK GDPR, CCPA/CPRA, and other U.S. state privacy laws.

2. Legal basis changed from objection to affirmative consent

A significant change replaces language stating that users could object to certain processing by contacting Softonic with language stating:

> “Based on the explicit, free and unequivocal consent that you give us at the time of collecting your data…”

This appears repeatedly in the section describing cookies, analytics, advertising, and related processing.

Effect and risk

• The policy now presents these activities as based on prior affirmative consent, rather than merely allowing users to object afterward.
• This may strengthen Softonic’s stated legal basis, but it also creates a greater compliance burden. Consent must be:
• freely given;
• specific and informed;
• unambiguous;
• separate from unnecessary terms; and
• as easy to withdraw as to provide.
• The policy should clearly identify the precise purposes and processing activities covered by each consent request. A general statement in the privacy policy may not be sufficient, especially for cookies, advertising, profiling, or possible AI-related processing.

3. Broader and clearer regulatory coverage

The policy now more clearly references:

• the UK GDPR;
• the Swiss Federal Act on Data Protection;
• the CCPA as amended by the CPRA; and
• other U.S. state comprehensive privacy laws.

This may expand the stated scope of compliance obligations and user rights, including rights relating to targeted advertising, sale or sharing of personal information, profiling, and sensitive data.

4. Third-party advertising disclosures

The policy refers users to the Cookie Banner for programmatic advertising vendors. This reinforces disclosure of third-party sharing but may be insufficient if the banner is not complete, current, and consistent with the privacy policy.

5. Other changes

• The document title and defined terms have been standardized.
• Contact and regulator website formatting has been corrected.
• The prior publication date (“9 June 2026”) and apparent table of contents were removed from the displayed text. Removing the date may make it harder for users to determine which version of the policy applies.

Summary

The provided diff contains only the statement:

> “Added approximately 96 words to the document”

It does not include the actual added, deleted, or replaced legal language. As a result, the substantive changes and associated risks cannot be reliably analyzed.

AI Training and Customer Data

• No language is provided showing whether customer data may be:
• Used to train, fine-tune, or improve AI models;
• Shared with AI providers or other third parties;
• Used in de-identified, aggregated, or identifiable form;
• Retained after termination;
• Excluded from model training upon customer request; or
• Protected by confidentiality, security, or deletion obligations.

• Accordingly, it is not possible to determine whether the changes expand or restrict the provider’s rights to use customer data for AI-related purposes.

Information Needed

Please provide the actual diff, including the text within:

• {additions}
• [deletions]
• []{replacements}

Once provided, the analysis can identify changes to data ownership, permitted use, AI training rights, confidentiality, retention, subprocessors, security, and customer opt-out or deletion rights.

Summary of Important Changes

1. Broader acceptance of all Terms

• Acceptance language is substantially expanded. Accessing or browsing Softonic websites, downloading content, or using the Publishing Centre now constitutes implicit acceptance of all sections of the Terms, including sections relating to services the user may not currently use.
• The terms applicable to website use, accounts, and the Publishing Centre are reorganized and renamed, including:
• “User Business Terms” → “User & Business Terms”
• “Publishing Center Terms” → “Publishing Center Terms & Conditions”
• “Softonic Account Terms” → “Softonic Account Terms & Conditions”
• Softonic retains the right to amend the Terms from time to time, and users are encouraged to review them whenever they access or use different services. This creates a risk that users may be bound by updated terms through continued use, without a separate affirmative acceptance.

2. AI-related provisions

• The diff adds or clarifies the definition of “AI Content” as tools or content generated by or assisted by artificial intelligence.
• Softonic disclaims representations, warranties, or guarantees regarding AI Content and states that it is provided “as is” and “as available,” with all faults.
• This increases the developer/user risk relating to accuracy, reliability, legality, performance, and suitability of AI-generated material. Users may have limited contractual recourse if AI Content causes harm or infringement.
• No express new provision authorizing Softonic to use customer, developer, or user data to train AI models appears in this diff. The changes do not grant an explicit AI-training license, identify training purposes, or state whether submitted content is used for model training. This omission should be confirmed against the Privacy Policy and any separate data-processing terms. The broad references to “Developer Content,” data, and services could nevertheless create uncertainty about permitted internal uses.

3. Expanded developer indemnity

The developer’s indemnification obligations are materially expanded to cover:

• Intellectual-property, privacy, publicity, and other proprietary-rights claims;
• Defamatory, misleading, deceptive, harmful, offensive, or unlawful Developer Content;
• Breaches of data-protection, consumer-protection, cybersecurity, export-control, digital-services, and other laws;
• Security vulnerabilities, inaccuracies, malfunction, or behavior of Developer Content;
• Disputes or claims involving end users of an App.

The indemnity survives termination, and the developer must cooperate with Softonic’s defense. This may expose developers to broader and potentially uncapped liability.

4. Stronger suspension, termination, and deletion rights

• Softonic may immediately suspend or terminate Marketplace access at any time, for any reason, with or without prior notice.
• Grounds include government requests, technical issues, inactivity, alleged violations, or conduct Softonic considers harmful to the Marketplace or others.
• After termination, Softonic may delete or restrict access to account data, Apps, and Developer Content and disclaims liability for resulting losses.
• Developers remain responsible for maintaining backups.

5. Security obligations

Developers must maintain reasonable security measures, secure development practices, testing, timely patching, and incident procedures. Suspected vulnerabilities, malware, compromise, or unauthorized access affecting Developer Content must be addressed. These obligations increase operational and compliance costs and may support indemnity claims if not met.

6. Other changes

• Takedown procedures now require more detailed complainant information and supporting evidence.
• Marketplace and AI-related services receive broader warranty disclaimers.
• Several wording and formatting corrections improve consistency but do not materially change risk.

Summary of Important Changes

1. Consent and use of personal data

The most significant substantive change concerns processing activities that previously stated:

• Users could object at any time by contacting Softonic’s Data Protection Officer; and
• Processing was described as being based on the user’s “explicit, free and unequivocal consent” given when data was collected.

The revised wording more directly states that processing is based on consent given at collection and removes the express statement that users may object at any time by contacting Softonic. Although the policy still refers elsewhere to withdrawing consent, the revised language may make the withdrawal mechanism less clear.

Risks and implications:

• The change may narrow or obscure users’ ability to withdraw consent or object to processing.
• Consent must remain specific, informed, freely given, and as easy to withdraw as to provide under GDPR, UK GDPR, and similar laws.
• If the relevant processing includes advertising, analytics, profiling, or other optional activities, Softonic should ensure that consent is obtained separately where required and that withdrawal is clearly available.
• The revised wording should be checked for consistency with the cookie banner, consent-management tools, and rights-management section.

2. Possible removal of DPO contact details

The diff appears to replace the email address dpo@softonic.com with a full stop. If this reflects the final text rather than a formatting error, the policy may no longer provide the DPO’s email address at that location.

Risk: Removing or obscuring a direct contact method could make it more difficult for users to exercise privacy rights and may undermine transparency requirements. The address should remain clearly available wherever the policy directs users to contact the DPO.

3. AI-model training

No express change concerning AI or the use of customer data to train AI models is shown in this diff.

The revised text does not add or remove language expressly authorizing:

• Training, fine-tuning, or evaluating AI models;
• Using customer content, prompts, usage data, or personal data for AI development;
• Sharing data with AI providers; or
• Opt-out or objection rights relating specifically to AI training.

Accordingly, this diff does not create a clear new contractual right to use customer data for AI training. However, any broad existing purposes—such as analytics, service improvement, profiling, or product development—should be reviewed separately to determine whether Softonic might interpret them as covering AI-related processing.

4. Other changes

• References to GDPR, UK DPA, FADP, CCPA, and U.S. State Privacy Laws are mainly punctuation and formatting changes, with no apparent substantive expansion.
• Minor punctuation, spacing, and heading changes appear non-substantive.
• The prior publication date and table-of-contents-style list appear to have been removed. This may reduce version transparency and make it harder for users to identify the policy’s effective date and changes.

Summary

The supplied diff does not include the actual amended contract language. It only states:

> “Added approximately 341 words to the document”

Accordingly, it is not possible to identify the legal changes, new obligations, allocation of risk, or revisions concerning customer data and AI model training.

AI Training and Data Use

• No determination can be made about whether the customer’s data may be used to train, fine-tune, test, validate, or improve AI models.
• The available information does not show whether the new language:
• Permits or restricts model training using customer data;
• Applies to customer prompts, inputs, outputs, usage data, or personal information;
• Allows data to be de-identified, aggregated, or shared with affiliates or subprocessors;
• Grants the provider ownership or broad license rights;
• Provides an opt-out or requires express consent;
• Imposes retention, deletion, confidentiality, or security obligations; or
• Limits use of data after termination.

Risk Assessment

The risk level cannot be assessed without the text of the additions and any surrounding provisions they modify. In particular, the added language should be reviewed for:

1. Broad data licenses allowing unrestricted use of customer content.

2. Ambiguous “service improvement” language that could include AI training.

3. Rights to use de-identified or aggregated data, including whether re-identification is prohibited.

4. Third-party or affiliate access to customer data.

5. Conflicts with confidentiality, privacy, or data-processing terms.

6. Lack of deletion or opt-out rights when the agreement ends.

Please provide the actual redline text, including the inserted 341 words and any deleted or replaced language, for a substantive analysis.

Summary

The supplied diff does not include the actual amended legal text. It only states that approximately 341 words were added.

What can be determined

• No specific contractual changes can be identified.
• It is not possible to assess whether the additions:
• expand or restrict either party’s rights;
• change liability, indemnity, confidentiality, security, or termination obligations;
• introduce new fees, warranties, or compliance requirements; or
• alter ownership or permitted uses of customer data.

AI-model training

The supplied material does not show whether the customer’s data may be:

• used to train, fine-tune, or improve artificial-intelligence or machine-learning models;
• used to develop products or services;
• combined with other customers’ data;
• retained after termination for training or research;
• reviewed by human personnel for model-development purposes; or
• excluded from training through an opt-out or contractual prohibition.

Accordingly, no conclusion can be reached about whether the amendment creates or changes AI-training rights or related privacy and confidentiality risks.

Information needed

Please provide the full redlined text, including the additions shown in {}, deletions shown in [], and replacements shown as []{}. The actual wording is necessary to identify the legal effect and any new risks.

Summary of Important Changes

1. Broader acceptance of all Terms

• Acceptance is now framed as implied acceptance of all sections of the Terms, rather than acceptance of specific sections based on the service used.
• Browsing Softonic websites, downloading content, or using the Publishing Centre may constitute agreement to the relevant—and potentially all—terms.
• Users are told that terms may change over time and are encouraged to review them whenever they access or use services, including services they do not currently use.

Risk: Users may be bound by provisions unrelated to their immediate activity, including developer, account, mobile application, and other service terms. The mechanism and timing for effective amendments remain broad.

2. Account eligibility and registration

• The account section is more clearly presented as applying to all users who register.
• Registration language now states that users must be of legal age to form a binding contract.

Risk: The revised wording may create enforceability or parental-consent issues for underage users, particularly where existing accounts or subscriptions are involved.

3. Publishing Centre: AI-related provisions

• The Publishing Centre now expressly refers to content “generated by or assisted by artificial intelligence” as “AI Content.”
• AI Content is subject to an expanded disclaimer: Softonic provides it on an “as is” and “as available” basis and makes no express or implied warranties regarding it.

AI training analysis:

• The supplied diff does not add an express right for Softonic to use customer, developer, user, or Developer Content to train AI models.
• It also does not state that such data will be excluded from training, used only for service provision, anonymized, or deleted from training datasets.
• The Terms incorporate the Privacy Policy and Cookies Policy, so any AI-training rights may appear there rather than in this text. Those policies should be reviewed separately.
• The absence of a clear training provision creates uncertainty about whether submitted content, usage data, prompts, feedback, or AI-generated material may be used for model development, analytics, or product improvement.

4. Developer indemnity substantially expanded

The indemnity now expressly covers:

• Intellectual-property, privacy, publicity, and other proprietary-rights claims;
• Defamatory, misleading, harmful, unlawful, or offensive Developer Content;
• Data-protection, cybersecurity, consumer-protection, export-control, and digital-services violations;
• App performance, malfunction, security vulnerabilities, inaccuracies, behavior, and disputes with end users.

Risk: Developers face substantially broader and potentially uncapped financial exposure, including claims arising from App operation and end-user interactions.

5. Suspension, termination, and data deletion

• Softonic may suspend or terminate Marketplace access at any time, for any reason, with or without prior notice.
• Grounds now include government requests, technical issues, inactivity, and conduct Softonic considers harmful.
• Softonic may delete or restrict access to account-linked data, content, and Apps, with no liability for resulting losses.
• Developers are expressly responsible for maintaining backups.

Risk: Developers may lose access to Apps and associated data without notice or recovery obligations.

6. Security obligations

• Developers must maintain reasonable security measures, secure development practices, testing, and timely vulnerability patching.
• Suspected vulnerabilities, malware, compromises, and unauthorized access must be reported.

Risk: These obligations increase compliance and incident-response burdens, but the diff does not specify reporting deadlines or technical standards.

Summary

The supplied diff does not include the actual amended contract language. It only states:

> “Added approximately 341 words to the document”

Accordingly, it is not possible to identify:

• The specific legal terms that were added or changed;
• New customer obligations or provider rights;
• Changes to liability, confidentiality, security, intellectual property, or termination provisions; or
• Whether the customer’s data may be used to train, fine-tune, evaluate, or improve AI models.

AI Training and Data-Use Review

No conclusion can be reached about AI-model training from the information provided. The actual added language should be reviewed for terms such as:

• “train,” “fine-tune,” “improve,” “develop,” or “evaluate” models;
• Use of customer data, prompts, inputs, outputs, content, or usage data;
• Permission to use data in aggregated, anonymized, de-identified, or pseudonymized form;
• Retention of data after termination;
• Sharing data with affiliates, subprocessors, or third-party AI providers;
• Whether use is automatic or requires customer opt-in;
• Whether customer data is excluded from model training by default; and
• Any ability to revoke consent or delete data used for training.

Information Needed

Please provide the full redlined text, including the approximately 341 added words and any surrounding provisions. Without the actual language, a reliable legal-risk analysis cannot be performed.

Summary of Important Changes

1. AI model training

• No express change concerning AI training was identified.
• The diff does not add or remove language stating that customer data, personal information, prompts, content, usage data, or other inputs may be used to train, fine-tune, evaluate, or improve AI models.
• Accordingly, this amendment does not appear to create a new contractual authorization for AI training. However, the broader processing language should still be reviewed in the complete policy to determine whether existing general-purpose clauses could be interpreted to cover model development or service improvement.

2. Legal and regulatory references

• The policy’s references to the GDPR, UK GDPR, UK DPA, Swiss FADP, CCPA, and other U.S. state privacy laws have been reformatted and clarified.
• These appear primarily editorial and do not materially change the stated legal framework.

3. Data controller and contact information

• “Softonic” and “Policy” are now defined more cleanly.
• The Data Protection Officer’s contact email, dpo@softonic.com, has been added in place of a generic reference.
• This improves transparency and gives customers a direct channel for privacy inquiries, objections, and consent withdrawal.

4. Consent and objection language

This is the most substantive change.

• Previous wording stated that certain processing activities were based on the user’s “explicit, free and unequivocal consent” given when data was collected.
• The revised wording instead states that users who do not wish their data to be processed may object at any time by contacting Softonic’s DPO.
• The policy then retains the statement that processing is based on consent.

Risk and practical effect

• The revision may make the user’s remedy appear to be an objection process, rather than a straightforward right to withdraw consent.
• Under data-protection laws, withdrawing consent and objecting to processing are distinct rights and may have different legal consequences.
• The language could create uncertainty about:
• whether consent is actually required before processing;
• whether users can withdraw consent as easily as they gave it;
• whether Softonic will stop all relevant processing after an objection; and
• whether certain processing is instead based on legitimate interests or another legal basis.
• Softonic should ensure that the full policy clearly distinguishes consent withdrawal, objection, and other rights.

5. Third-party disclosures

• References to programmatic advertising vendors and the Cookie Banner have been standardized.
• No new category of recipient is clearly added in the diff, but the continued use of advertising partners remains relevant to tracking, profiling, and international-transfer risks.

6. Administrative and presentation changes

• Typographical and spacing corrections were made throughout.
• The policy now states that it was reviewed and published on 9 June 2026.
• A long list of section headings appears appended at the end, likely intended as a table of contents. If displayed to users, it should be checked for formatting and accessibility.

Summary

The diff indicates that approximately 96 words were removed, but it does not identify which words, clauses, or sections were deleted.

Important changes

• Cannot determine the substantive legal effect of the deletion without the actual deleted text.
• The removed language could potentially affect:
• Customer rights and obligations
• Data ownership, confidentiality, or security
• Liability, indemnification, or warranties
• Termination or dispute-resolution provisions
• Use of customer data for analytics, product improvement, or artificial intelligence

AI training and customer data

• The provided diff contains no identifiable language addressing AI models or training.
• It is therefore not possible to determine whether the revision:
• Authorizes or restricts using customer data to train AI models;
• Changes whether customer data may be used for model improvement;
• Adds or removes consent requirements;
• Changes opt-out rights;
• Permits use of de-identified, aggregated, or identifiable data; or
• Limits retention or deletion of data used for training.

Risk assessment

The principal risk is lack of visibility into the deleted provisions. If the removed 96 words contained data-use restrictions, confidentiality protections, or customer consent language, the deletion could materially expand the provider’s rights or reduce the customer’s protections. Conversely, the deletion might remove permissive language and narrow those rights.

A redline showing the actual deleted text, or the prior and revised versions of the relevant section, is required for a reliable legal analysis.

Summary of Important Changes

1. No express AI-training provision added

• The diff does not add or amend any language expressly stating that customer data may be used to:
• train, fine-tune, or evaluate artificial-intelligence or machine-learning models;
• develop generative-AI products;
• create model inputs, outputs, embeddings, or profiling systems; or
• share data with AI providers for those purposes.
• Accordingly, the revised text does not create a clearly stated contractual right to use customer data for AI training. However, existing broad purposes—such as analyzing use of the Services, providing and improving services, fraud prevention, analytics, advertising, and personalization—could potentially be argued to cover certain automated or machine-learning activities. The policy would benefit from an explicit statement if AI training is intended, including the data categories, purposes, legal basis, recipients, retention, opt-out rights, and whether data is anonymized or de-identified.

2. Consent language changed to an objection-based formulation

The most material substantive change replaces repeated wording stating:

> “Based on the explicit, free and unequivocal consent that you give us…”

with language stating, in substance:

> “However, if you do not wish your data to be processed for these purposes, you may object at any time by contacting dpo@softonic.com…”

Risks and implications

• This may change the apparent legal basis from prior explicit consent to an opt-out/right-to-object model.
• The change is potentially significant for cookies, analytics, advertising, and other processing previously described as consent-based.
• A general right to contact the DPO may not be sufficient where applicable law requires prior consent, particularly for certain cookies, electronic marketing, or processing of sensitive data.
• The policy should clearly identify the legal basis for each processing purpose and distinguish:
• consent withdrawal;
• objection to legitimate-interest processing; and
• opt-out rights under U.S. state privacy laws.
• The repeated, partially awkward replacement may create ambiguity about whether consent is still required before processing begins.

3. Expanded or clarified regulatory references

The text standardizes references to the GDPR, UK DPA, UK GDPR, Swiss FADP, CCPA, and other U.S. state privacy laws. This is primarily drafting cleanup, but it confirms that the policy is intended to cover a broad range of jurisdictions and may increase expectations for jurisdiction-specific rights and disclosures.

4. Contact details and disclosure clarifications

• The Data Protection Officer’s email address, dpo@softonic.com, is added in several places, including rights and objection/withdrawal procedures.
• References to the Cookie Policy, Cookie Banner, Terms of Use, and complaints authorities are cleaned up.
• Third-party advertising vendors are expressly linked to those listed in the Cookie Banner, which may make the banner an important companion disclosure.

5. Publication and formatting changes

• The policy is stated to have been reviewed and published on 9 June 2026.
• A long series of section headings appears appended at the end, apparently as a table of contents or navigation data. If displayed to users as written, this could create a formatting and readability defect, though it does not by itself alter substantive rights.

Summary of Important Changes

1. Consent replaces an objection/opt-out mechanism

The most significant substantive change affects processing previously described as occurring under the Terms of Service, where users could object by contacting Softonic’s data-protection address.

The revised wording states that processing is based on the user’s “explicit, free and unequivocal consent” given when data is collected. It also states that users may withdraw consent later.

Legal implications and risks

• Higher threshold, but potentially greater compliance burden: Reliance on consent requires that it be informed, specific, freely given, and clearly separated from acceptance of other terms where required.
• Consent must be granular: If the relevant processing includes cookies, analytics, advertising, profiling, or other distinct purposes, one general consent may not be sufficient.
• Withdrawal must be as easy as giving consent: The policy refers users to an email address, but an email-only withdrawal mechanism may be viewed as less accessible than the original consent method.
• Potential ambiguity: The repeated replacement appears to apply broadly, but it is not clear exactly which processing purposes now depend on consent. The policy should identify each consent-based purpose clearly.

2. Cookie consent language clarified

The revised text expressly states that users may withdraw consent to cookies at any time and directs them to the Cookies Policy. This is broadly favorable for transparency, but the practical withdrawal process should be clearly available through the cookie banner or settings tool—not only by contacting Softonic.

3. Minor terminology and formatting changes

The draft standardizes:

• Defined-term spacing and punctuation, including GDPR, UK DPA, FADP, CCPA, US State Privacy Laws, “Softonic,” “Policy,” and “Services.”
• References to the Cookies Policy, Terms of Use, and Terms of Service.
• URLs and punctuation for regulatory authorities.

These changes appear editorial and do not materially alter rights or obligations.

4. Removal of review date and contents text

The final deleted passage included:

• The statement that the policy was reviewed and published on 9 June 2026; and
• A list of policy headings.

Removing the publication date may make it harder for users or regulators to determine when the current version took effect. The table-of-contents text appears largely structural, but should be retained if needed for navigation and transparency.

5. AI-model training

No express change concerning the use of customer data to train, fine-tune, evaluate, or improve AI models appears in this diff. The revised language does not add an AI-training authorization, nor does it expressly prohibit such use.

If Softonic uses customer data for AI-related purposes, the policy should address that processing specifically, including the data involved, purpose, legal basis, opt-out or consent rights, retention, disclosures to AI vendors, and whether data is used to train general-purpose models.

No

Key Changes and Legal Risks

1. Broader acceptance of all Terms

• Acceptance is now framed as implied acceptance of all sections of the Terms, not only the section corresponding to the service being used.
• Browsing Softonic websites, downloading content, or using the Publishing Center may bind the user to provisions relating to services they do not currently use.
• Users are directed to review the Terms each time they access different services, and Softonic expressly reserves the right to amend the Terms over time.

Risk: Users may be bound by future amendments and unrelated provisions without a separate click-through acceptance. This may create enforceability and notice concerns, particularly for material changes.

2. Account registration and eligibility

• The account section is more clearly presented as applying to all registered users.
• Registration must occur through Softonic’s specified process.
• The user must be of legal age to form a contract.

Risk: The age requirement may create uncertainty regarding minors’ access and responsibility for accounts or content.

3. User & Business Terms terminology

• “User Business Terms” has generally been changed to “User & Business Terms.”
• Privacy and Cookies Policies are expressly described as integral parts of those Terms and are accepted together with them.

Risk: Incorporation of external policies may expand the user’s obligations, particularly if those policies can be amended separately.

4. AI-related provisions and model training

• The diff adds or standardizes definitions and disclaimers for content “generated by or assisted by artificial intelligence” (“AI Content”).
• AI Content is provided on an “as is” and “as available” basis, with no warranties regarding accuracy, reliability, or fitness.

No express AI-training change identified: The diff does not add language authorizing Softonic to use customer, developer, user, or Developer Content to train, fine-tune, or improve AI models. It also does not expressly prohibit such use. Any training rights would therefore need to be checked in the Privacy Policy, Developer Content license, or other unchanged provisions.

Risk: The absence of a clear training-use clause leaves uncertainty about whether submitted content may be used for AI development under broader data-use or content-license language.

5. Developer indemnity substantially expanded

The revised indemnity expressly covers:

• Intellectual-property, privacy, publicity, and proprietary-rights claims;
• Defamatory, misleading, harmful, unlawful, or deceptive Developer Content;
• Data-protection, cybersecurity, consumer-protection, export-control, and digital-services violations;
• Security vulnerabilities, inaccuracies, malfunction, and behavior of Developer Content;
• Disputes or claims involving end users of an App.

The indemnity survives termination, and Softonic may control the defense.

Risk: Developers face significantly broader and potentially uncapped financial exposure, including operational and security-related claims.

6. Publishing Center suspension and deletion rights

• Softonic may suspend or terminate Marketplace access at any time, for any reason, with or without notice.
• Grounds now include inactivity, government requests, technical issues, and conduct Softonic considers harmful.
• Softonic may delete or restrict access to associated data, Apps, and Developer Content and disclaims liability for resulting loss.

Risk: Developers have limited continuity, retrieval, and remedy rights. They must maintain their own backups.

7. Security obligations

Developers must maintain reasonable security measures, secure development practices, testing, timely patching, and incident reporting for suspected vulnerabilities, malware, compromises, or unauthorized access.

Risk: These obligations increase compliance and potential indemnity exposure, but the required security standard and reporting timelines remain unclear.

Summary

The provided diff indicates that approximately 96 words were added, but it does not include the actual added language or identify any deleted or replaced terms.

Key Legal Changes

• Cannot be determined: The substance and legal effect of the additions are unavailable.
• No identifiable deletions or replacements: The diff does not show any text removed or modified.
• Potential impact: Without the added wording, it is not possible to assess whether the changes affect liability, confidentiality, ownership, termination, security, compliance, or other contractual rights.

AI Training and Customer Data

The supplied diff does not contain enough information to determine whether the contract now:

• Permits the provider to use customer data, prompts, outputs, or usage information to train or improve AI models;
• Allows such use for service improvement, analytics, research, or product development;
• Uses customer data in aggregated, anonymized, or de-identified form;
• Allows sharing of data with affiliates, vendors, or model providers;
• Gives the customer an opt-out or requires consent;
• Limits retention, deletion, or human review of data; or
• Grants the provider ownership or broad usage rights over customer content or AI outputs.

Risk Assessment

Because the actual 96 added words are missing, no reliable legal risk assessment can be made. The added language should be reviewed specifically for broad permissions to use customer content or personal data for training, fine-tuning, evaluating, or improving artificial-intelligence or machine-learning models.

Information Needed

Please provide the actual text of the additions, using the stated notation ({added}, [deleted], and []{replacement}). Without that text, it is not possible to identify the important contractual changes or any new AI-data-use risks.

Summary of Important Changes

1. AI model training and use of customer data

• No express provision has been added or removed concerning the use of customer data to train, fine-tune, evaluate, or otherwise develop AI models.
• The diff does not identify AI training as a processing purpose, disclose whether data is shared with AI providers, or explain retention, opt-out, or deletion rights relating to AI use.
• If Softonic uses customer data for AI-related purposes elsewhere, this policy change does not make that use more transparent. The absence of an AI-specific disclosure may create transparency and consent risks, particularly where personal data, behavioral data, or user-generated content is used.

2. Consent language materially revised

The policy repeatedly replaces language stating that users may object to processing by contacting Softonic with language stating:

> “Based on the explicit, free and unequivocal consent that you give us at the time of collecting your data…”

Practical and legal impact

• The revised wording appears to change the stated legal basis from a general right to object to prior consent at collection.
• It may make consent appear to be required for the relevant processing rather than optional.
• The policy still states that users may withdraw consent, but the revised wording should clearly explain:
• which processing activities require consent;
• how consent is obtained;
• whether services remain available without consent; and
• the consequences of withdrawal.
• Repeating the same replacement several times creates drafting ambiguity and may make it difficult to determine which specific processing purposes are consent-based.
• Under GDPR/UK GDPR and similar laws, consent must be specific, informed, freely given, and capable of being withdrawn as easily as it was given. Consent may not be valid if bundled with necessary service terms or if refusal causes unnecessary detriment.

3. Broader legal framework and terminology

• References to the GDPR, UK DPA, UK GDPR, Swiss FADP, CCPA, and other U.S. state privacy laws have been standardized typographically.
• These edits do not appear to expand the substantive scope of applicable laws, but they confirm coverage of multiple jurisdictions and may increase compliance expectations regarding consent, rights, disclosures, and data sharing.

4. Other disclosures and presentation

• References to cookies, programmatic advertising vendors, complaints authorities, and the Cookie Policy have mainly been corrected for spacing and punctuation.
• The displayed publication date and apparent contents/navigation text at the end of the document have been removed. This may reduce clarity about when the policy was last reviewed or updated.
• No clear substantive change to data retention, international transfers, security, or third-party disclosures is shown.