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A CLOUD GURU POLICIES

We care about your privacy and want to help you understand how we collect, use,
and share your personal information.

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Our Policies
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PRIVACY POLICY




CODE OF CONDUCT

Definitions
Diversity Statement
Reporting Issues


TERMS OF USE




PLATFORM SUB-PROCESSORS

Platform Sub-processors
Cloud Guru Group and Affiliate Sub-processors


PLATFORM AND OPERATIONAL SECURITY

Overview
Platform Security
Operational Security
Backups are a central part of our Disaster Recovery strategy. Customer data is
stored in Cloud storage services. All data is backed-up on at least a daily
basis.
Compliance
Contact Us


TECHNICAL AND ORGANISATIONAL MEASURES

Overview - TOMS
Pseudonymisation and Encryption
Confidentiality
Integrity
Availability and Resilience
Processes of Regular Testing, Assessing and Evaluating the Effectiveness of
Technical and Organisational Measures for Ensuring the Security of the
Processing


A CLOUD GURU HANDS-ON FEATURE TERMS




MASTER SERVICES AGREEMENT




DATA PROCESSING ADDENDUM

Customer DPA (Controller:Processor) - Version 5.1



WE'RE TAKING A DIFFERENT APPROACH TO PRIVACY

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PRIVACY POLICY


EFFECTIVE DATE:MAY 10, 2021

Privacy Policy

A Cloud Guru Privacy Policy

Last updated: May 10, 2021

The A Cloud Guru companies (“ACG,” “we,” “our,” “us“) are committed to
protecting your privacy. This Privacy Policy sets out how ACG collects, stores,
and uses your personal data or personal information (your “data” or
“information”) in connection with your use of the services we offer
(collectively, the “Services“) and your use of our websites at acloud.guru and
acloudguru.com and all subdomains thereof or the A Cloud Guru App (collectively,
our “Website“). Different laws refer to “personal data” or “personal
information,” so the terms “data” and “information” are used interchangeably in
this Privacy Policy.

Please read this Privacy Policy carefully to understand our practices and your
rights in relation to your information. This Privacy Policy applies only to
information that we collect. If you do not agree with this Privacy Policy in
general or any part of it, you should not use our Services or access our
Website.

1. INFORMATION WE COLLECT

We collect and process certain information about you when you use our Services
because that collection and processing is within our legitimate interests, such
as to provide, improve, maintain, and enhance our Services and technology, to
provide you with information about our Services, and to ensure the security of
the Services and our Website.

We collect and process the following personal information that we receive in
connection with your use of the Services and/or Website:

 * Identifiers: This may include information such as your first and last name,
   username, email address, country, IP address, and browser and operating
   system configuration.
 * Employment-Related Information: If you are an employee of one of our business
   customers, we collect business contact information, which may include your
   name, title, function, name of employer, information about the employer (such
   as business unit or group), work telephone number and email address, work
   mailing address, and supervisor name.
 * Password: Your ACG password (unless you use an identity provider like Google,
   Facebook, or Security Assertion Markup Language).
 * Performance Information: The courses you have signed up for, taken, or
   watched and the actions you take while using our interactive features such as
   our Cloud Playground and Hands-on Labs.
 * Technical Usage/Activity Information: This includes technical information
   automatically collected from your computer, mobile device, or another access
   device-related to how you use the Services or Website, such as cookies data
   and device information (including but not limited to, identifier, name, and
   type of operating system). This also includes standard web information like
   your browser type, browser data, usage data, and the pages you access and
   actions you take on our Website.
 * Provided Information: Any other information you affirmatively provide to us
   when signing up for or using the Services, including data you input and any
   marketing preferences you provide us with.

2. HOW WE USE YOUR INFORMATION

We may use your information in pursuing our legitimate interest in operating the
services. Specifically, we use your information as follows:

 * Performance: To provide, maintain, and enhance the Services in fulfillment of
   our obligations to you and, if you are an employee of a business customer, to
   your employer.
 * Your Account and Support: To communicate with you about your account and
   provide customer support to you when you create an account, post information
   on our Website, or submit questions, queries or feedback via our Website,
   survey tool, email, or social media.
 * Advertising: To advertise our Services and business features to you and
   provide you with news and updates related to ACG and our Services, including
   through direct marketing and interest-based advertising.
 * Validation: To validate your purchase or verify your payment method when you
   sign up for a trial or subscription or when you provide evidence of purchases
   of our courses on a third-party platform.
 * Employees of Business Customers: If you are an employee of one of our
   business customers, to identify your usage of the Services as it relates to
   your employer’s use of and subscription to the Services.
 * Certifications: To provide our Services and validate the authenticity of your
   certificate when you upload a professional certification via our Website.
 * Customer Support and Communication: To provide our Services, communicate with
   you, and contact you about our Services when you inquire about our product
   via our Website, App, email (if you send an email to us), or social media (if
   you contact us via social media) and to communicate with you through our
   newsletters and emails where you have provided your consent.
 * Legal and Tax Compliance: To comply with court orders, valid discovery
   requests, valid subpoenas, other legal obligations, or law enforcement
   requests. To identify where our users are located in connection with
   applicable tax laws, in which case we collect your country and IP address in
   order to comply with our legal obligations.
 * Personalization: We use the Technical Usage Information we collect as
   follows: to personalize our Website to ensure content from the Website is
   presented in the most effective manner for you and your device; to monitor
   and analyze trends, usage, and activity in connection with our Website and
   Services; to administer and improve the Website; for internal operations such
   as troubleshooting, data analysis, testing, research, statistical, and survey
   analysis; to keep the Website safe and secure; and to measure and understand
   the effectiveness of the content we serve to you and others.
 * Ensuring Compliance: We may use your information to ensure that you are using
   our services as permitted and to avoid or mitigate a violation of the
   applicable terms or agreement governing your use of the Services.
 * Consent: For any other purposes to which you have consented.

3. COOKIES

We use cookies, pixel tags, web beacons, and similar files or technologies
(“Cookies”) to collect and store the information we automatically collect about
your computer, mobile device, and use of the Website. Cookies are files
containing small amounts of information that are downloaded to your computer or
mobile device when you visit a certain webpage. Cookies are then sent back to
the originating webpage on each subsequent visit, or to another webpage that
recognizes that cookie. Cookies are used in order to make our Website work, or
to work more efficiently, and to improve your experience of our Website.

In addition to cookies that are strictly necessary to operate the Website, we
use the following cookies:

 * Functional Cookies: These cookies allow us to enhance your experience on our
   Website. These cookies are set by us and the following third parties:
   Cloudinary and Braintree.
 * Performance or Analytics Cookies: These cookies enable us to provide a better
   user experience based on how you use our Website.One of our third-party
   analytics tools is Google Analytics provided by Google, Inc. Google Analytics
   uses cookies, small text files containing a string of alphanumeric characters
   and which are stored on your computer to provide us with statistics on the
   use of our Website and Services. The reports that we receive from Google
   disclose aggregate usage trends. For further information on how Google
   Analytics collects and processes information about you and information on how
   to opt out from Google’s collection of information from you, please click
   here.

You can opt-out of Google Analytics without affecting how you visit our Website.
For more information on opting out of being tracked by Google Analytics across
all websites you use, see here.

 * We also use cookies provided by Hotjar Limited in order to better understand
   your needs and to optimize our Website and Services. Hotjar is a technology
   service that helps us better understand our users’ experience (e.g., how much
   time they spend on which pages, which links they choose to click, what users
   do and do not like, etc.) and this enables us to create user profiles, as
   well as build and maintain our service with user feedback. Hotjar uses
   cookies and other technologies to collect data on our users’ behavior and
   their devices, including IP address, device screen size, device type (unique
   device identifiers), browser information, geographic location (country only),
   and preferred language used to display our Website. Hotjar stores this
   information in a pseudonymized user profile. For further details, please see
   Hotjar’s privacy policy by clicking here.

You can opt-out of the creation of a user profile, Hotjar’s storing of data
about your usage of our Website, and Hotjar’s use of tracking cookies on other
websites by following this opt-out link. Hotjar also honors the Do Not Track
header. This means that if you have the Do Not Track header installed, Hotjar
will not track you.

 * Targeting or Advertising Cookies: These cookies tell us and the third parties
   setting them about your browsing habits, so you can be provided with
   advertising that is more relevant to you. These cookies are set by us or
   third parties (such as Google AdWords, Bing Ads, DoubleClick, and LinkedIn).
 * Social Media Cookies: These cookies allow you to share what you have been
   doing on the Website on social media.
 * Disabling Cookies: If you do not accept the use of these cookies, please
   disable them by changing your browser settings so that cookies from the
   Website cannot be placed on your computer or mobile device. These browser
   settings will typically be found in the “options” or “preferences” menu of
   your browser; otherwise, you should use the “Help” option in your browser for
   more details. If you only want to limit third-party advertising cookies, you
   can turn such cookies off by visiting the following links:
 * Your Online Choices (http://www.youronlinechoices.com/)
 * Network Advertising Initiative (http://www.networkadvertising.org/)
 * Digital Advertising Alliance (http://www.aboutads.info/consumers)

4. INFORMATION WE SHARE WITH THIRD PARTIES

We do not sell your information to third parties, and we do not pass on your
information to any other websites. We may share your information with the third
parties listed in this section.

Cloud Providers

 * Cloud Storage Providers:  We may share your information with Cloud storage
   providers, including AWS located in the United States, to store the
   information you provide, provide our Services to you, provide disaster
   recovery services, and to perform any contract between you and us.

Third-Party Services and Sub-processors

We also utilize other companies and individuals to perform certain functions on
our behalf. We will disclose your information to these third parties only to the
extent necessary to perform their functions. We refer to third parties who
process your personal information as “sub-processors.” A list of our
sub-processors is available at:
https://legal.acloudguru.com/policies?name=platform-sub-processors (the
“Sub-processor List”), as may be updated from time to time. Each of these
sub-processors has its own Privacy Policy, which you can learn about by visiting
the sub-processor’s website.

The categories of third-party services and sub-processors we currently use are:

 * Payment Processors: Payment processors to process your payment information
   when you purchase our paid services.
 * Analytics: Tools that perform analytics to help us understand your usage of
   our Services. We provide these third parties with a limited amount of your
   information (such as your email address and signup date) when you visit our
   Website or use our Services so that we can improve our service to you based
   on your usage. We may also use some of them as a medium for communication,
   either through email or messages within our Services.
 * Marketing/Advertising: Marketing and advertising services that help us use
   information collected about you to market our Services to you.
 * Authentication:  Authentication services that authenticate your identity and
   grant you access to our Services.
 * Fraud and Abuse Tracking: Services to track any actual or attempted fraud,
   abuse, or violation of our applicable terms or agreement in connection with
   the use of our Services.

Other Disclosures

Additionally, there are other situations where we may share your personal
information with others, such as:

 * Business Customer Employers: If you are an employee of one of our business
   customers, we will share information generated from your use of the Services
   with your employer. This includes such as courses taken, account usage, and
   course and skill analysis results.
 * Obligations and Protection: If we have a legal obligation to share your
   information, if we have to enforce or apply our terms of use or other
   agreements, to detect, prevent, or otherwise address security, fraud, or
   technical issues, or to protect the rights, property, or safety of us, our
   users, a third party, or the public as required or permitted by law
   (exchanging information with other companies and organizations for the
   purposes of fraud protection and credit risk reduction).
 * Business Transfers: In the event that we sell or merge our business or sell
   all or substantially all of our assets (or are preparing to take these
   actions), we may disclose your information to the prospective merger entity
   or buyer, and the information held by us about our users will be one of the
   transferred assets. In these cases, we will take reasonable steps to ensure
   your information remains subject to protections at least as protective as the
   terms of this Privacy Policy.
 * With Your Consent: In other circumstances where we may wish to share your
   information with third parties, we will send you a notice about the intended
   sharing, and you will have an opportunity to choose not to have your
   information shared. In addition, if you voluntarily upload any information to
   public areas of the Website you will be sharing that information publicly
   with other users having access to those areas.

5. KEEPING YOUR INFORMATION SECURE

In an effort to keep your information secure, when we receive your personal
information, we take certain Technical and Organizational Measures and Platform
Security measures.

 * For more information on our Technical and Organizational Measures please
   visit:
   https://legal.acloudguru.com/policies?name=technical-and-organisational-measures#overview-tom.
 * For more information on our Platform Security measures, please visit:
   https://legal.acloudguru.com/policies?name=platform-and-operational-security#overview.
 * Payment Processing: In processing your payments through our payment
   processors, we do not retain any personally identifiable information or any
   financial information such as credit card or account numbers. Instead, all of
   that information is provided directly to our third-party payment processor.

Although we have these measures in place, please note that transmitting
information over the internet is generally not completely secure, and we cannot
always guarantee the security of your data.

6. YOUR RIGHTS IN YOUR INFORMATION

You may have certain legal rights in your personal information. If you reside in
the European Economic Area, these rights are governed by the European Union’s
General Data Protection Regulation (“GDPR”); if you are a resident of
California, these rights are governed by the California Consumer Privacy Act
(“CCPA”); if you reside or are located in a different jurisdiction, these rights
may be governed by the applicable data protection laws of your jurisdiction. We
are committed to complying with these data and privacy laws.

GDPR

Individual Customers: If you are using our Services for your own personal
purposes (as opposed to in connection with your employment through a
subscription obtained through your employer) ACG is your data controller for the
purpose of GDPR.

Corporate Customers: If you are using our Services in connection with your
employment, your employer is your data controller for the purposes of the GDPR,
and ACG is your data processor collecting and using that data only to provide
the Services to your employer. Your employer may have their own privacy notices
that will apply to your use of our Services. Your employer will have access to
your information we collect in connection with your use of the Services.

Under GDPR, subject to certain conditions and exceptions, your rights in your
personal information include the following:

 * The right to be informed about whether your personal information is being
   processed and to request access to and certain information about your
   information we process.
 * The right to request that we correct or update any information you believe is
   inaccurate and to request that we complete any information you believe is
   incomplete.
 * The right to request that we erase your personal information in certain
   situations, including:where it is no longer necessary for us to hold your
   personal information for the purpose originally collected or processed;
   where you have provided your personal information to us with your consent and
   you wish to withdraw your consent, and there is no other legal ground under
   which we can process your personal data;
   where we are processing your personal information on the basis of legitimate
   interests and you object to such processing and we cannot demonstrate an
   overriding legitimate ground for the processing; or
   where you believe the personal information we hold about you is being
   unlawfully processed by us.
 * The right to request that we restrict processing of your personal information
   in certain situations, including:where you believe the personal information
   we hold about you is inaccurate and while we verify accuracy;
   where we want to erase your personal information due to unlawful processing
   but you want us to continue to store it;
   where we no longer need your personal information for the purposes of our
   processing but you require us to retain the data for the establishment,
   exercise, or defense of legal claims; or
   where you have objected to us processing your personal information based on
   our legitimate interests and we are considering your objection.
 * The right to request that we transfer personal information collected to
   another organization or directly to you.
 * The right to object to/stop our processing of your personal information based
   on our legitimate interests. In that case, we will no longer process your
   personal information unless we can demonstrate an overriding legitimate
   ground. At any time you have the right to object to our processing of
   information about you in order to send you marketing, including where we
   build profiles for such purposes, and we will stop processing the data for
   that purpose.
 * The right to not be subject to automated decision making, including where we
   build profiles for such purposes, where the decision would have a legal
   effect on you or produce a similarly significant effect.

Please note that these rights above are limited under GDPR, for example, where
fulfilling your request would adversely affect other individuals, our trade
secrets or intellectual property, where there are overriding public interest
reasons, or where we are required by law to retain your personal information. In
addition, if you consider that our processing of personal data relating to you
violates your rights under GDPR, you have the right to complain to your
applicable data protection supervisory authority.

Note About Automated Decision-Making. In accordance with GDPR, ACG may use
automated decision making where it is necessary for entering into or performing
a contract between you and ACG, or otherwise with your consent. ACG uses
third-party service providers who employ automated decision-making for the
purpose of detecting and preventing fraud and abuse of our Services and Website
and violations of the agreement governing your use of the Services. By creating
an account or using the Services, you consent to automated decision making for
this purpose. We may update the automated techniques and tools we use over time.

California Residents

If you are a California resident, the CCPA provides you with the following
rights:

 * The right to know the specific pieces and/or categories of personal
   information that we have collected about you over the past 12 months, the
   categories of sources for that personal information, the business or
   commercial purposes for collecting the information, the categories of
   personal information that we have disclosed, and the categories of third
   parties with which the information was shared. This information is listed in
   the above sections of this Privacy Policy.
 * The right to request that we delete the personal information we have
   collected from you (and direct our third-party service providers to do the
   same). This right is subject to several exceptions where the information is
   necessary for us or a third party to do any of the following:complete the
   transaction for which we collected your information or perform our contracts
   with you;
   provide you with a good or service requested by or reasonably anticipated
   based on your relationship with us;
   detect security incidents and protect and prosecute against malicious,
   deceptive, fraudulent, or illegal activity;
   debug to identify and repair errors that impair our Website or Services;
   exercise free speech or ensure others can exercise free speech or other legal
   rights;
   comply with the California Electronic Communications Privacy Act pursuant to
   Chapter 3.6 of Title 12 of Part 2 of the California Penal Code;
   engage in public or peer-reviewed scientific, historical, or statistical
   research in the public interests that adheres to all other applicable ethics
   and privacy laws;
   making internal uses that are reasonably aligned with your expectations based
   on your relationship with us;
   comply with a legal obligation; or
   make internal lawful use of your information in a manner compatible with the
   context of providing the information.
 * The right to opt-out of the sale of your information.
 * We do not sell your personal information or disclose your information to
   third parties for their direct marketing purposes.
 * If in the future we intend to sell or disclose your information for
   third-party marketing, we will provide you notice; and you will have the
   right to opt-out of the sale of your personal information via a “Do Not Sell
   My Personal Information” or similar link and you will have the right to
   request certain information about our disclosure of personal information to
   third parties for their own direct marketing purposes during the 12 months
   preceding your request. This request will be free and may be made once per
   year.
 * The right to not be discriminated against for exercising any of your rights
   under the CCPA.

Exercising Your Rights

To exercise any of your rights listed above, whether under GDPR or CCPA, please
contact ACG via the Privacy Center.

If you are an employee of one of our business customers, please contact your
employer to exercise your rights in your personal information.

We intend to respond to a request for access or deletion within 1 month of
receiving a request under GDPR, within 45 days of receiving a request under the
California Consumer Privacy Act, or within the time period permitted under any
other applicable law. If we need more time, we will inform you of the reason and
the extension period.

Note that we may require that you verify your identity in order for us to
process your request. If we are unable to verify your identity, we may deny your
request and we will let you know if that is the case.

Additionally, deleting or restricting the processing of your personal
information may impact features of our Services that require that information to
function. As a result, if you delete or restrict processing of your personal
information, you may no longer be able to use all or part of the Services.

7. CHILDREN

We do not knowingly collect personal information from children under age 16 for
any purpose. If we learn that we have collected personal information of a child
under age 16, we will attempt to delete that personal information as soon as
possible and take any other measures required under applicable law.

8. INTERNATIONAL TRANSFERS

If you are located in the European Economic Area, your personal information will
be transferred to and processed by:

 * ACG personnel located in the United States and Australia under the terms of
   the EU Commission’s model contracts for the transfer of personal data to
   third countries (i.e., the standard contractual clauses), pursuant to
   Decision 2004/915/EC. Please contact privacy@acloud.guru if you would like to
   see a copy of the model contracts; and
 * Our third-party suppliers (as described above) located outside the EEA where
   such transfers will be subject to the European Commission’s model contracts
   for the transfer of personal data to third countries (i.e., the standard
   contractual clauses). Please contact privacy@acloud.guru if you would like to
   see a copy of the model contracts.

9. CHANGES TO PRIVACY POLICY

We may make changes to this Privacy Policy at any time. The “Last Updated” date
at the top of this page refers to the last date that this Privacy Policy was
updated. All changes to this Privacy Policy are effective immediately upon
notice, which notice we may give by any means, including, but not limited to, by
posting a revised version of this Privacy Policy or other notice on the Website.
Please check back frequently for any updates or changes.

10. CONTACTING US

Questions, comments, and requests regarding this Privacy Policy are welcomed and
should be addressed to: privacy@acloud.guru.

The ACG entities applicable to this Privacy Policy are as follows: Serverless
Heroes, Inc., located at 800 Brazos St., Suite 340, Austin, TX 78701; Linux
Academy, Inc., located at 125 Bear Creek Parkway, Keller, TX 76248; and A Cloud
Guru Ltd., located at Regal House, Office 318 A-C, 70 London Road, Twickenham,
Middlesex TW1 3QS, United Kingdom.

Our Approach to Privacy
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