Last updated 03.28.2021 

PANDA PRIVACY POLICY

Responsibly handling customer data has been of utmost importance to PANDA since the inception of the company. This privacy statement explains our collection, use, and disclosure of personal data in connection with current and prospective customers and authorized users of our Services. This privacy statement applies to use of personal data by Panda AI, Inc., our subsidiaries and affiliates (“PANDA,” “We,” or “Us). References to our “Services” in this statement include our websites, apps, software, services, and devices. 

This privacy statement does not apply to personal information we process on behalf of our customers. We process that data as described in our agreements. Please refer to the privacy notices of our customers to learn how they process your data.  

PERSONAL DATA WE COLLECT.
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We collect information about you from different sources and in various ways when you use our products, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.

Information you provide directly. We collect personal data you provide to us. For example:

Contact Information. To create or update a PANDA workspace account, you supply PANDA with an email address, phone number, password, domain, employer and job title, and/or similar account details.

Payment Information. Customers that purchase our services provide PANDA (or its payment processors) with billing details such as credit card information and/or a billing address.

Content and Files. If you send us emails or other communications, we will collect and retain those communications. 

Information we collect automatically. When you use our products, we collect some information automatically. For example: 

Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the Cookies, Mobile IDs, and Similar Technologies section below, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.  

Usage data. We automatically log your activity on our websites, apps and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website. 

Geolocation data. Depending on your device and app settings, we collect geolocation data when you use our apps or online services.

Session data. PANDA may also collect and compile data related to customer’s and the authorized users’ use of the Services and the Service’s performance, including to compile aggregated statistical and performance information related to the provision and operation of the Services.Information we create or generate. We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.
 
Information we obtain from third-party sources. We also may obtain any of the above categories of information from third parties. These third-party sources include, for example:

Data brokers. Data brokers and aggregators from which we obtain data to supplement the data we collect.

Third party partners.  Third party applications and services, including social networks you choose to connect with or interact with through our services.

Co-Branding/Joint Partners.  Partners with which we offer co-branded services or engage in joint marketing activities.

Service providers.  Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.

Publicly available sources.  Public sources of information such as open government databases

When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain products or features, those products or features may not be available or function correctly. 

COOKIES, MOBILE IDS, AND SIMILAR TECHNOLOGIES.
We use cookies, web beacons, mobile analytics, and advertising IDs, and similar technologies to operate our websites and online Services and to help collect data, including other identifiers and device information and usage data. Cookies are small text files placed on your device that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. 

Web beacons are electronic (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way websites access and use cookies. Our apps contain software that enables our third-party analytics and advertising partners to access the mobile IDs. 

We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site (or use app). We and our partners also use these technologies to collect personal information about your online activities over time and across different websites or online services. This information is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the information we collect or infer with third parties for their purposes. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

The third-party analytics providers we use on our websites and in our Services include, for example:

Company: Google Analytics

Purpose(s): Analytics

Privacy Notices: www.google.com/policies/privacy/partners 

Manage Settings (opt-out): https://tools.google.com/dlpage/gaoptout

To learn about their privacy practices and how to opt-out from their use of cookie data for targeted advertising purposes, click on the links above. 

These companies may also participate in associations that provide simple ways to opt out of analytics and ad targeting, which you can access at: 

United States: NAI (http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/

Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/

Europe: European Digital Advertising Alliance (http://www.youronlinechoices.com/

California “Do Not Sell My Personal Information”

The California Consumer Protection Act (“CCPA”) requires us to disclose categories of personal data sold to third parties and how to opt-out of future sales. The CCPA defines personal information to include online identifiers, include IP address, cookie IDs, and mobile IDs. The law also defines a “sale” to include simply making data available to third parties in some cases. We let advertising and analytics providers collect IP addresses, cookie IDs, mobile IDs through our sites and apps when you use our online services, but do not “sell” any other types of personal information.

If you do not wish for us or our partners to “sell” your personal data to third parties for advertising purposes, you can make your Do Not Sell Request by visiting the links above or contacting us at our information below. 

Note that although we will not “sell” your personal data after you click that link, we will continue to share some personal information with our partners (acting as our service providers) to help us perform advertising-related functions, including managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads, and/or reducing ad fraud. Further, clicking the link will not necessarily opt you out of the use of previously sold personal information or stop all interest-based advertising. If you access this site (or app) from other devices or browsers, visit the link below from those devices or browsers to ensure your choice applies to the data collected when you use those devices or browsers. 

Other information related to your right to opt-out from sales of personal data is contained in the California Privacy Rights section of this statement.

Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. 

Mobile Advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs. Email web beacons. Most email clients have settings which allow you prevent the automatic downloading of images, which will disable web beacons in the email messages you read. 

Do Not Track. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above. 

Our use of personal data.
PANDA will use any of the categories of personal data described above for the following purposes: 

To provide, update, and maintain our Services. This includes use of the other information described above to support the delivery of the Services under a customer agreement, train PANDA’s AI models, prevent or address service errors, security or technical issues, analyze and monitor usage, trends, and other activities, or at an authorized user’s request.

To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your provided contact information to respond.

To send emails and other communications. We may send you service, technical, and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our services, our services offerings, and important services-related notices, such as security and fraud notices. These communications are considered part of the Services, and you may not opt-out of them.

For billing, account management, and other administrative matters, PANDA may need to contact you for invoicing, account management, and similar reasons, and we use account data to administer accounts and keep track of billing and payments.

For marketing and personalization purposes.

As required by applicable law, legal process, or regulation.

OUR SHARING OF PERSONAL DATA.
We share personal data with your consent or as necessary to complete your transactions or provide the products you have requested or authorized. For example, when you provide payment data to make a purchase, we will share that data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services. 

In addition, we share each of the categories of personal data described above for the following business purposes: 

Our subsidiaries, affiliates, and related companies share common data systems and process personal data as needed to provide our products and operate our business. 

We share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. 

We may also disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets. 

We will also access, transfer, disclose, and preserve personal data when we believe that doing so is necessary to:

Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;

Protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;

Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks; or

Protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

Third-party analytics companies also collect personal data through our website and apps including, transaction details, account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. 

Finally, we may share de-identified information in accordance with applicable law. 
Please not that some of our products include references or links to products provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or consent to our sharing personal data with them, that data is governed by their privacy statements.

CHOICE AND CONTROL OF PERSONAL DATA.
Access, correction, and deletion.
If you wish to request access to, or correction or deletion of, personal data about you that we hold, you my email support@getpanda.ai.

If you cannot access certain personal data we have via the links above or directly through the PANDA products you use, you can always contact us as described at the bottom of this privacy statement. However, to the extent permitted by applicable law, we reserve the right to decline requests that are unreasonable or excessive, where providing the data would be prohibited by law or could adversely affect the privacy or other rights of another person, or where we are unable to authenticate you as the person to whom the data relates.  

Communications preferences. You can choose whether to receive promotional communications from us by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message. These choices do not apply to mandatory service communications that are part of certain of our products, or to surveys or other informational communications that may have their own unsubscribe method. 

Choices for Cookies and Similar Technologies. See the Cookies section for choices about cookies and other analytics and advertising controls.

EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data: 

You can request access to, and rectification or erasure of, personal data;

If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;

If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing; 

You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and

For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests contact us at support@getpanda.ai.  When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party.  You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

CALIFORNIA PRIVACY RIGHTS
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information. 

Right to Know.
You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by contacting us at support@getpanda.ai. 

Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, email support@getpanda.ai.

Right to Opt-Out. You have a right to opt-out from future “sales” of personal information. Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this privacy statement may be considered a “sale” under those definitions. In particular, we let analytics provides collect IP addresses, cookie IDs, and mobile IDs through our sites and apps when you use our online services, but do not “sell” any other types of personal information. For more information, including how to opt-out, please see the Cookies section of this statement. We do not knowingly sell the personal information of minors under 16 years of age.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us. 

Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We may verify your request by asking you to email your request from the email address associated with your Panda account or requiring you to provide information necessary to verify your account or identity.

Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.

RETENTION OF PERSONAL DATA
We retain personal data for as long as necessary to provide the products and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

DATA SECURITY
We take reasonable and appropriate steps to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction. 

To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts. 

LOCATION OF PERSONAL DATA
The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that the data we collect under this statement is processed according to the provisions of this statement and applicable law wherever the data is located.

CHANGES TO THIS PRIVACY STATEMENT
We will update this privacy statement when necessary to reflect changes in our products, how we use personal data, or the applicable law. When we post changes to the statement, we will revise the "Last Updated" date at the top of the statement.  If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law. 

HOW TO CONTACT US
If you have a privacy concern, complaint, or a question for PANDA, please contact us at support@getpanda.ai.