Last Update: January 12, 2022

Sabalcore Computing Inc. (“us”, “we”, or “our”) operates the https://www.sabalcore.com website and provides high performance computing in the cloud services (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. Providing the data does not guarantee service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service, accessible from https://www.sabalcore.com

This Privacy Notice maybe in addition to other privacy notices related to other services Sabalcore provides.

Definitions

Service

Service is pay-per-use or term rental of high performance computing (HPC) systems in the cloud. Our relationship with you is we are your HPC service provider. The https://www.sabalcore.com website is operated by Sabalcore Computing Inc.

Data Subject (Registered User)

A data subject is an individual who has acknowledge they are a resident of the European Economic Area or not, reviewed the privacy policy, agreed to the terms of service, completed and submitted the user account application form, and deemed to be a valid data subject.

Personal Data

Personal Data means data that we collect for legitimate interests about a Data Subject who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself.

Data Provide by Data Subject

Data that maybe stored at the request of the Data Subject which may contain Personal Data and is not required for fulfilment of the Service.

Registered User Data

Data that is controlled by the Data Subject. This is data that the Data Subject transfers or generates using the service to or from the service.

Cookies

Cookies are small pieces of data stored on your computer. Only users of the website and registered Users are affected by cookies.

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, Sabalcore is a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We process your data and use services of various Service Providers in order to provide the Service.

Information Collection and Use

We collect and store different types of information for various purposes to provide our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”) in order to conduct the business. We accept the data as provided and make no obligation to verify its legitimacy. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City, Country
• website
• IP address origination
• Media access control address

We will use your Personal Data to contact you for communications regarding the service, information newsletters regarding the service, and other information that may be of interest to you. Contacting you by these communications is required to facilitate the service. As a Registered User, you are obligated to receive all of these communications from us during the relationship with us.

Data Provided by Data Subject

A Register Users may ask us to record certain personally identifiable information such as VAT numbers, purchase order numbers, or other. We are not obligated to control this information however we will treat it personal data.

Usage Data

We collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include identifiable information such as your computer’s Internet Protocol address (e.g. IP address), MAC address, and country of origin, browser type, browser version, the pages of our website that you visit, the time and date you accessed the service, the time spent logged into the service, unique device identifiers and other diagnostic data.

Registered User Data

Data that is controlled by the Data Subject. This is data that the Data Subject generates or transfers to or from the service in compliance with the terms of service. This data is not subject to this privacy policy.

Logs and accounting

We record activity logs and accounting data for the purpose of providing the Service.

Cookies Data

Part of our service uses modern web browsers to display Registered User data.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from our website and stored on your device. Only a Registered User will receive cookies.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Security Cookies. We may use Security Cookies for security purposes.

Use of Data

Sabalcore Computing Inc. uses the collected data for various purposes:

• To provide and maintain our Service
• To verify an individual’s identity and/or location (or the identity or location of our client’s representative or agent) in order to allow access to the service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To detect, prevent, and address security issues
• To provide you with general information about our services such as new or updated features.
• To validate authorized signatories when concluding agreements and transactions

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Sabalcore Computing Inc. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Sabalcore Computing Inc. may process your Personal Data:

• Because we may need to perform a contract with you
• Because you have given us permission to do so
• Because we have a Legitimate Interest
• To provide you with Direct Marketing
• To prevent fraud
• To maintain security
• For payment processing using third party providers which may include Stripe Inc., PayPal Inc., Bank of America Corp., and Intuit Inc.
• For personal data management using third party providers such as accounting, form data collection, and email. A list of providers we use is available upon request.
• Because we need to comply with Local, Federal, or International law

Retention of Data

Sabalcore Computing Inc. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Sabalcore Computing Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access Personal Data.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Sabalcore Computing Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there is an adequate level of protection and controls in place including the security of your data and other personal information and only when deemed necessary only to provide the service.

Disclosure of Data

Business Transaction

If Sabalcore Computing Inc. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data and Sensitive Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Sabalcore Computing Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Sabalcore Computing Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Sabalcore Computing Inc.
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security Of Data

The security of your data is important to us. Sabalcore accounts for the technology, the costs of implementation and the nature, scope, context and purposes of Processing as well as the risks involved, and maintains appropriate technical and organizational measures to ensure a level of security appropriate to the risk of Processing Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Sabalcore Computing Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us using the information in the “Contact Us” section at the end of this policy.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data. Please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Sabalcore Computing Inc. relied on your consent to process your personal information.

Please note that we will ask you to verify your identity through several forms before responding to such requests. Requests will be fulfilled as soon as possible.

If you are not a resident of the European Economic Area (EEA), we have no obligation to fulfil these rights.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related.

We have reviewed the Service Provider’s Privacy Policies and Data Processor obligations for GDPR. Disclosures of Personal Data which we make to our third party service providers, as described in this section, will be made subject to conditions of confidentiality and security as we may consider appropriate to the specific circumstances of each such disclosure.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

A list of third party providers is available upon request.

Payment Information

We provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card or bank details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. A list of the business operations providers we work with is available upon request.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a link, you will be directed away from our website to that site. We are not responsible for the privacy policies of websites.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us immediately. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers as soon as possible.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We may notify you of any changes by posting the new Privacy Policy on this page. We are not obligated to confirm you received notice of the changes. The “LAST UPDATED” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice. Use of the Services following these changes (or your continued provision of Personal Data to us) signifies acceptance of the revised Privacy Notice.

As a courtesy, we will let you know via email and/or a prominent notice on our Service the updated “effective date” at the top of this Privacy Policy. We are not obligated to confirm you received notice.

You are advised to review this Privacy Policy periodically for any changes regularly. Changes to this Privacy Policy are effective when they are posted on this page.

Additional information for the EEA

We seek to resolve directly all complaints about how we handle personal information. Data Subjects may also file a complaint with a supervisory authority in the EEA competent for their relevant country or region. Please contact us directly for any concerns.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: busdev@sabalcore.com