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      Software: Confluent Platform
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Last Updated September 27, 2021


CONFLUENT PRIVACY POLICY



Confluent, Inc. and its subsidiaries (“Confluent,” “we,” “our,” or “us”)
understand that privacy is important to visitors to our websites (our “Sites”)
and users of our products and services (our “Products”).  This Privacy Policy
("Policy") explains how we collect, use, and share your personal information,
and how you can exercise your privacy rights. 

If you are unable to access this Policy due to a disability or any physical or
mental impairment, please contact us using the contact details in the How to
Contact Us section and we will arrange to supply you with the information you
need in an alternative format that you can access. You can also access a
printable version of this Policy.

This Privacy Policy covers personal information we process:

(1) When you visit our Sites, and in the usual course of business, such as in
connection with our events, sales, and marketing activities (collectively,
"Visitors"); and

(2) When you register to or otherwise use Confluent Products whether as an
individual, as an applicant, team member, or employee of our customers
(collectively, "Users"). 

This Privacy Policy does not apply to Sites or Products that display or link to
different privacy policies.  This Policy also does not apply where Confluent
processes personal information of our customers on their behalf; our collection
and processing of such personal information is governed by our agreements with
those customers.

Quick Links

We recommend that you read this Policy in full to ensure you are fully informed.
However, to make it easier for you to review those parts of this Policy, which
apply to you, we have divided up the document into the following sections:

 1.  WHO WE ARE
 2.  PERSONAL INFORMATION WE COLLECT
 3.  OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES
 4.  OUR USE OF PERSONAL INFORMATION
 5.  SHARING OF PERSONAL INFORMATION 
 6.  YOUR CHOICES ABOUT PERSONAL INFORMATION
 7.  ADDITIONAL DISCLOSURES FOR CALIFORNIA CONSUMERS
 8.  HOW WE STORE AND PROTECT PERSONAL INFORMATION
 9.  CHANGES TO OUR PRIVACY POLICY
 10. HOW TO CONTACT US

 

1. WHO WE ARE

Confluent is a company headquartered in Mountain View, California. Confluent is
pioneering a fundamentally new category of data infrastructure focused on data
in motion. Confluent’s cloud-native offering is the foundational platform for
data in motion – designed to be the intelligent connective tissue enabling
real-time data, from multiple sources, to constantly stream across the
organization. With Confluent, organizations can create a central nervous system
to innovate and win in a digital-first world.  

2. PERSONAL INFORMATION WE COLLECT 

The information we collect depends on the context of your interactions with
Confluent and the choices you make (including your privacy settings), the
Products and features you use, your location, and applicable law.  

(i) Information You Provide to Us

WHEN YOU VISIT OUR SITES

Certain parts of our Sites may ask you to provide personal information
voluntarily. We collect and store personal information that you directly provide
us through our Site, through interactions on social media, participation in a
survey or promotion, application for a job, when downloading white papers on our
Sites, and at events.  We will collect certain personal information so that we
may fulfill your request or keep in touch in connection with our sales and
marketing activities (always in accordance with your marketing preferences).
Information we collect includes:

 * Contact information:  your name, email address, phone number, mailing
   address, billing address, and usernames;
 * Demographic data: your job title, company name, city, state, and country; 
 * Payment information: your credit card numbers and other payment information.
   Our third-party payment processors (like Stripe) collect this information if
   you purchase our Products, such as online training, cloud services, or
   software subscriptions; and
 * Content and communications: any data you enter into any ‘free text’ boxes on
   our forms; comments in our chat forms, and communications with us on social
   media and other platforms (like GitHub and Twitter), through phone, or
   messaging services (like Slack).

WHEN YOU USE OUR PRODUCTS

If you are a User, you or your employer, may provide certain personal
information to us through the use of Confluent Products - for example, when you
register for a Confluent account to access and use our Products, when you
consult with customer support, or send us an email or communicate with us in any
way. Personal information we collect may include: 

 * Business contact information: such as your name, job title, organization,
   phone number, email address and country.
 * Marketing information: such as your contact preferences. 
 * Account log-in credentials: such as your email or username and password when
   you sign up for an account with us and the unique User/ team ID assigned to
   you in our systems.
 * Troubleshooting and support data: such as personal information you provide or
   we otherwise access in connection with support queries we receive from Users.
   This may include, for example, contact or authentication data, the content of
   your chats and other communications with Confluent, and the product or
   service you are using related to your help inquiry.

(ii) Information We Collect Automatically. 

WHEN YOU VISIT OUR SITES

When you visit our Sites or interact with our emails, we gather certain
technical information from your browser or device automatically and store it in
log files.  In some (but not all) countries, including countries in the European
Economic Area ("EEA"), UK and Switzerland, this information is considered
personal information under data protection laws. To the extent that this
automatically collected data includes, or is linked to, personal information, we
will treat the data in accordance with this Privacy Policy.  

This information we collect includes:

 * Geolocation data: Such as your geolocation data when you visit our Sites and
   use our Products. For example, we may derive your general location using IP
   address.
 * Identifiers and device information. Such as your device’s operating system,
   device identifier, customer ID and other device information, user agent
   string, Internet Protocol (IP) address, access times, browser type, and log
   data detailing your interactions with our Site (e.g., number of clicks, pages
   viewed, information searched for), and the website you visited before and
   after coming to our Site (i.e., referrer header) are logged automatically. 
   When you submit a support ticket, we receive data from the user agent string
   of your browser, which includes device information, browser information, OS
   information, city, state, country, and IP address.
 * Information collected through social media and other platforms.  We receive
   information about you when you engage with us through various third-party
   platforms, for example, by joining our Slack community or Google group,
   liking us on Facebook, connecting on LinkedIn, GitHub, or Meetup, following
   us on Twitter or Instagram, registering for training through Content Raven,
   or sharing content from our Site on Facebook, Twitter, or LinkedIn.  The data
   we exchange with these third-party platforms may depend upon your privacy
   settings with these platforms.  You should review and consider adjusting your
   privacy settings on third-party websites and services before engaging.  Do
   not provide us with any sensitive personal data through these platforms.  We
   are not responsible for the data protection and use practices of these
   third-party platforms.  Please see their privacy policies to learn how they
   use your information.  

For more information please see the “Our Use of Cookies and Other Technologies”
and “Product telemetry data” sections below.

WHEN YOU USE OUR PRODUCTS

When you use our Products, we collect certain technical information from your
browser or device automatically. This information includes: 

 * Geolocation data: Depending on your device settings, we collect geolocation
   data when you use our Products. For example, we may derive your general
   location using IP address.
 * Product telemetry data:  Such as telemetry data and other data about your
   usage, including your IP Address and other unique identifiers in combination
   with information about the version of our software you are running and how it
   is configured, to collect and aggregate certain diagnostic and analytics
   information.  We may combine this information with information you provide
   when you download our Products or provide to customer support, including the
   name of your organization or company.  You can turn off the collection of
   telemetry data as described in the “Choices” section below and as described
   further in the applicable product documentation including the More
   Information page. 
 * Inferences. We infer new information about you and your company from data we
   collect, including using automated means to generate information about your
   likely preferences, your service and product needs or other characteristics.
   For example, we infer your city, state, and country location based on your IP
   address.
 * Information collected through social media and other platforms.  We receive
   information about you when you engage with us through various third-party
   platforms, for example, by joining our Slack community or Google group,
   liking us on Facebook, connecting on LinkedIn, GitHub, or Meetup, following
   us on Twitter or Instagram, registering for training through Content Raven,
   or sharing content from our Site on Facebook, Twitter, or LinkedIn.  The data
   we exchange with these third-party platforms may depend upon your privacy
   settings with these platforms.  You should review and consider adjusting your
   privacy settings on third-party websites and services before engaging.  Do
   not provide us with any sensitive personal data through these platforms.  We
   are not responsible for the data protection and use practices of these
   third-party platforms.  Please see their privacy policies to learn how they
   use your information.

(iii) Information We Collect from Third-party Sources.  

We may occasionally receive your personal information from third party sources
including our affiliates, marketing and research partners, and companies such as
DiscoverOrg (contact database), Hootsuite (social media management platform),
Kickfire (company database), and LinkedIn.  

Users of our Products may also provide your personal information when they
identify you as a billing, support, or technical contact, or when inviting you
to use our Products or attend our events.  If you integrate or link a
third-party service with our Sites or Products, we may receive personal
information about you from that third-party service based upon the settings and
permissions you've established with such third party service, and that third
party service's privacy practices.

The types of information we collect from third parties may include contact
information, demographic data, and content and communications.  We use this
information to maintain and improve the accuracy of the records we hold about
you, identify new customers, and provide a more tailored advertising
experience.  We may combine this information with other information we collect
about you through our Sites and Products. 

When you are asked to provide personal information, you may decline.  But if you
choose not to provide information that is necessary to provide certain Products,
those Products may not be available or function correctly.

Finally, you have the option to create a Confluent Cloud account and log into
such account using Google sign-in services. Google sign-in services will
authenticate your identity and provide you with the option to share with us
certain information, such as your full name, nickname, e-mail address and
picture. Confluent receives this data from Google as part of the creation,
authentication and authorization framework in connection to your Confluent Cloud
account.

3. OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our Sites and related online services use cookies and similar technologies to
enable certain functionality and help collect information about your visit. We
use the following technologies, over which you have certain options:

“Cookies” are small text files, typically containing a unique string of letters
and numbers, stored on your hard drive by a Site.  When you return to the Site
using the same browser, the Site can read the cookie and thereby gather
information about your usage over time.  Among other things, we use cookies and
other technology to see which areas and features are popular and to count
visits, which helps us to improve our Site, our Products, and your experience.
Most Web browsers are set to accept cookies by default.  If you prefer, you can
usually set your browser to remove cookies and to reject cookies.  If you choose
to remove reject cookies, this could affect certain features or services of our
Site or other Products.  For specific opt out links and to manage your
preferences in relation to first and third party cookies please see our Cookie
Notice at https://www.confluent.io/cookies/.

Web Beacons.  We may collect information using Web beacons. Web beacons are
electronic images that may be used on our Site, Products, or in our emails.  We
use Web beacons to deliver cookies, count visits, understand usage and campaign
effectiveness, and to tell if an email has been opened and acted upon. 

Google Analytics: We use cookies served by Google Analytics to collect limited
data directly from your browser to enable us to better understand your use of
the Sites and Services, including making use of the demographics and interests
reports services of Google Analytics. Further information on how Google collects
and uses this data can be found at www.google.com/policies/privacy/partners/.
You can opt-out of all Google supported analytics within the Services by
visiting https://tools.google.com/dlpage/gaoptout.

Analytics and Advertising.  We work with third parties to provide analytics and
advertising services in connection with our Sites and Products.  These third
parties use cookies, web beacons, or similar technologies to automatically
collect some of the information described above from visitors of our Sites and
Products over time and across third party Web sites and mobile applications for
purposes of analytics and advertising.  We use the analytics information to
analyze and improve our services.  Our advertising partners use the information
to try to understand your interests and show you relevant advertising about
products and services from and on behalf of us and others.   Our third-party
analytics and advertising partners may provide you with options to opt-out of
certain information collection. For additional information about online
interest-based advertising, our use of cookies and other similar tracking
technologies, and how to opt-out of having your information used for these
purposes by many of these third-parties, please see our Cookie Notice at
https://www.confluent.io/cookies/.

Telemetry data.  If you prefer that we do not collect certain telemetry data,
including IP Address, through KSQLDB or Health+, you can turn off the collection
of this data as detailed in our More Information page. Please note that if you
initiate a support request, you may be required to provide us with certain log
information or other data about your systems, servers, and clients to allow us
to provide such support services.

Do Not Track.  There are many ways through which web browser signals and other
similar mechanisms (for example, “Do Not Track”) can indicate your choice to
disable tracking, and, while we and others give you choices described in this
Privacy Policy, we do not currently honor these mechanisms. 

4. OUR USE OF PERSONAL INFORMATION

Confluent processes personal information for the following business purposes,
and if you are a resident in the EEA or UK, on the legal basis identified below:

 * Providing our websites and Confluent Products: In reliance on our legitimate
   interest, we process your personal information to operate and administer our
   websites, and to provide, operate, and maintain the Confluent Products;
 * Communicating with you about the Confluent Products: We may send you service,
   technical and other administrative or technical email, messages and other
   types of notifications(such as distribution and product updates and product
   patches and fixes) in reliance on our legitimate interests in administering
   the Confluent Products and providing certain features. These communications
   are considered part of the Confluent Products and in most cases you cannot
   opt-out of them.  If an opt-out is available, you will find that option
   within the communication itself; 
 * Providing necessary functionality: We process your personal information in
   reliance on our legitimate interest to provide you with the necessary
   functionality required during your use of our websites and Confluent
   Products;
 * Transactional considerations: We process your personal information to
   complete transactions, and send you related information, including purchase
   confirmations and invoices, to perform our contract with you and to the
   extent necessary in reliance on our legitimate interest;
 * Handling contact and support requests: If you fill out a “Contact Us” web
   form or request support as a User, or if you contact us by other means
   including via a phone call, we process your personal information to perform
   our contract with you and/or (if we have not entered into a contract with
   you) to the extent it is necessary for our legitimate interest in fulfilling
   your requests and communicating with you;
 * Administering Events: We process your personal information to plan and host
   events or webinars for which you have registered or that you attend,
   including sending related communications to you, billing, registration and to
   connect you with other event attendees, to perform of our contract with you,
   or to the extent necessary for our legitimate interests in fulfilling your
   requests to attend any such events;
 * Developing and improving our websites and services: We process your personal
   information to analyze trends and to track your usage of and interactions
   with our websites to the extent it is necessary for our legitimate interest
   in developing, improving and troubleshooting our websites, marketing
   activities and the Confluent Products and providing you with more relevant
   content and service offerings, or where necessary, in reliance on your
   consent;
 * Sending marketing communications: We will process your personal information
   for marketing purposes in accordance with your preferences, such as to
   communicate with you via email, SMS or telephone about services, features,
   surveys, newsletters, promotions or events we think may be of interest to you
   and/or to provide other news or information about Confluent and/or our select
   partners, in each case in reliance on our legitimate interest in conducting
   direct marketing or where necessary with your consent. Please see the "Your
   Privacy Rights" section below, to learn how you can control the processing of
   your personal information by Confluent for marketing purposes;
 * Displaying personalized advertisements and content: We process your personal
   information to conduct marketing research, advertise to you, provide
   personalized information about us on and off our websites and to provide
   other personalized content based upon your activities and interests to the
   extent it is necessary for our legitimate interest in supporting our
   marketing activities or advertising the Confluent Products or, where
   necessary, to the extent you have provided your prior consent (please see the
   "Your Privacy Rights" section, below, to learn how you can control how the
   processing of your personal information for personalized advertising
   purposes);
 * Promoting the security of our websites and services: To the extent necessary
   for our legitimate interests in promoting the safety and security of our
   websites and services, we use your personal information to investigate and
   prevent fraudulent transactions, unauthorized access to the websites,
   Confluent Products, and other illegal activities;
 * For our business purposes, such as data analysis, audits, fraud monitoring
   and prevention, developing new products and features, enhancing, improving or
   modifying our products and services, identifying usage trends and expanding
   our business activities in reliance on our legitimate interests;
 * Complying with legal obligations: We process your personal information when
   cooperating with public and government authorities, courts or regulators in
   accordance with our legal obligations under applicable laws to the extent
   this requires the processing or disclosure of personal information to protect
   our rights or is necessary for our legitimate interest in protecting against
   misuse or abuse of our websites, the Confluent Products, protecting personal
   property or safety, pursuing remedies available to us and limiting our
   damages, complying with judicial proceedings, court orders or legal processes
   or to respond to lawful requests. As a U.S. company, Confluent is prohibited
   under U.S. laws and regulations from engaging in business, directly or
   indirectly, with certain countries and persons designated by the U.S.
   government. To comply with such laws and regulations, including for purposes
   of compliance with the Office of Foreign Assets Control guidelines and
   sanctions program, Confluent may request additional personal information and
   process such additional personal information for purposes of compliance with
   a legal obligation to which Confluent is subject.
 * Reviewing compliance with applicable usage terms: We process your personal
   information to review compliance with our contract with you or your
   organization (where applicable) to the extent that it is in our legitimate
   interest to ensure adherence to the relevant terms; and
 * Other purposes: We will process your personal information for other purposes
   about which we notify you in advance, or for which we receive your consent.
   In general, we collect and process personal information about you, as
   necessary to provide the Products you use, operate our Sites and business,
   meet our contractual and legal obligations, protect the security of our
   systems and our customers, or fulfill other legitimate interests as described
   in this Privacy Policy and in our notices to you.
   


5. SHARING OF PERSONAL INFORMATION

We may share or disclose your personal information to the following categories
of recipients: 

 * Among our affiliates. We may share your personal information with our
   affiliates, which include companies owned by or under common ownership of
   Confluent such as Confluent Europe Ltd., Confluent Germany GmbH, Confluent
   Singapore Pte. Ltd., Confluent Australia Pty Limited, Confluent India Private
   Limited, Confluent France SAS, Infinitem Canada Ltd, Confluent Sweden AB,
   Confluent Hong Kong Ltd., Confluent Israel Ltd., Confluent Japan Godo Kaisha,
   Confluent Malaysia Sdn. Bhd., Confluent Korea Limited, Confluent Spain,
   Sociedad Limitada, Confluent ME FZ-LLC and Confluent Federal, LLC, all of
   which will be required to use your personal information as described in this
   Privacy Policy. 
 * Partners and other similar parties. We may share your personal information
   with our sponsors and co-sponsors of events, whose information we believe may
   be relevant to you. We may also share your personal information with research
   and advisory firms whose reports are offered through our Sites (subject to
   applicable laws).
 * Third-party vendors and other service providers. We may share your personal
   information with our third-party vendors and service providers that we use to
   provide services such as payment processing, reselling services, support
   ticket portals, secure transfer software, cloud hosting, video conference
   services, venues, marketing automation platforms, project management tools,
   registration services, learning management services, collaboration and
   communication tools (including surveys), data backup services, and
   professional services.
 * Business transfers. We may share your personal information with other parties
   in connection with a company transaction, such as a merger, sale of company
   assets or shares, reorganization, financing, change of control or acquisition
   of all or a portion of our business or assets by another company or third
   party, or in the event of a bankruptcy, dissolution, or related or similar
   proceedings.
 * Compliance with laws. We may share your personal information as required by
   law or subpoena or if we reasonably believe that such action is necessary to
   comply with the law or the reasonable requests of law enforcement.
 * Legal rights. We may share your personal information to enforce our Terms of
   Use or other agreements, to protect the security or integrity of our Sites
   and Products, or to exercise or protect the rights, property, or personal
   safety of Confluent, our customers, users, or others.
 * Advertising partners. We may partner with third party advertising networks,
   exchanges and social media platforms to display advertising on our websites
   or to manage and service advertising on other sites and we may share personal
   information with them for this purpose. Please see the section above "Our Use
   of Cookies and Similar Tracking Technologies" for further information.

6. YOUR CHOICES ABOUT PERSONAL INFORMATION

Depending on your location, your jurisdiction, and subject to applicable law,
you may have the rights below with regard to the personal information we control
about you. We will respond to your requests within the appropriate timeline
under applicable law.

Communications preferences.  You can stop receiving promotional emails from us
by clicking on the “unsubscribe link” provided in such emails or by contacting
us at the contact details set forth below.  In addition, you can make changes to
your preferences in our Preference Center at
https://www.confluent.io/email-preferences/.  We make every effort to promptly
process all unsubscribe requests.  If you opt out, we may still send you
transactional communications (e.g., non-promotional emails such as emails about
training and events you registered to attend and technical or security notices).

 

Privacy Rights (EEA residents & California Consumers). EEA residents and
California consumers are afforded certain privacy rights by relevant privacy
laws, such as the General Data Protection Regulation ("GDPR") and the California
Consumer Privacy Act ("CCPA"), respectively. Please see below for applicable
rights under each legal regime. 

 

European Data Protection Rights (EEA Residents) 

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

 * You may request access to, and correction or erasure of, your personal
   information at anytime. 
 * You can object to processing of your personal information, ask us to restrict
   processing of your personal information or request portability of your
   personal information. 
 * If the processing of personal information is based on your consent, you have
   a right to withdraw consent at any time for future processing. Withdrawing
   your consent will not affect the lawfulness of any processing we conducted
   prior to your withdrawal, nor will it affect processing of your personal
   information conducted in reliance on lawful processing grounds other than
   consent.
 * You have the right to complain to a data protection authority about our
   collection and use of your personal information but we encourage you to first
   contact us with any questions or concerns. For more information, please
   contact your local data protection authority. Contact details for data
   protection authorities in the European Economic Area (“EEA“) are available at
   https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
 * Confluent does not engage in any automated decision making with User personal
   information.

You may exercise the rights above by using this form or by e-mailing us at
privacy@confluent.io. 

California Privacy Rights (California Consumers) 

The California Consumer Privacy Act (“CCPA”), provides California residents with
the following rights: 

 * You may request access to, or for a copy of the personal information we have
   collected, used, disclosed, and sold about you over the past twelve (12)
   months. Please see the section below "Additional Disclosures for California
   Consumers" for more information on our general practices. 
 * You may also request that we delete certain personal information we have
   collected from you. 
 * You have a right not to receive discriminatory treatment for the exercise of
   your CCPA privacy rights.
 * You may also have the right to opt out of the sale of your personal
   information. In consideration of the right, Confluent does not sell
   information as the terms “sale” or “sell” are traditionally understood (i.e.
   for money). However, making a California resident’s personal information
   (including IP addresses, cookies IDs, and mobile IDs) available to third
   parties as described above may broadly be considered a “sale” under the CCPA,
   given its broad definition of "sale." The definition is so broad it could
   include the sharing of personal information with third parties in exchange
   for something of value, even if no money changes hands.  As discussed in this
   Privacy Policy, our advertising and analytics providers may collect your IP
   address, cookie ID, and mobile ID when you use our websites, and such vendors
   may further share your information to provide similar advertising or
   analytics services to their other customers. You can request to opt out of
   such “sale” of your Personal Information by visiting our Cookie Notice and
   following its instructions.

If you are a California resident seeking to exercise your CCPA rights, or if you
are an authorized agent wishing to exercise CCPA rights on behalf of someone
else, please use this form or e-mail us at privacy@confluent.io. 

Please note that to protect your personal information, we will verify your
identity by a method appropriate to the type of request you are making. We may
also request that your authorized agent have written permission from you to make
requests on your behalf, and we may also need to verify your authorized agent's
identity to protect your personal information.

7. ADDITIONAL DISCLOSURES FOR CALIFORNIA CONSUMERS

California law requires us to provide California consumers with some additional
information regarding how we collect, use, and share your "personal information"
(as defined in the CCPA). Throughout this Policy, we discuss in detail the
specific pieces of information we collect from you or your device and discuss
how we use and share such information. 

As described in detail in section 2 above we may collect the following
categories of information about you through the Confluent Product or when you
visit our sites: 

 * Identifiers, such as name and contact information; 
 * Device identifiers, such as IP address;
 * Internet or other network or device activity, such as browsing history or app
   usage; 
 * Geolocation information; and other information that identifies or can be
   reasonably associated with your device;
 * Commercial information, such as transaction data; 
 * Professional or other employment related information, such as where you work
   and your title; and
 * Financial information, such as credit card and payment data.

The sources from which we collect personal information are described in Section
2 ("Personal Information We Collect") of this Privacy Policy The business and
commercial purposes for which we collect this information are described in
section 4 ("Our Use of Personal Information") of this Privacy Policy. The
categories of third parties to whom we "disclose" this information for a
business purpose are described in section 5 ("Sharing of Personal Information")
of this Privacy Policy.

The CCPA defines ‘sale’ very broadly. It includes the sharing of California
Information in exchange for anything of value. According to this broad
definition, in the year before this section was last updated, we may have sold
the following categories of personal information to third parties: identifiers
(like your IP Address) and other electronic network activity (such as browsing
history). We may have sold these categories of personal information to the third
parties listed in section 5 ("Sharing of Personal Information") of this Privacy
Policy.

8. HOW WE STORE AND PROTECT PERSONAL INFORMATION

Storage and processing.  Your information collected through the Sites and our
Products may be stored and processed in any country in which Confluent or its
subsidiaries, affiliates, or service providers maintain facilities including
your region, the United States, United Kingdom, European Economic Area, Canada,
Singapore, India, Hong Kong, Israel, Japan, Malaysia, Singapore, South Korea,
United Arab Emirates, Australia, amongst others. Our processing locations are
chosen in order to operate efficiently, to improve performance, and to create
redundancies in order to protect the data in the event of an outage or other
problem. We take steps designed to ensure that the data we collect under this
Privacy Policy is processed according to the provisions of this Privacy Policy
and applicable law wherever the data is located. 

International data transfers.  When we transfer personal information from the
European Economic Area, the United Kingdom, or from Switzerland to the United
States or other countries which have not been determined by the European
Commission to have laws that provide an adequate level of data protection, we
use legal mechanisms, including contracts, designed to help ensure your rights
and protections. Specifically, our website servers are located in the United
States and our affiliates, partners, third parties and service providers operate
in the United States, United Kingdom, European Economic Area, Canada, Singapore,
India, Hong Kong, Israel, Japan, Malaysia, Singapore, South Korea, United Arab
Emirates, Australia, amongst others. This means when we collect your personal
information, we may process it in any of these countries. However, we have taken
appropriate safeguards to require that your personal information will remain
protected in accordance with this Privacy Policy. The safeguard Confluent
primarily relies upon is the European Commission-approved standard contractual
clauses. For more information about these mechanisms, please contact us using
the contact details provided in the “How to Contact Us” section below.

Keeping your information safe.  Confluent cares about the security of your
information and takes reasonable and appropriate technical and organizational
measures designed to prevent loss, misuse, and unauthorized access, disclosure,
alteration, and destruction of personal information.  However, no security
system is impenetrable, and we cannot guarantee the security of our systems or
your information. For this reason, you should be mindful of the information you
provide to us. 

Lawful basis for processing personal information (EEA only).  If you are located
in the European Economic Area (EEA), Confluent, Inc., is as a rule the data
controller of your information. For more details on the legal bases used for the
processing of your personal information, please see section 4 "Our Use of
Personal Information". 

Our legal basis for collecting and using the personal information above will
depend on the personal information concerned and the specific context in which
we collect it.  However, we will normally collect personal information only
where we have your consent to do so, where we need the personal information to
perform a contract with you, or where the processing is in our legitimate
interests and not overridden by your data protection interests or fundamental
rights and freedoms.  In some cases, we may also have a legal obligation to
collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement
or to perform a contract with you, we will indicate this at the relevant time
and advise you whether the provision of your personal information is mandatory
or not (as well as the possible consequences, if any, if you do not provide your
personal information).  Similarly, if we collect and use your personal
information in reliance on our legitimate interests (or those of a third party),
we will indicate to you at the relevant time what those legitimate interests
are. 

If you have questions about the legal basis for processing or want to find out
more, please contact us using the details at the end of this Privacy Policy in
the section "How to Contact Us". 

Retention.  We retain personal information for as long as we have an ongoing
legitimate business need to do so.  For example, we retain your account
information for as long as your account is active or as needed to provide you
with Products you have requested or authorized, including maintaining and
improving the performance of the Products and protecting system security.  We
also retain personal data as needed to maintain appropriate business and
financial records, protect our legal interests, resolve disputes, or comply with
legal or regulatory requirements.  When we have no ongoing legitimate business
need to process your personal information, we will either delete or anonymize
it, or if this is not possible (for example, because your personal information
has been stored in backup archives), then we will store your personal
information using appropriate security measures and take appropriate steps
designed to isolate it from any further processing until deletion is possible. 

9. CHANGES TO OUR PRIVACY POLICY

Confluent may modify or update this Privacy Policy from time to time to reflect
the changes in our business and practices. Please review this page
periodically.  If we make any changes to this Privacy Policy, we will notify you
by changing the "Last Updated" date above.  If we make any material changes, we
will provide you with additional notice or obtain consent as may be required by
applicable law.

10. HOW TO CONTACT US

If you have any questions, complaints, or concerns about how your information is
handled, please email us at privacy@confluent.io.  Our main address is 899 West
Evelyn, Mountain View, CA 94041, USA.  Our EU representative’s contact
information is Confluent Germany GmbH c/o Osborne Clarke, Innere Kanalstraße 15,
D-50823 Cologne, Germany and may also be reached at privacy@confluent.io. Our
United Kingdom representative’s contact information is Confluent Europe Ltd. -
EMEA, 1 Bedford Street London WC2E 9HG and may also be reached at
privacy@confluent.io.  

If you would like to exercise any of your rights for yourself or on behalf of
someone else, please use this form or e-mail us at privacy@confluent.io.

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