We at Hibernating Rhinos Limited ("Hibernating Rhinos" "us", "we", or "our") recognize and respect the importance of maintaining the privacy of our customers. This Privacy Notice describes the types of information we collect from you when you visit our websites ("Site"), download our applications ("App") and/or use our services ("Services"). This Privacy Notice also explains how we may process, transfer, store and disclose the data collected, as well as your ability to control certain uses of the collected data. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://ayende.com/terms ("Terms").

Hibernating Rhinos Limited is the data controller in respect of some of the processing activities outlined in this Privacy Notice. Our registration number is 513553742. Hibernating Rhinos Limited is the data processor with respect to the data that is processed by our customers using our App. Our co-controllers are listed below.

"Personal Data" means any data that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.

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Privacy Notice Key Points

The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.

• Personal Data We Collect. When you register, we collect Personal Data provided by you, such as your name, email address, the company you work for and your job title and payment details. If you register through a third party log-in/ account registration service (such as Facebook, Gmail, etc.), we collect your basic profile information from such third-party log-in/account registration service. We also collect Personal Data when you use the Site and/or Services, or contact us with questions or complaints. We generally do not collect Personal Data when you use the App, unless you request support or send us logs. We also collect Personal Data when you sign up for bootcamp lessons and/or webinars. When you visit our Site, we automatically collect your IP address and operating system.
• How We Use the Data We Collect. We use the data (including Personal Data) we collect mainly to administer and provide the App, Site and/or Services, contact you with administrative information, contact you with marketing offers (if you indicated your desire to receive them), and improve the App, Site and/or Services.
• Basis for Processing Your Personal Data. Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to you. Processing the data for marketing purposes is based upon your consent. Processing for the purposes of developing and enhancing our products and services, for analytics and usage analysis, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
• Sharing the Personal Data We Collect. We may share the Personal Data we collect with our service providers and subcontractors who assist us in the operation of the App and/or Site and process the data on our behalf and under our instructions. We share Personal Data with certain co-controllers, as listed below. Additionally, when we act as a processor on behalf of our Customers, we will share your Personal Data with the applicable Customer.
• International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Data. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
• Your Rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Data and obtain a copy of the Personal Data we have collected about you. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. You also have the right to object at any time to processing your personal data for marketing purposes. You have the right to withdraw your consent to processing, if provided, at any time by contacting us as detailed in this Privacy Notice.
• Use of Cookies and Similar Technologies. We use cookies and similar technologies to help personalize your experience by providing you targeted content and advertisements matching your interests, which we and/or third parties have identified based on your activity and browsing history on the Site, for purposes of providing the Services, collecting aggregate and anonymized analytical data and protecting our Site and Services. You can adjust your settings to determine which cookies you do or do not allow. Changing your settings and/or deleting existing cookies may affect the Services.
• Retention. We retain data for as long as necessary for the purposes set forth in this Privacy Notice.
• Security. We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Data, but they do not provide absolute data security.
• Changes to the Privacy Notice. We may change this Privacy Notice from time and shall notify you of such changes.

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Data We Collect

We collect data from you when you choose to use our App, Site and/or Services. In order to use our App, Site and/or receive related Services and/or make a purchase through the Site, you will be required to register and provide us with certain Personal Data. We also collect Personal Data when you make use of the Site, request support or send us logs with respect to your use of the App, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason. If you use the Services by logging in through Facebook and/or any other third-party login service, we may also receive Personal Data about you as provided by Facebook and/or any other third-party login service. Please check such third-party’s policies in order to understand what data we receive.

Examples of the Personal Data that we collect from you may include your name, address, birth date, gender, IP address, phone number, e-mail address, and the last four (4) digits of your credit card number. Such Personal Data may be collected by us through the Site.

In addition, when you use the Site, certain data may be automatically gathered about your computer or mobile device, such as operating system, IP address, device ID, and subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any data regarding your viewing and purchase history on our Site.

It is your voluntary decision whether to provide us with any such Personal Data, but if you refuse to provide such data we may not be able to register you to the Site and/or provide you with the Services.

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How We Use Your Personal Data

General

We and any of our trusted third-party subcontractors and service providers may use the Personal Data we collect from and about you for any of the following purposes:

1. to provide you with the App, Site and/or Services;
2. to respond to your inquiries or requests, contact and communicate with you;
3. to develop new products or services and conduct analyses to improve our current content, products, and services;
4. to provide you with customized content, targeted offers, and advertising on the Site, on other third-party sites or apps you may visit, or via e-mail, based upon your browsing history on our Site and/or your preferences;
5. to contact you with informational newsletters and promotional materials relating to our App, Site and Services;
6. to review the usage and operations of our App, Site and Services;
7. to use your data in an aggregated, non-specific format for analytical purposes (as detailed below);
8. to prevent fraud, protect the security of our App, Site and Services, and address any problems with the App, Site and/or Services and
9. to provide customer support.

Statistical Data

By analyzing all data we receive, including all data concerning users, we may compile statistical data across a variety of platforms and users ("Statistical Data"). Statistical Data helps understand trends and customer-needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Data is anonymous and aggregated and we will not link Statistical Data to any Personal Data. We may share such Statistical Data with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

Analytics

We, or our service providers or subcontractors, may use analytics tools ("Tools"), including "Google Analytics" and "Facebook Pixel" to collect data about the use of the Site and/or Services. Such Tools collect data such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. The Tools may collect certain Personal Data, and may link such Personal Data to specific data stored in our customer database. We use the data we get from the Tools to improve our App, Site and Services. Google's ability to use and share data collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use located at https://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at https://www.google.com/policies/privacy/. Facebook's ability to use and share data collected by Facebook Pixel about your visits to this site is restricted by Facebook Business Tools Terms located at https://www.facebook.com/legal/technology_terms and the Facebook Data Policy page located at https://www.facebook.com/about/privacy/update

Legal Uses

We may use your Personal Data as required or permitted by any applicable law.

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Basis for Processing Your Personal Data

Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to you, including responding to your inquiries or requests, contacting and communicating with you and providing customer support. When you make a purchase (which may be subject to an agreement executed between you and us), use our Services or engage in any other transaction with us, we may also process your Personal Data to perform that contract.

Processing the information for third-party marketing purposes is based upon your consent. When using the Services. You may withdraw your consent to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes at any time by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.

Processing for the purposes of developing new and enhancing our products and Services, for analytics and usage analysis, for the marketing of our products and services, and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue. In conducting such processing activities, we balance these legitimate interests against the rights and interests of our users. If you would like more information regarding how we make such determinations, please contact us through the contact information specified below.

Please note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your Personal Data. Please contact us if you would like details about the specific legal ground we are relying on to process your Personal Data.

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Disclosure of Data

We may share your data, including Personal Data, as follows:

As processors

When we act as a processor on behalf of our Customers, we will share your Personal Data with the applicable Customer.

Business Partners, Service Providers, Affiliates, and Subcontractors

We may disclose data, including Personal Data we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such data to:

1. help us provide you with the Site, App and/or Services;
2. aid in their understanding of how users are using our App, Site and Services; and
3. when you have consented to such disclosure, provide to you targeted offers and advertising on both our Site, as well as on other sites you choose to visit, based upon your browsing history on our Site and/or your preferences.

Data Controllers

When you use our Site and/or Services, we also disclose your Personal Data to additional third parties, which act as co-controllers with respect to the collection of your Personal Data. For further details regarding our arrangement with such co-controllers, please contact us through the contact information listed in this Privacy Notice. The details and contact information of such controllers are as set forth below:

International Transfer

We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them data we receive (including Personal Data). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.

Business Transfers

We may transfer our databases containing your Personal Data if we sell our business or part of it, including in cases of liquidation. Data about our users, including Personal Data, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.

Law Enforcement Related Disclosure

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and data of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Data with third parties:

1. if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice);
2. to protect the rights, property or safety of third parties;
3. when required by law, regulation subpoena, court order or other law enforcement related issues; or
4. as is necessary to comply with any legal and/or regulatory obligation.

You can request such Personal Data as specified herein by emailing us at ayende@ayende.com.

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How We Protect Data

We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

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How to Access and Limit Our Use of Certain Data

You have certain rights in relation to the Personal Data that we or our co-controllers hold about you, as detailed below. For any requests to exercise such rights with respect to information held by our co-controllers, please contact the applicable co-controller directly. If you wish for us to notify all co-controllers, please specify that when you contact us in order to exercise any of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any data and/or comply with any of your requests, as detailed below:

• Right of Access and Data Portability. You have a right to know what Personal Data we collect about you and, in some cases, to have the data communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Data you provided to us (excluding data that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Data to another party. If you wish to exercise this right please contact us letting us know what data in particular you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the data you request, for instance, if the data includes Personal Data about another person. Where we are not able to provide you with data that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
• Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Data and/or that we suspend the use of Personal Data, the accuracy of which you may contest, while we verify the status of that Personal Data. We will correct your Personal Data within a reasonable time from the receipt of your written request thereof.
• Deletion of Personal Data. In certain circumstances you have a right to have Personal Data that we hold about you deleted. Should you wish to have any Personal Data about you deleted, please contact us, using the contact information specified in this Privacy Notice. Subject to applicable law, we will delete Personal Data provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Data. We cannot restore data once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should request to terminate your account with us and clear our cookies from any device where you have visited our Site. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your data in an anonymized form.
• Account Deactivation. You can ask us to deactivate your account by contacting us using the information below. In order to deactivate your account, we may ask you for additional information.
• Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
• Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Data including for the purpose of direct marketing.
• Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent.
• Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.

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Data Retention

Subject to applicable law, we retain data as necessary for the purposes set forth above. We may delete data from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice.

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Cookies and Similar Technologies

We use cookies and similar technologies to help personalize your experience. A "persistent" cookie may be used to help save your settings and customizations across visits. Third parties through which we provide the Services and/or our business partners may be placing and reading cookies on your browsers, or using web beacons to collect data in the course of advertising being served on different websites.

What are Cookies?

A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.

• A "session cookie" is temporary and will remain on your device until you leave the Site.
• A "persistent" cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it.
• First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use first.
• Data may also be collected through web beacons, which are small graphic images ("pixel tags"), which usually work together with cookies in order to identify users and user behavior. These may be shared with third parties.

We may use the terms "cookies" to refer to all technologies that we may use to store data in your browser or device or that collect data or help us identify you in the manner described above.

How We Use Cookies

The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

How to Adjust Your Preferences

Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.

Third Party Cookies

• Google Analytics
• Google Ads
• Facebook Ads
• Linkedin Ads

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Communications

Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You may remove your Personal Data from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at ayende@ayende.com. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may cancel your account.

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Children

We do not knowingly collect personally-identifiable data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.

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Changes

When visiting this Site, you shall be asked to accept the terms of this Privacy Notice. If you do not agree with the terms hereof, please do not use the Site. We may update this Privacy Notice from time to time – we encourage you to review it periodically. By continuing to access or use the Site and/or Services after those changes become effective, you agree to be bound by the revised privacy notice.

We will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.

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Comments and Questions

If you have any comments or questions about our privacy policy, or if you wish for us to amend or delete your Personal Data, please contact us at ayende@ayende.com.

Last updated: February 2021