PRIVACY NOTICE

Last updated May 30, 2023

We take your privacy very seriously. Thank you for choosing to be part of our community at Curii Corporation. We are committed to protecting your personal information and your right to privacy.

Curii Corporation operates several websites (the “Websites”) including https://curii.com, https://summit.arvados.org/ and https://playground.arvados.org which redirects to https://workbench.pirca.arvadosapi.com (referred to as Arvados Playground).

When you visit our Websites, and more generally, use any of our services (the “Services”, which include the Websites), we appreciate that you are trusting us with your personal information. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. This privacy notice applies to all information collected through our Services (which, as described above, includes our Websites), as well as, any related services, sales, marketing or events.

If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@curii.com. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

TABLE OF CONTENTS

1. INFORMATION WE COLLECT

Personal Information

This includes information that identifies an individual.

Signing up for an account on the Arvados playground requires Person Information (i.e. Organization, E-mail at Organization). You may provide additional data for your account (e.g. Role at Organization, Website URL). You don’t have to provide this additional information, and you can erase it at any time. Curii Corporation stores your account data as long as your account remains open.

In order for you to take advantage of particular opportunities provided through the Websites (for example, to receive white papers, comment on a blog post, or sign-up for a program), we may require that you furnish Personal Information. We collect Personal Information from you, such as your name, postal address, telephone number and email address, only when you voluntarily provide it to us.

We may also combine Personal Information you provide to us with publicly available information, such as your organization’s name, in the event you provide us with an email address from your organization.

Non-Personal Information

Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Websites.

We automatically collect certain information when you visit, use or navigate the Websites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Websites and other technical information. This information is primarily needed to maintain the security and operation of our Websites, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes: Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Websites and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Websites (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Websites. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Websites. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can refuse access to the detailed location information or disable your Location setting on your device, but we will still have a record of your IP address, because that is necessary to provide the service. If you opt out of detailed location sharing, you may not be able to use certain aspects of the Services.

2. HOW WE USE YOUR INFORMATION

Personal Information

We may use Personal Information:

to contact you in special circumstances related to your Arvados Playground account;

to fulfill your requests, such as to create a account, send a requested white paper, send online video updates or complete your purchases;

to operate an online service, to send you important information regarding the Websites and issues specifically affecting that service and your use of the service, including changes to Websites terms, conditions and policies. Because this information may be important, you may not opt out of receiving it;

to inform you of products, programs, services and promotions from us and/or our marketing partners that we believe may be of interest to you;

for our internal business purposes, such as data analysis, audits, developing new products, enhancing our Websites, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns.

Non-Personal Information

Because Non-Personal Information does not personally identify you, we may use such information for any purpose, at our sole discretion, unless otherwise noted in this Privacy Policy. In addition, we reserve the right to share Non-Personal Information with affiliates and other third parties, for any purpose. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we do combine any Non-Personal Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

IP Addresses. We use IP addresses for purposes such as calculating Websites’ usage levels, helping diagnose server problems and administering the Websites. We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Information. Please note that we treat IP Addresses, server log files and related information as Non-Personal Information, except where we are required to do otherwise under applicable law.

3. SHARING YOUR INFORMATION

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may disclose Personal Information:

to our third party service providers who need the information to provide us with components of our online service and/or such services as Websites’ hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service and email delivery services;

to identify you to any person to whom you send messages regarding Website-related content through the Website;

to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including, without limitation, in connection with any bankruptcy or similar proceedings); and

as we believe appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is explained in “PRIVACY RIGHTS”

5. TRANSFERRING INFORMATION INTERNATIONALLY

We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Websites from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information. If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

6. HOW LONG DO WE KEEP YOUR INFORMATION

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 2 years except for the account data stored in your Arvados playground account. Curii Corporation stores your Arvados playground account data as long as your account remains open.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. INFORMATION SAFETY

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Websites is at your own risk. You should only access the Websites within a secure environment.

8. COLLECTING INFORMATION FROM MINORS

We do not knowingly solicit data from or market to children under 18 years of age. By using the Websites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Websites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware that your child has provided us with Personal Information, please contact us in accordance with the “ CONTACTING US ABOUT THIS NOTICE” section below.

9. PRIVACY RIGHTS

You may review, change, or terminate your account at any time.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Websites. To learn how to opt-out of interest-based advertising by advertiser visit http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. CALIFORNIA RESIDENTS PRIVACY RIGHTS

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Websites, you have the right to request removal of unwanted data that you publicly post on the Websites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Websites, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

12. NOTICE UPDATES

We will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. OTHER IMPORTANT INFORMATION

Forums and Profiles. We may make other services available through the Websites (for example, message boards, forums, chat functionality, “profile pages” and blogs) to which you are able to post information and materials (collectively referred to as the “Forums”). Please note that any information you disclose through the Forums may be available to visitors to the Websites and to the general public. We urge you to exercise discretion and caution when deciding to disclose Personal Information, or any other information, via the Forums. We are not responsible for the use of any Personal Information you disclose through the Forums.

Third Party Sites and Services. We provide links on the Websites as a convenience for our users. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, or of other websites or services operated by third parties. Your activities, including your provision of Personal Information, with any such third parties or such third parties’ websites or services will be governed by the privacy policy of such third parties. The inclusion of a link on the Websites does not imply endorsement of the linked website by us or by our affiliates. We are not responsible for the use of any Personal Information you disclose to third party sites or services.

14. CONTACTING US ABOUT THIS NOTICE

If you have any questions regarding this Privacy Policy, please contact us by email at info@curii.com, or please write to the following address:

General Counsel Curii Corporation 212 Elm St, #310 Somerville, MA 02144

15. REVIEWING, UPDATING OR DELETING THE DATA WE COLLECT FROM YOU

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.

If you no longer wish to receive marketing-related emails from us, you may opt out by following the “unsubscribe” instructions in the latest such message you have received or by contacting us. We will endeavor to comply with your request as soon as reasonably practicable.