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THE DATA WE COLLECT, HOW IT'S USED, AND WHO WE SHARE IT WITH



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



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ANACONDA CONTRACTING HUB

WELCOME TO THE ANACONDA CONTRACTING HUB!
PURCHASED VS. FREE OFFERINGS
ANACONDA SUBSCRIPTIONS
ANACONDA PROFESSIONAL SERVICES


ANACONDA LEGAL DEFINITIONS




MASTER SUBSCRIPTION AGREEMENT

MASTER SUBSCRIPTION AGREEMENT
ANACONDA SUPPORT POLICY
PROFESSIONAL SERVICES ADDENDUM


PRIVACY POLICY

1. PERSONAL INFORMATION WE COLLECT
Information We Collect:
2. WHY AND HOW WE COLLECT AND PROCESS, STORE AND RETAIN YOUR PERSONAL DATA
3. HOW WE SHARE YOUR PERSONAL DATA
4. WHAT RIGHTS AND CHOICES DO YOU HAVE CONCERNING THE PERSONAL DATA WE COLLECT
5. How we keep your personal data secure
6. INTERNATIONAL TRANSFER: WHAT YOU NEED TO KNOW
7. WHAT YOU NEED TO KNOW ABOUT MINORS AND PERSONAL DATA
8. DISCLAIMER
LEGAL IMPRINT


TERMS OF SERVICE

TERMS OF SERVICE


END USER LICENSE AGREEMENT

END USER LICENSE AGREEMENT


OFFERING-SPECIFIC TERMS

ANACONDA DISTRIBUTION
ANACONDA PROFESSIONAL REPOSITORY
ANACONDA SERVER (ARTIFACT REPOSITORY)
MINICONDA
ENTERPRISE DS PLATFORM
ANACONDA LEARNING
ANACONDA NOTEBOOKS
ANACONDA PLATFORM TOOLS
PYSCRIPT.COM
EDUBLOCKS TERMS OF SERVICE
SECURITY & GOVERNANCE


PARTNER TERMS

ANACONDA GENERAL PARTNER TERMS
DISTRIBUTOR, RESELLER, VAR PARTNER ADDENDUM
REFERRAL PARTNER ADDENDUM
ANACONDA AD PARTNER TERMS


SECURITY TERMS

INFORMATION SECURITY ADDENDUM


ADDITIONAL POLICIES & TERMS

EMBEDDED END CUSTOMER TERMS
NON-DISCLOSURE AGREEMENT
ACCEPTABLE USE POLICY
ANACONDA EVENTS CODE OF CONDUCT
ANACONDA DMCA POLICY
ANACONDA TRADEMARK & BRAND GUIDELINES
ANACONDA DISPUTE POLICY
ANACONDA SCHOLARSHIP PROGRAM TERMS


FREQUENTLY ASKED QUESTIONS

GENERAL CONTRACTING QUESTIONS


ANACONDA DATA APP CONTEST TERMS

ANACONDA DATA APP CONTEST TERMS & CONDITIONS



WE'RE TAKING A DIFFERENT APPROACH TO PRIVACY

Show Me


PRIVACY POLICY


EFFECTIVE DATE:MAY 30, 2023

Anaconda, Inc. and its Affiliates (collectively, “Anaconda”, “we”, “our” or
“us”) offer a variety of products, services, and websites (collectively,
“Services”). We respect your privacy, and this Privacy Policy describes our
practices with respect to Personal Information we collect from or about you when
you use our Services.

The terms "Personal Data" and "Personal Information" are used synonymously
throughout this Privacy Policy to describe the information that alone or in
combination with other information in our possession could be used to identify
you, either directly or indirectly. Personal Information does not include
aggregated, de-identified, and/ or anonymized information, i.e., when the
information has been transformed so that it no longer relates back to a person’s
identity.

Please note when we provide our Services under a Master Subscription Agreement
with an organization, that organization has control over the information
processed by the Services. This Privacy Policy does not apply when we process
Personal Data as a service provider or processor for an organization, in such
cases, our Data Processing Addendum will apply. For the purposes of this Privacy
Policy, a “User” represents an individual user who actively interacts with the
Services.




We have made it a priority to gather only the information that is necessary to
provide you with the best possible experience while using our Services. We don't
share your information with third parties unless it is strictly necessary to
deliver the Service you requested, or we are legally obligated to do so. We
utilize industry-standard security measures to protect your data from
unauthorized access, use, or disclosure.

We understand that it can be difficult to grasp legalese; if you have any
questions or concerns, please don't hesitate to reach out to us at
privacy@anaconda.com. Our goal is to ensure you understand our privacy practices
and feel comfortable using our Services.





THIS PRIVACY POLICY COVERS:

 1. Personal Information We Collect
 2. How We Use Personal Information
    1. Why and How We Collect and Process your Personal Information
    2. How we Store and Retain your Personal Data
 3. How We Share Personal Information
    1. Third Parties with Whom We Share Personal Data
    2. Cookies and Tracking Technologies
    3. Google Analytics
 4. Your Rights and Choices Concerning your Personal Data
    1. For Users in Europe, EEA or the United Kingdom
    2. For California Residents
    3. For Canadian Citizens
 5. How We Keep your Personal Data Secure
 6. International Transfer: What You Need to Know
    1. Transfer from the European Economic Area (EEA) and the UK to Third
       Countries
    2. Use Of EU-U.S. And Swiss-U.S. Privacy Shield Framework
 7. What You Need to Know about Minors and Personal Data
    1. Disclaimer





1. PERSONAL INFORMATION WE COLLECT

Depending on the nature of your relationship with Anaconda, we may collect
various types of Personal Information. We have listed these categories below, to
simplify and streamline the process of identifying the categories of Personal
Data that we, and our Sub-Processors, collect and process. Our intention is to
make it easier for you to understand the types of Personal Information that we
collect and how we use it to provide our Services.





CATEGORIES OF DATA SUBJECTS:

 1. Attendees: Those who visit our offices or provide their information to
    Anaconda or Anaconda representatives when they attend or register to attend
    Anaconda-sponsored events or other events at which Anaconda (and/or its
    representatives) participates, as well as those who participate in
    Anaconda’s studies such as user experience research.
 2. Website Visitors: Those who visit our Websites, including those who may opt
    to provide an email address or other contact information to receive
    communications from Anaconda, fill out a survey, or provide feedback. For
    the purposes of this Privacy Policy, “Websites” refer collectively to
    www.anaconda.com as well as any other websites Anaconda operates for its own
    behalf and that link to this Privacy Policy. For clarity, “Websites” does
    not include any sites owned or operated by our Customers, including where we
    serve as Registrar.
 3. Customers: Individuals or entities who enter into a subscription agreement
    with Anaconda (or its authorized partner) and to whom Anaconda provides
    Services pursuant to such agreement. For purposes of this Privacy Policy,
    “Services” shall refer to all of the cloud-based solutions offered,
    marketed, or sold by Anaconda or its authorized partners that are designed
    to increase the performance, security, and availability of data science
    packages, applications, devices, and services, along with any software,
    software development kits, and application programming interfaces ("APIs")
    made available in connection with the foregoing.
 4. Administrative Users: Those with login credentials for an Anaconda account
    and/or those who administer any of the Services for a Customer. In some
    cases, an Administrative User and Customer may be the same individual. In
    other cases, an Administrative User may be an agent acting on behalf of a
    Customer.
 5. Public Users: Those who use Anaconda’s public repository at Anaconda.org.
 6. End Users: Those who (i) access or use our Customers’ domains, networks,
    websites, application programming interfaces, and applications, or (ii)
    Customers’ employees, agents, or contractors, who access or use Services,
    such as Anaconda Distribution end users.


INFORMATION WE COLLECT:




Data Categories

Personal Information

Employee/ User/ Customer ‘Personal Identifiers’ refers to the basic information
that can be used to identify a person.

The First and last name of an individual and the individual's email address are
used for communication

If you are applying to one of the positions in our job portal, we might collect
date of birth, gender, government-issued identification information, passport or
visa information, and legal work eligibility status.

‘Employee/ User/ Customer Credentials’ refers to information used to
authenticate a user’s account

User name, passwords, profile picture, and tokens

‘Payment Information’ refers to financial information voluntarily submitted by
Users or Customers to purchase Anaconda Products and Services

- Credit/debit card information, such as card number, expiration date, security
code (CVV), and cardholder name

- Bank account details, such as bank name, account number, and a routing number

- Billing address, such as the address associated with the individual's payment
method

- Records of past payments and purchases

- Company Size and number of employees

‘Business Information’ refers to personal information related to an individual’s
professional activity and the Organization he/she is related to

The individual's role or title within a company or organization, employer name,
business contact information such as work email address, corporate phone number,
and physical address

‘Employment Information’ refers to personal information related to an
individual's employment

Job title, department, and compensation, benefits information, such as
enrollment in health insurance or retirement plans. HR-related information, such
as performance reviews, educational history, employment, and military history,
former disciplinary actions, and training records. Information related to
payroll and taxes, such as Social Security numbers, tax withholding information,
tax category

‘Usage, and Metadata’ refers to Information related to how a product or service
is used. It might contain or not personal information

Activity logs such as records of actions taken by the individual within a
service or platform, session duration, the specific times and dates the
individual accessed a service or platform. Information on how the individual
interacts with a service or platform, such as clicks, and page views.

‘Device Information’ refers to information related to an individual’s technical
gadget, such as a phone or computer

The specific web browser used by the individual, the type of operating system
used by the individual, IP address, MAC address, geo-location

‘User-Generated Data’ refers to information created by users in Anaconda Forums
and Platform

- Text-based communications, such as chat messages, comments on forums, or
direct messages on a social media platform

- Reviews and ratings, such as Feedback provided by individuals regarding
products, services, or experiences.

- Blog posts and articles

- Photos and images shared or uploaded, including profile pictures, personal
photos, or images used in articles and posts.

- Video content created and shared, such as vlogs, tutorials, or personal
recordings.

-Audio content uploaded or shared by individuals, voice messages, or audio
clips, video recording

- Customizations and settings, such as the changes made by individuals to
personalize their experience on a platform or service, including notification
settings

- Timestamps with date and time when content was created or shared by an
individual.

- File metadata such as format, size, or resolution

‘Information from Third-party Sources’ refers to any data related to an
individual that is obtained from sources other than the individual themselves
and that is collected by Anaconda indirectly via public or social platforms

- Data obtained from an individual's social media profiles, such as Likes,
Shares, Reactions, Followers, and connections, the use of specific keywords or
tags in social media content, or mentioning other users

- Public directories, such as information available through public sources, such
as phone directories or online databases.

- Data obtained from third-party sources, such as credit reporting agencies,
marketing databases, or government records

Data Categories

Employee/ User/ Customer ‘Personal Identifiers’ refers to the basic information
that can be used to identify a person.

Personal Information

The First and last name of an individual and the individual's email address are
used for communication

If you are applying to one of the positions in our job portal, we might collect
date of birth, gender, government-issued identification information, passport or
visa information, and legal work eligibility status.

Data Categories

‘Employee/ User/ Customer Credentials’ refers to information used to
authenticate a user’s account

Personal Information

User name, passwords, profile picture, and tokens

Data Categories

‘Payment Information’ refers to financial information voluntarily submitted by
Users or Customers to purchase Anaconda Products and Services

Personal Information

- Credit/debit card information, such as card number, expiration date, security
code (CVV), and cardholder name

- Bank account details, such as bank name, account number, and a routing number

- Billing address, such as the address associated with the individual's payment
method

- Records of past payments and purchases

- Company Size and number of employees

Data Categories

‘Business Information’ refers to personal information related to an individual’s
professional activity and the Organization he/she is related to

Personal Information

The individual's role or title within a company or organization, employer name,
business contact information such as work email address, corporate phone number,
and physical address

Data Categories

‘Employment Information’ refers to personal information related to an
individual's employment

Personal Information

Job title, department, and compensation, benefits information, such as
enrollment in health insurance or retirement plans. HR-related information, such
as performance reviews, educational history, employment, and military history,
former disciplinary actions, and training records. Information related to
payroll and taxes, such as Social Security numbers, tax withholding information,
tax category

Data Categories

‘Usage, and Metadata’ refers to Information related to how a product or service
is used. It might contain or not personal information

Personal Information

Activity logs such as records of actions taken by the individual within a
service or platform, session duration, the specific times and dates the
individual accessed a service or platform. Information on how the individual
interacts with a service or platform, such as clicks, and page views.

Data Categories

‘Device Information’ refers to information related to an individual’s technical
gadget, such as a phone or computer

Personal Information

The specific web browser used by the individual, the type of operating system
used by the individual, IP address, MAC address, geo-location

Data Categories

‘User-Generated Data’ refers to information created by users in Anaconda Forums
and Platform

Personal Information

- Text-based communications, such as chat messages, comments on forums, or
direct messages on a social media platform

- Reviews and ratings, such as Feedback provided by individuals regarding
products, services, or experiences.

- Blog posts and articles

- Photos and images shared or uploaded, including profile pictures, personal
photos, or images used in articles and posts.

- Video content created and shared, such as vlogs, tutorials, or personal
recordings.

-Audio content uploaded or shared by individuals, voice messages, or audio
clips, video recording

- Customizations and settings, such as the changes made by individuals to
personalize their experience on a platform or service, including notification
settings

- Timestamps with date and time when content was created or shared by an
individual.

- File metadata such as format, size, or resolution

Data Categories

‘Information from Third-party Sources’ refers to any data related to an
individual that is obtained from sources other than the individual themselves
and that is collected by Anaconda indirectly via public or social platforms

Personal Information

- Data obtained from an individual's social media profiles, such as Likes,
Shares, Reactions, Followers, and connections, the use of specific keywords or
tags in social media content, or mentioning other users

- Public directories, such as information available through public sources, such
as phone directories or online databases.

- Data obtained from third-party sources, such as credit reporting agencies,
marketing databases, or government records




Anaconda offers a variety of products and services, some of which are accessed
via our website. When you access our website or services, as a User or Customer,
we collect, process, and at times, store different data categories such as,
Personal Identifiers, User Credentials, Business Information, Device
Information, Usage, and Metadata




When you apply for a position in our Job Portal and start working with us, in
connection with human resources functions and activities, we may collect,
process, and at times, store different data categories such as, Personal
Identifiers, Employment Information and Information from third-party sources.

There are other situations when we collect, process, and store your personal
data, such as when you are a potential lead or prospective candidate, when you
collaborate in our blogs and forums, when you connect and interact with us
through social media profiles, when you receive our communications because you
are subscribed to our newsletter or when you sign up for one of our webinars.




Please be aware that we adhere to the Data Minimization principle; therefore, we
will only collect or process those data categories that are necessary and
relevant for the legal basis for which they are being collected. We are
committed to being cautious and mindful of the personal information we require
from you, and we do not collect any more information than what is required for
the purpose of providing our services and complying with legal obligations.





2. WHY AND HOW WE COLLECT AND PROCESS, STORE AND RETAIN YOUR PERSONAL DATA





2.1 WHY AND HOW WE COLLECT AND PROCESS YOUR PERSONAL DATA

We collect and process your personal data when you have given consent to this
processing for one or more specific purposes; and when the processing of
personal data is necessary for the purposes of Anaconda legitimate interests
such as:

 1.  To provide our Services: We collect and process your personal data to
     provide you with the product and services you request. We use your contact
     information to provide product support services you might require, to
     deliver necessary product updates and patches, and to administer user
     accounts. We may also need to process your personal data for billing
     purposes or to simply implement, finalize, or enforce a Service or Software
     Agreement with you.
 2.  To personalize your experience: We may collect data to personalize your
     experience while using our software, such as your preferences and settings.
 3.  To improve our Services: We may collect data to understand how our software
     is used and to identify areas for improvement.
 4.  To send you communications: We may use your data to send you
     communications, such as updates on our software, promotional offers, or
     other related information, only if you have provided your consent. Also, we
     collect data when you sign up online for any of our events or training
     sessions.
 5.  For research and development: We may collect data to conduct research and
     development to improve our software and services. This may include
     collecting data on how you use our software and your preferences using
     surveys, questionnaires, interviews, and any other research tool available
     to us.
 6.  For analytics: We may collect data to analyze usage patterns, measure
     engagement, and track performance metrics. This helps us understand how our
     software is used, identify areas for improvement, and optimize the user
     experience.
 7.  To provide Customer Support: We may collect data to provide customer
     support and troubleshoot any issues you might have with our software. This
     may include your contact information and details about your use of our
     software.
 8.  For administrative purposes: We may use data for administrative purposes,
     such as to verify your identity, manage your account, or process payments.
 9.  For security purposes: We may use data to protect the security of our
     software and services, including to detect and prevent cyber-attacks,
     unauthorized access, and other security breaches.
 10. For compliance with legal and regulatory requirements: We may use data to
     comply with legal and regulatory requirements, such as to respond to
     government or law enforcement requests, to comply with court orders, or
     with other legal and regulatory requirements.
 11. Employee Personal Data: Anaconda collects or has access to personal data
     about employees to carry out and support human resources functions and
     activities, which may include: (i) recruiting and hiring job applicants;
     (ii) managing employee communications and relations; (iii) providing
     compensation and benefits; (iv) administering payroll; (v) processing
     corporate expenses and reimbursements; (vi) managing employee participation
     in human resources plans and programs; (vii) carrying out obligations under
     employment contracts; (viii) managing employee performance; (ix) conducting
     training and talent development; (x) facilitating employee relocation and
     international assignments; (xi) managing employee headcount and office
     allocation; (xii) managing employee termination process; (xiii) managing
     information technology and communication systems, such as corporate email
     system; (xiv) conducting ethics and disciplinary investigations; (xv)
     administering employee grievances and claims; (xvi) managing audit and
     compliance matters; (xvii) complying with applicable legal obligations,
     including government reporting and specific local law requirements; and
     (xviii) other general human resources purposes. Anaconda may also obtain
     and process personal data about employees’ emergency contacts, and other
     individuals (such as spouses, family members, dependents, and
     beneficiaries) to the extent employees provide such information to
     Anaconda. Anaconda processes this information to comply with its legal
     obligations and for benefits administration and other internal
     administrative purposes.


2.2 HOW WE STORE AND RETAIN YOUR PERSONAL DATA

In accordance with applicable data protection laws and regulations, we may store
Personal Data or Information in combination with non-personal information. In
such cases, we consider the resulting combination as personal information and
will handle it in accordance with our Privacy Policy and applicable data
protection laws and regulations.




Additionally, we may remove all personal information from a set of data
(anonymization), at which point the remaining information will be considered
non-personal information. This means that the information will not be able to
identify an individual, and is therefore not subject to the same legal
requirements as personal information.




For the storage of personal data, we have a robust infrastructure integrated
with Snowflake's cloud-based data warehousing solution with AWS's cloud
services. This integration allows us to use the maximum of capabilities to
provide security, scalability, and reliability to our customers, either when
they are using our Cloud Services, or when we are storing their data in our
warehouse. This infrastructure is accompanied by strict Technical and
Organizational measures explained in our Information Security Addendum.




Nonetheless, we want to make it clear that our servers and databases are located
in the United States, and we do not offer or provide storage options in data
centers located in other territories. Therefore, by using our services, you
agree and acknowledge that your personal information may be transferred and
stored in the United States, which may have different data protection laws than
the country in which you reside.




Once stored, we retain the minimum amount of Personal Data necessary for the
above-mentioned purposes, and will not use or disclose it for any other purpose
without your consent. We will retain your personal data only for so long as a
legitimate business or human resources purpose exists or until you have
requested us to delete your personal data via our Privacy Center.




We might delete the personal data of Customer, whenever the following conditions
are met:

 1. the data subject has submitted a Data Deletion Request or has invoked his
    right to be forgotten. When you make a data deletion request, to inform
    Third-Party Sub-processors about the request, we follow these steps:
 2. We verify the request making sure it is valid, by carrying out an ID
    Verification Process to ensure you are authorized to ask for the deletion of
    personal data.
 3. We locate data, Identifying the data that needs to be deleted and locate it
    within your systems and those of the Sub-processors.
 4. We notify Sub-processors by sending a notice to all relevant Sub-processors
    of the data deletion request and providing them with the necessary
    information to locate and delete the data in a maximum period of ninety (90)
    days.
 5. We monitor compliance, making sure the Sub-processors are compliant with the
    data deletion request in the appointed period of time.
 6. We Confirm deletion, guaranteeing that the Sub-processors deleted the data
    and providing evidence of the deletion to the user if necessary.
 7. We update records to reflect the deletion of the data, and we document the
    steps taken to comply with the request.
 8. It is no longer necessary for the fulfillment of the Anaconda's legal basis.
    In this case, in compliance with the principles of storage limitation and
    data minimization, we regularly carry out a Periodic Data Deletion Process
    to clean our database of the personal information we no longer need,
    especially of those Customers or Users who have become inactive or who
    haven’t interacted for a period of twenty-four (24) months with Anaconda
    products and Services.
 9. Anaconda has detected a security threat that can put at risk the Company's
    systems or the Anaconda user community. In such cases, Anaconda shall take
    the necessary measures to delete the personal data of the data subject in a
    timely and secure manner, ensuring that the data is properly disposed of and
    cannot be accessed or used by unauthorized third parties.

If you would like to know more about our Data Retention and Deletion processes,
you can ask for our extended Anaconda Data Retention and Deletion Policy by
writing to privacy@anaconda.com





3. HOW WE SHARE YOUR PERSONAL DATA


3.1 CATEGORIES OF THIRD-PARTIES WITH WHOM WE SHARE PERSONAL DATA

In this Section, we outline the circumstances under which we may share personal
data with various entities:

 1. Third Party Sub-processors: Anaconda may engage and contract with these
    third-party companies to provide services that help us with our business and
    human resource activities such as software support services, contract
    management services, sales support services, software training services,
    benefits administration, human resource compliance, and management platform,
    employee stock options management platform, and in-office communications
    system. These third-party service providers are limited to only using the
    information as instructed to provide contracted services to us.

Some of these Third Parties we share personal data with are Sub-processors,
these processors assist us in providing our main services, such as hosting
providers or payment processors. We carefully vet our Sub-processors to ensure
that they maintain appropriate data protection and security measures, and we
enter into binding agreements with them that require them to process personal
data in accordance with our instructions and to maintain the confidentiality and
security of the personal data they receive. If you want to know more about our
Sub-processors, visit our Sub-processor List.

 1. Partners: We may also share personal data with Partners for the purpose of
    providing our services or to further our legitimate business interests. For
    example, we may share personal data with a marketing Partner to help us
    promote our services. Third-party Partners are required to comply with
    strict data protection requirements and are prohibited from using the
    information for any purpose other than as instructed by us.
 2. Affiliated Businesses: In certain circumstances, we may be associated with
    businesses or third parties that offer or provide goods or services to users
    through or in association with our Services, either alone or in conjunction
    with us. You can identify when an affiliated business is connected with such
    a transaction or service. We will only share your Personal Information with
    the affiliated business to the extent that it is necessary for the
    transaction or service. We do not have authority over the policies and
    practices of third-party software or businesses, including their privacy
    policies. Therefore, if you opt to participate in any transaction or service
    that is associated with an Affiliated Business, we advise you to review all
    policies of such businesses or websites carefully.
 3. Intercompany Transfers: Pursuant to this Privacy Policy, we may disclose or
    transfer any information we collect to a third party in the event of a
    merger, sale of company assets, financing, or acquisition of all or a
    portion of our business. In these situations, personal data may be
    transferred to the new controlling entity as part of the transferred
    business assets. The new controlling entity will be required to comply with
    our privacy commitments and to use the personal data in accordance with this
    Privacy Policy. In such instance, we will make reasonable efforts to notify
    affected individuals through email or a conspicuous notice of the Services
    and the transaction made, as well as the options you have on your personal
    data.
 4. For Legal Reasons: Anaconda may also disclose your personal data as required
    by law, such as to comply with a subpoena or similar legal processes. To the
    extent we are legally permitted to do so, we will take commercially
    reasonable steps to notify you in the event that we are required to provide
    your Personal Data to third parties as part of a legal process. Anaconda may
    also be required to disclose personal data in response to lawful requests by
    public or law enforcement authorities.


3.2 USE OF COOKIES AND TRACKING TECHNOLOGIES

Anaconda uses various types of cookies on its website and applications,
including essential functionality cookies, performance and analytics cookies,
targeting or advertising cookies, and social media cookies. Cookies are small
text files that are placed on your device by websites and applications that you
visit. They are used to collect and store information such as login credentials,
user preferences, and website analytics data. By using Anaconda's website and
applications, you consent to the use of cookies in accordance with this Cookies
Clause and the Cookies Consent Notice visible when you enter any Anaconda’s
website.

 1. Essential functionality cookies are necessary for the proper functioning of
    Anaconda's website and applications, and cannot be disabled.
 2. Performance and analytics cookies gather data on website usage to improve
    Anaconda's services.
 3. Targeting or advertising cookies are used to track your online activity and
    show you personalized advertisements. Social media cookies are used for
    integration with social media platforms.
 4. Sale or share of Personal Information

Anaconda may use both session cookies (which expire once you close your web
browser) and persistent cookies (which remain on your device until they expire
or are deleted). Anaconda may also use Third-Party Cookies, which are placed by
a third party separate from Anaconda, for various purposes, including website
advertising and social media integration.

You may have the option to disable Performance and Analytics, Targeting or
Advertising, and Sell or Share cookies through your web browser settings or
opt-out through our Privacy Center.





3.3 GOOGLE ANALYTICS

We utilize various features provided by Google Analytics (GA) (User-ID tracking,
Demographics and interests reports, Remarketing, and AdWords integration) to
measure the performance and success of our products, marketing campaigns,
courses, and initiatives. These features may include tracking the number of
visitors to our website, analyzing user behavior on our website, and identifying
which pages and features are most popular with our users.

However, we recognize that the collection and processing of personal information
are subject to strict legal requirements under data protection laws and
regulations, including the General Data Protection Regulation (GDPR) in the
European Union. As such, we do not share Personal Information with GA that
originates from Austria, Denmark, Finland, France, Italy, and Norway, in
accordance with recent national rulings related to data protection.

Furthermore, we apply technical measures to exclude any kind of GA-related
tracking on our website in prohibited territories in order to ensure the safety
and security of our Users' Personal Information. These measures may include, but
are not limited to, blocking GA cookies and IP addresses from being transmitted
to GA servers and implementing opt-out mechanisms that allow users to choose
whether or not their personal information is collected and processed by GA.





4. WHAT RIGHTS AND CHOICES DO YOU HAVE CONCERNING THE PERSONAL DATA WE COLLECT


4.1 IF YOU ARE IN EUROPE, EEA OR THE UNITED KINGDOM

As a data subject, you have certain rights with respect to the personal
information that we collect and process. These rights include:

 1. Right of Access (Art. 15 GDPR). You have the right to request a copy of the
    personal information we hold about you and to know how that information is
    used. In accordance with this right, our organization will provide you with
    a copy of your personal data upon request, free of charge. You can request
    access to your personal data by request in our Privacy Center. It is
    important to note that in some cases, we may not be able to provide you with
    access to your personal data if it interferes with the rights and freedoms
    of others or if it is protected by legal privilege.
 2. Right to Rectification (Art. 16 GDPR). You have the right to request that we
    correct any inaccuracies in the personal information we hold about you. In
    accordance with this right, our organization allows individuals to request
    the correction of their personal data if they believe it to be incorrect or
    outdated. If we have disclosed incorrect information to third parties, we
    will take reasonable steps to inform them of the correction where
    appropriate.
 3. Right to Erasure (Art. 17 GDPR). You have the right to request that we
    delete your personal information in certain circumstances. In accordance
    with this right, our organization will erase your personal data upon
    request, provided that there are no overriding legitimate grounds for
    retaining it. It is important to note that in some cases, we may not be able
    to fulfill your request for erasure if your personal data is required for
    legal reasons or to perform our contractual obligations.
 4. Right to Restrict Processing (Art. 18 GDPR). You have the right to request
    that we restrict the processing of your personal information in certain
    circumstances. In accordance with this right, our organization will restrict
    the processing of your personal data upon request, provided that there are
    no overriding legitimate grounds for continuing the processing. This means
    that we will only store your personal data and not use it for any other
    purposes, unless you give us your consent.
 5. Right to Object (Art. 21 GDPR). You have the right to object to the
    processing of your personal information in certain circumstances, including
    for the purpose of direct marketing or profiling. In accordance with this
    right, our organization will stop processing your personal data upon
    request, provided that there are no compelling legitimate grounds for
    continuing the processing.

The exercise of this right differs from the Process to Object Sub-processors
established in our Sub-processors Policy, with which Customers can object to the
engagement of a Sub-processors by writing to privacy@anaconda.com in a timely
manner and following the appropriate steps for Sub-processors Objection.

 1. Right to Lodge a Complaint (Art. 77 GDPR). You have the right to lodge a
    complaint with the relevant supervisory authority if you believe we have
    violated your rights. We encourage all Customers and Users to bring any
    concerns to our attention by contacting our Data Protection Officer
    (privacy@anaconda.com). If you are not satisfied with our response, you have
    the right to file the complaint with the relevant Supervisory Authority.

The European Supervisory Authority responsible for Anacond, Inc., is the Berlin
Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219,
10969 Berlin, Germany, Phone: +49 (0) 30 13889-0, Fax: +49 (0) 30 2155050,
Email: mailbox@datenschutz-berlin.de

Overall, you have the right to be informed on the use of your personal data, and
you have the choice to request that we do not continue to process or store your
data for some reason. To review and update your personal data to ensure it is
accurate or request we delete or return your data to you, please contact
Anaconda’s Privacy Compliance Team and see how to use our Privacy Center below
(Section 4.5).





4.2 IF YOU ARE A CALIFORNIA CITIZEN

As a user, you have certain rights under the California Privacy Rights Act
(CPRA) (CA CIV code 1798.100 C) concerning your personal information. These
rights include:

 1. Right to delete Personal Information: You have the right to request that we
    delete any personal information collected about you. If we receive such
    request, we will not only delete your personal information from our records
    but also notify and demand to our service providers, contractors, and third
    parties to whom we have sold or shared your personal information to delete
    your information unless it is impossible or involves a disproportionate
    effort. We may maintain certain personal information despite your request
    for a number of stated legal purposes.
 2. Right to Correct Inaccurate Personal Information: You have the right to
    request that we correct any inaccurate personal information that we maintain
    about you.
 3. Right to Know What Personal Information has been Collected: You have the
    right to request that we disclose to you the categories of personal
    information we have collected about you, the sources from which we collect
    the personal information, the business purpose for collecting, selling or
    sharing your personal information, the categories of third parties to whom
    we disclose your personal information, and the specific pieces of personal
    information we collected about you.
 4. Right to Opt-Out of Sale of Personal Information: You have the right to opt
    out of the sale of your personal information to third parties. (See Section
    4.2 A).
 5. Right to Limit Use and Disclosure of Sensitive Personal Information: You
    have the right to direct us to limit the use of sensitive personal
    information that we collect about you.
 6. Non-Retaliation: We will not discriminate against you because you exercised
    any of your rights under the CPRA.
 7. Do not Share o Sell Information Clause.

We do not sell or share your personal information with third parties for
monetary or other valuable consideration, but your information might be shared
for other reasons (See Sections 3.1 and 3.2). Nonetheless, under the CPRA, we
are required to provide notice to California residents if their personal
information may be sold or shared and to provide them with the right to opt out
of the sale or sharing of their personal information. If you are a California
resident, you have the right to direct us not to sell or share your personal
information with third parties.

As part of your privacy choices, when you enter our webpage, you can decide not
to accept the cookies that involve sharing your personal information using our
Consent Manager.




If you are already opted-in, you can always opt out of the share or sale of your
personal information to third parties using your browser setting. If you opt-out
in compliance with the CPRA, we commit not to ask for consent to share your
information until at least twelve (12) months after the initial opt-out.

In case you are a minor under the age of 16, we will not sell or share your
personal information without your affirmative consent or the affirmative consent
of your parents or guardian if you are under the age of 13.

 1. Pre-Action Notice-and-Cure Requirement

If you believe that we have violated your rights under the CPRA, you may have
the right to bring legal action against us. Before doing so, you must provide us
with 30 days written notice identifying the specific provisions of the CPRA that
you allege we have violated. If we cure the noticed violation within the 30-day
period and provide you with an express written statement that the violations
have been cured and that no further violations shall occur, you may not initiate
any legal action.

However, if we continue to violate the CPRA after providing you with an express
written statement, you may bring an action against us to enforce the statement
and pursue statutory damages for each breach of the statement, as well as any
other violation of the CPRA that postdates said statement.

The Californian Competent Authority is the California Privacy Protection Agency,
2101 Arena Blvd, Sacramento, CA 95834. Phone: +1 (279) 895-1412, Email:
info@cppa.ca.gov





4.3 IF YOU ARE A CANADIAN CITIZEN

We comply with the Canadian Consumer Privacy Protection Act (Bill C-27) amending
the Personal Information Protection and Electronic Documents Act (PIPEDA) and
Personal Information and Data Protection Tribunal Act (PIDPT). If you are
Canadian Citizen, we guarantee that we collect personal information on a lawful
basis, and we share it under the provision of the Data Mobility Framework with
other organizations that provide the required security standards, requirements
for format, and transfer mechanism.




When we process your data we do not use automated decision-making. In case we
do, you will be informed, and we will comply with the Algorithmic Transparency
Principle, informing you (without risking our intellectual property) how we
implement said tools.

Once we process your personal information, you will have the right to know what
personal information is being collected, used, or disclosed. Also, you will have
the option to withdraw consent, the right to be forgotten, and the right to data
portability. In alignment with the Bill, we have created a Privacy Management
Program that includes the policies, practices, and procedures to facilitate the
way your exercise your rights. (See Sections 4.5 and 5)





4.5 USE OUR PRIVACY CENTER

This Section is oriented to guide you on how to make a request in our Privacy
Center. The "Delete all my data" request will attend to your rights of data
erasure, deletion, or the right to be forgotten. The "Do not Contact request"
will attend to your rights of Right to Restrict Processing and Right to Object,
we will continue to process your information for activities not related to
marketing and sales.

The "Download all my data" attends to your rights of Knowing What Personal
Information has been Collected from you and your rights of Access and Data
Portability. On the other hand, the "Correct my data" request attends to your
rights to Correct Inaccurate Personal Information or the right to rectification.

To make a request, simply provide the email associated with your account. We
will respond to your request within a maximum timeframe of thirty (30) to sixty
(60) days and may need to verify your identity before fulfilling your request.
Please note that certain rights may have limitations, and we must comply with
the laws of your jurisdiction. Our Privacy Compliance Team will assist you with
your request, providing appropriate information and guidance throughout the
process to protect your rights.





5. HOW WE KEEP YOUR PERSONAL DATA SECURE

We take data security seriously and have implemented various measures to ensure
that Customer Protected Data is safe during transmission. This includes using
AES-256 strong encryption for all ingested data and VPNs. Anaconda manages its
security infrastructure effectively by utilizing firewalls, routers, IPS/IDS
devices, load balancers, and VPN concentrators to control access between the
internet and its Cloud Service. Anaconda utilizes containerization and
segmentation to control access to networks and private clouds, only allowing
authorized traffic.

To maintain the highest level of security when personal data is at rest,
Anaconda performs periodic vulnerability assessments on its applications and
systems. These assessments include both automated analysis and manual
assessments, which will have a unique common vulnerability and exposure
identifier associated with a Common Vulnerability Scoring System (CVSS) that
will help us to remediate in a timely manner any urgent issue.

To ensure access to personal data, we regularly back up our systems used to
provide a Cloud Service to our Customers to ensure that their data is available.
These backups are appropriately classified according to our internal data
classification definitions and are protected to ensure that only authorized
individuals are able to access the Protected Data. This includes but is not
limited to data stored off-site in electronic media and the protection of hard
copy records.

Finally, to ensure the effectiveness of our Security System, we regularly test
and monitor its controls, systems, and network to validate proper implementation
and effectiveness in addressing the threats, vulnerabilities, and risks
identified. This testing and monitoring include internal risk assessments,
formal procedures such as port scans, testing, and validation of multi-factor
authentication for select environments, third-party compliance, including
hosting services and third-party components, penetration testing, and assessing
changes affecting systems processing authentications, authorizations, and
security audits.

If you need additional information, you can ask for our Security Information
Addendum, by writing to privacy@anaconda.com





6. INTERNATIONAL TRANSFER: WHAT YOU NEED TO KNOW


6.1 TRANSFER FROM THE EUROPEAN ECONOMIC AREA (EEA) AND THE UK TO THIRD COUNTRIES

We are headquartered in the United States of America. Personal data may be
accessed by us or transferred to us in the United States. If personal
information is transferred to Anaconda from the European Union or another
transfer or jurisdiction that has determined that the United States does not
provide an adequate level of protection, Anaconda will take adequate measures
designed to protect the personal information, such as ensuring that such
transfers are subject to a Data Processing Agreement and the terms of the EU
Model Clauses or other adequate transfer mechanisms as required under relevant
data protection laws.

Furthermore, in compliance with the GDPR and UK GDPR, we have performed a Data
Protection Impact Assessment to identify and mitigate any potential risks to
individuals' rights and freedoms, you can find our Transfer Impact Assessment
(TIA) at the end of our Data Processing Agreement.

Additionally, with Customers located in the UK, we sign an International Data
Transfer Agreement (IDTA) with its addendum approved in 2022 by the Information
Commissioners Office (ICO) in replacement of the European Contractual Clauses.





6.2 USE OF EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORK

As of July 16, 2020, the EU-U.S. and Swiss-U.S. Privacy Shield Framework is no
longer valid. However, Anaconda, Inc. continues to uphold and adhere to the
principles and commitments established by the Privacy Shield as part of our
ongoing commitment to protect the privacy and personal data of our users.

We have implemented policies, procedures, and technical measures to ensure that
all personal data transfers from the European Union and Switzerland to the
United States are conducted in accordance with the Privacy Shield principles. We
certify that we will continue to process personal data received under the
Privacy Shield Frameworks following the applicable Privacy Shield principles,
including the onward transfer requirements.

The U.S. Department of Commerce administered our Privacy Shield certification,
and we remain accountable for the personal data that we receive under the
Privacy Shield and subsequently transfer to a third party. We encourage any
individual who has inquiries or complaints regarding our compliance with the
Privacy Shield to contact us directly or to use the existing pathways already
described in this Policy.





7. WHAT YOU NEED TO KNOW ABOUT MINORS AND PERSONAL DATA

We are committed to providing a safe and secure environment for students who use
our Learning Services. Our Anaconda Learning Platform and other services as
EduBlocks are specifically designed to cater to the needs of students and to
provide them with an engaging and interactive learning experience. We take the
necessary steps to ensure that our services are age-appropriate and do not
contain any content that may be harmful to minors.

If you are under 18 years of age, you can rest assured that your personal
information is safe with us. We take all necessary measures to ensure that your
data is secure and protected. We fully comply with the Children's Online Privacy
Protection Act (COPPA) and any similar international, federal, state, or local
laws, rules, or regulations aimed at protecting children's privacy, if we
collect personal information from children under 13 years of age, we do it so
only with the express consent and participation of a parent or legal guardian,
and such information is collected for the sole purpose of providing our Learning
Services to the child and is never disclosed to any third parties without the
parent's or legal guardian's express consent.





8. DISCLAIMER

By agreeing to this Privacy Policy, you explicitly give Anaconda, Inc.
permission to process your personal data for the purposes stated above. If you
wish to withdraw your consent, you can contact our Privacy Compliance Team
through the Privacy Center. By providing us with your personal data, you
acknowledge that it may be stored or processed in the United States and subject
to US laws, including those allowing government agencies, courts, and law
enforcement to access personal data.





LEGAL IMPRINT

Anaconda Inc., (formerly Continuum Analytics, Inc.)

FEIN: 45-4029380

Locations:

Austin

1108 Lavaca Street Suite 110-645

Austin, TX, 78701, USA

New York

206 379 Broadway Ave., Suite 310

New York, NY 10013, USA

Anaconda Germany GmbH

VAT: DE289537954

Location:

Berlin

Friedrichstrasse 123

10117 Berlin, Germany

Our Approach to Privacy
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