Privacy Policy

Last Updated: October 27, 2026

Protecting your privacy is really important to us. With this in mind, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the "Revision history" below to indicate when those changes will become effective.

1 Purpose

This Privacy Policy is incorporated by reference into the Sagemath Terms of Service (the “Terms”). The terms “Sagemath”, “we”, and “us” include Sagemath, Inc. and our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. All other terms not defined in Section 13 or otherwise herein will have the meanings set forth in the Terms.

2 Scope

This Privacy Policy applies to Personal Information that is Processed by Sagemath in the course of our business, including on Sagemath websites (each a “Site”), mobile applications, forums, blogs, and other online or offline offerings (collectively the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Sagemath are expected to protect that data by adherence to this Privacy Policy.

Sagemath complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Sagemath has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Sagemath has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit www.dataprivacyframework.gov. Additionally, Sagemath may protect information through other legally valid methods, including international data transfer agreements.

This Policy applies to all Sagemath’s operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates certified under the DPF program and any additional subsidiary, affiliate, or branch of Sagemath that we may subsequently form.

3 Transparency Notice - Types of Personal Information We Collect and How We Use It

The types of Personal Information we may collect, how we use it, and the lawful basis for processing depend on the nature of your relationship with Sagemath and the requirements of applicable law. We endeavor to collect only Personal Information that is relevant to providing, securing, improving, and supporting the Services and to meeting our legal and business obligations.

Where applicable data protection law requires a lawful basis for processing Personal Information, Sagemath relies on the lawful basis appropriate for the particular purpose, including performance of a contract, legitimate interests, consent, compliance with legal obligations, and, where applicable, vital interests or tasks carried out in the public interest. For example, we may process Personal Information to provide and secure the Services, process payments, respond to requests, comply with law, or process optional cookies and marketing communications where consent is required.

3.1 Types of Personal Information We Collect

Sagemath collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees (collectively “Individuals”).

Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Sagemath, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

• Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Sagemath’s newsletter or a loyalty program that we may offer, request to receive customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily.
• Posting on the Services. Sagemath may offer publicly accessible forums, blogs, and social media pages. You should be aware that, when you disclose information about yourself in on Sagemath’s forums, blogs, and social media pages, the Services will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

Automatic Data Collection. We may collect the following information automatically through our Services or other methods of web analysis: your Internet protocol (IP) address, cookie identifiers, details about your browser or device, and information about how you use the Services.

Public Share Views. When you are signed in and view or copy files from a public share, including one you published yourself, we record that your account accessed that share, the project it belongs to, whether you are an owner, a collaborator or another visitor of that project, your approximate region (one of six world regions, such as Western Europe, derived from your recent connection; never your country or city), and the date and time of your first access that day. We do not record which files you opened or how often. We keep at most one record per account, share and day. We use these records to investigate security problems and abuse, to show the owners and collaborators of the shared project how often the share is viewed and from which regions (counts only, never which accounts viewed it; a region is shown only when at least five viewers come from it), and to produce aggregate statistics, including totals by region, that include only groups of at least five viewers. We rely on our legitimate interests in securing the Services and in providing these statistics, and we delete these records after 13 months.

Project Access Records. When someone is added to or removed from a project, or their role in a project changes, we record the project, the account whose access changed, the account that made the change (and, for an accepted invitation, the account that sent it), the role, how the change was made (for example, accepting an invitation or being added to a course), and the time. These records contain account identifiers only, not names, email addresses or file contents, and project members cannot delete them. We use them to investigate security problems and abuse, such as unauthorized access to a project, relying on our legitimate interest in securing the Services, and we delete them after 13 months.

Information from Other Sources. We may receive information about you from other public sources, including through Third-Party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to Sagemath and to enhance our ability to provide you with information about our business, products, and Services.

3.2 How Sagemath, Inc. Uses Your Information

We Process Personal Information about Individuals for the following business purposes, relying on the lawful basis appropriate for each purpose, such as performance of a contract, legitimate interests in operating, securing, improving, and supporting the Services, compliance with legal obligations, or consent where required by applicable law:

To Provide Products, Services, or Information Requested:

• Generally manage Individual information and accounts;
• Respond to questions, comments, and other requests;
• Provide access to certain areas, functionalities, and features of Sagemath’s Services;
• Contact you to answer requests for customer support or technical support;
• Allow you to register for events.

Administrative Purposes:

• Measure interest in Sagemath’s Services;
• Develop new products and Services;
• Ensure internal quality control;
• Verify Individual identity;
• Communicate about Individual accounts and activities on Sagemath’s Services and systems, and, in Sagemath’s discretion, changes to any Sagemath policy;
• Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
• Process payment for products or services purchased;
• Process applications and transactions;
• Prevent potentially prohibited or illegal activities (which may include the use of automated, AI-assisted analysis for abuse detection);
• Enforce our Terms.

Marketing Sagemath Products and Services. We may use Personal Information to tailor content and notify you about offers, products, and services that may be of interest to you. We rely on consent where required by applicable law, or on legitimate interests where permitted by applicable law. You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as set forth below.

Research and Development. Sagemath may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. We may share anonymous Individual and aggregate data for research and analysis purposes.

Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Sagemath’s or our business partners’ products and services or upcoming special offers/events. We offer the option to decline these communications at no cost to the Individual by following the instructions set forth below.

Anonymous and Aggregated Information Use. Sagemath may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Sagemath’s Services, or other analyses we create. Anonymized or aggregated information is not treated as Personal Information when it cannot reasonably be used to identify you, and Sagemath may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Sagemath and with Third Parties for our or their purposes in a form designed to prevent anyone from identifying you.

Sharing Content. Sagemath’s Services may offer various tools and functionalities that allow you to share content. For example, Sagemath allows you to provide information about your colleagues, students, or friends through our course management system and referral services, such as inviting a collaborator to a project. Our referral services may allow you to forward or share certain content with others, such as emails inviting them to use our Services. Email addresses that you may provide in such situations will be used to send the content or link you request, but will not be collected or otherwise used by Sagemath or any other Third Parties for any other purpose. The Services also allow you to share your content with Third Parties such as GitHub and NPM. Any Personal Information you choose to share with these Third Parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of these Third Parties before submitting your Personal Information.

Other Uses. Sagemath may use Personal Information to pursue our legitimate interests, such as direct marketing where permitted by applicable law, marketing research, network and information security, and fraud prevention, where those interests are not overridden by your rights and interests. Sagemath may also use Personal Information for other purposes disclosed to you at the time you provide Personal Information or otherwise with your consent.

3.3 Cookies and Pixel Tags (Web Beacons)

We, as well as Third-Parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. We use the following required cookies to make sure that the Services work properly.

  Cookies	Purpose
  remember_me	Persistent auth token to keep you signed in.
  account_id	Stores your account ID for the client UI.
  cocalc_version	Client version for compatibility checks before project access.
  connect.sid	Session cookie used for Passport/SSO login flows.
  get_api_key	Temporary cookie used during SSO API key requests.
  PWRESET	Short-lived password reset token.
  SMCSERVERID3	Load balancer stickiness cookie set by HAProxy.
  cc_cookie	Stores cookie banner choices, including consent categories and revision.
  cocalc_youtube_consent	Stores whether you allowed embedded YouTube videos to load.

  Please note that we do our best to keep this table updated, but the number and names of cookies may change from time to time. You may not opt-out of the use of these cookies since it would be impossible for us to provide the service otherwise.

  With your consent, we may use optional analytics cookies to understand how the site is used. Examples include Google Analytics cookies such as _ga, _gid, and related _ga* cookies, as well as the CoCalc analytics cookie CC_ANA.

  If enabled and consented to, first-party usage metrics may record product interactions in our own systems. These usage metrics are not managed as browser cookies.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement on that web page. We do not use pixel tags directly, but some of our service providers, including HubSpot, Salesloft, and Zendesk, may use similar technology to let us know that email messages have been opened, acted on, or forwarded. You can review the privacy policies of those providers on their respective websites.

3.4 Third-Party Websites, Social Media Platforms, and Software Development Kits

The Services may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and Sagemath does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

The Services may include publicly accessible forums, blogs, and social media pages You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible forum, blog, or social media page may be viewed and used by others without any restrictions. By using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

We use Third-Party software development kits (“SDKs”), such as the Stripe, Inc. SDK, as part of the functionality of our Services.

3.5 Third-Party Payment Processing

When you make purchases through the Services, payments are processed by our payment processor, Stripe. Stripe collects information from and about you that is necessary to complete the transaction, comply with legal and tax obligations, and help prevent fraud and abuse. This may include your name, email address, billing address, tax identifiers, IP address, and payment information. We do not receive your full payment account numbers. We use Stripe for payment processing based on the need to complete transactions and our legitimate interests in preventing fraud and abuse. You can review Stripe's privacy policy on Stripe's website.

4 Human Resources Data

Sagemath collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy.

We Process Human Resources Data for a variety of business purposes, relying on the lawful basis appropriate for each use, such as performance of an employment or contractor relationship, legal obligations, legitimate interests, or consent where required by applicable law:

• Workflow management, including assigning, managing and administering projects;
• Human Resources administration and communication;
• Payroll and the provision of benefits;
• Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
• Job grading activities;
• Performance and employee development management;
• Organizational development and succession planning;
• Benefits and personnel administration;
• Absence management;
• Helpdesk and IT support services;
• Regulatory compliance;
• Internal and/or external or governmental compliance investigations;
• Internal or external audits;
• Litigation evaluation, prosecution, and defense;
• Restructuring and relocation;
• Emergency contacts and services;
• Employee safety;
• Compliance with statutory requirements;
• Processing of Employee expenses and travel charges; and
• Acquisitions, divestitures, and integrations.

5 Onward Transfer — Sagemath May Disclose Your Information

5.1 Information We Share

We may share your information as described in this Privacy Policy, relying on the lawful basis appropriate for the disclosure, such as performance of a contract, legitimate interests, legal obligations, consent where required by applicable law, or the same lawful basis that supports the underlying processing. Examples include sharing with our Third-Party service providers, protecting and defending our rights and property, or sharing with your permission.

• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT, marketing, and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services.
• Business Partners. Sagemath may share your Personal Information with our business partners and affiliates to provide you with a product or service that you have requested. Sagemath may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Sagemath. Sagemath requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Sagemath provided them.
• DPF. With respect to onward transfers to Agents under DPF, DPF requires that Sagemath remain liable should its Agents Process Personal Information in a manner inconsistent with the DPF Principles.
• Displaying to Other Users. The content you post to the Services may be displayed on the Services. Other users of the Services may be able to see some information about you, such as your name. We are not responsible for privacy practices of the other users who will view and use the posted information.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Sagemath policies or contracts; (v) to collect amounts owed to Sagemath; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

5.2 International Data Transfers

Information collected via or by Sagemath may be transferred, processed, and stored in the United States, in the cloud, on our servers, on the servers of our affiliates, or on the servers of our service providers, as necessary to provide the Services and subject to applicable legal requirements and transfer safeguards.

If you use Services that require you to select a geographic location explicitly, such as compute servers or cloud file systems, your data will be sent to the chosen location.

6 Opt-Out (Right to Object to Processing)

6.1 General

You have the right to object to and opt out of certain uses of your Personal Information. Where we rely on your consent to process Personal Information, or explicit consent to process Sensitive Personal Information, you may withdraw that consent at any time by contacting [email protected]. Withdrawing consent does not affect processing that occurred before withdrawal or processing that relies on another lawful basis or applicable legal permission.

6.2 Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Sagemath and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

6.3 Mobile devices

Sagemath may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Sagemath may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.

6.4 Human Resources Data

With regard to Personal Information that Sagemath receives in connection with the employment relationship, Sagemath will use such Personal Information only for employment-related purposes as more fully described above. If Sagemath intends to use this Personal Information for any other purpose, Sagemath will contact the Individual and proceed only after obtaining affirmative express consent (opt in).

6.5 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

7 Rights of Access, Rectification, Erasure, Restriction, and to Object

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal information; (v) seek correction of inaccurate, untrue or incomplete personal information; (vi) request erasure of personal information held about you by Sagemath, subject to certain exceptions prescribed by law; (vii) object to processing of your personal information; (viii) where applicable, exercise rights relating to decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you, including requesting human intervention where required by law. If your account is restricted or suspended due to automated security monitoring, you have the right to request human intervention and contest the decision by contacting us at [email protected]. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws and free of charge. However, if the request is excessive or repetitive, Sagemath may charge a reasonable fee. To protect your privacy, Sagemath will take steps to verify your identity before fulfilling your request.

8 Data Retention

Sagemath retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

When you delete your account, Sagemath removes your email address, name, password, profile picture, SSH keys, sign-in connections, settings and other personal data from your account record, and deletes any contact record about you in our sales and marketing system. We keep your former email address for 90 days to help with account recovery requests and to prevent abuse, and then delete it. Records that we must keep by law, such as purchase and tax records, are kept for as long as the law requires.

Records of which accounts viewed a public share are deleted 13 months after the view. Deleting your account also deletes these records (records about shares stored in another region of our service are deleted within those 13 months).

Records of changes to who can access a project are deleted 13 months after the change. These records are kept for 13 months even if an account is deleted, because they are needed to investigate security problems.

9 Security of Your Information

We implement appropriate technical and organizational measures designed to protect Personal Information against unauthorized access, loss, misuse, alteration, or disclosure. These measures include encryption for data storage and backups, firewalls, and access controls. You can learn more about our security controls, third-party audits, and certifications on our Trust page at https://cocalc.ai/policies/trust. Where automated or AI-based analysis is used for security monitoring, Sagemath configures these tools to ensure that user content is analyzed only for classification of abuse and is not used to train the underlying models of third-party providers. No method of transmission or storage over the Internet is completely secure, and we cannot guarantee absolute security. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a personal data breach, in accordance with GDPR we will inform the Supervisory Authority within 72 hours. If there is a high risk to your security or if required by the Supervisory Authority, we will notify you electronically by posting a notice on the Services or sending an e-mail to you.

10 Children’s Privacy

The Services are not directed to children under 16 years of age, and Sagemath does not knowingly collect Personal Information from children under 16 years of age. If we learn that we have collected any Personal Information from children under 16 years old, we will promptly take steps to delete such information.

11 Redress/Compliance and Accountability

If you have any questions about our privacy practices or this Privacy Policy, please contact Sagemath by email at [email protected]. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

If you are a EU resident, you may contact our Ireland Representative: Instant EU GDPR Representative Ltd, Adam Brogden, [email protected], Tel +353 15 549 700, https://sagemathinc.gdprlocal.com/eu, INSTANT EU GDPR REPRESENTATIVE LIMITED Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland

If you are a UK resident, you may contact our UK Representative: GDPRLocal Ltd, Adam Brogden, [email protected], Tel +441 772 217 800, https://sagemathinc.gdprlocal.com/uk, GDPRLocal Ltd. 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Sagemath commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Sagemath at the contact information provided above.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Sagemath commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.

You may also have a right, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms; for additional information, see www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction. The Federal Trade Commission has jurisdiction over Sagemath’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

12 Other Rights and Important Information

12.1 Changes To Our Privacy Policy and Practices

We may revise this Privacy Policy from time to time. When we do, we will post the updated Privacy Policy here and update the “Last Updated” date. If applicable law requires additional notice or consent for a change, we will provide it before the change applies.

12.2 California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Sagemath does not share Personal Information with Third Parties for their own marketing purposes.

12.3 Supervisory Authority

If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

12.4 Compliance

This Policy shall be implemented by Sagemath and all its operating divisions, subsidiaries and affiliates. Sagemath has put in place mechanisms to verify ongoing compliance with DPF Principles and this Policy. Any Employee that violates these privacy principles will be subject to disciplinary procedures.

13 Definitions

The following capitalized terms shall have the meanings herein as set forth below.

• “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Sagemath or to which Sagemath discloses Personal Information for use on its behalf.
• “Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Sagemath or its subsidiaries worldwide.
• “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
• “DPF Principles” means the seven (7) principles of the Data Privacy Framework: (1) notice, (2) choice, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability. Additionally, it includes the sixteen (16) supplemental principles described in the Data Privacy Framework: (1) sensitive data, (2) journalistic exceptions, (3) secondary liability, (4) performing due diligence and conducting audits, (5) the role of the data protection authorities, (6) self-certification, (7) verification, (8) access, (9) human resources data, (10) obligatory contracts for onward transfers, (11) dispute resolution and enforcement, (12) choice – timing of opt-out, (13) travel information, (14) pharmaceutical and medical products, (15) public record and publicly available information, and (16) access requests by public authorities.
• “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
• “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Sagemath or Sagemath’s Agents.

14 Revision history

A revision control history for this web page can be found at github.com/sagemathinc/cocalc-ai/commits/main/src/packages/frontend/public/policies/privacy.tsx.

Questions?

Please contact us at [email protected] if you have any questions about our Privacy Policy.

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