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Google Cloud Privacy Notice

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Last modified: December 07, 2020

This is not the current version of this document and is provided for archival purposes.
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This Privacy Notice describes how we collect and process your personal information in
relation to Google Workspace and
Google Cloud Platform (together, “Cloud Services”).

We offer Cloud Services either directly or via our authorized partners. Where we refer to
our customers in this notice, we also mean our partners and their customers.

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#### Information We Collect

Google processes Customer Data, Partner Data and Service Data in order to provide Cloud
Services. This Privacy Notice applies solely to Service Data and
**does not** apply to Customer Data or Partner Data.

Customer Data and Partner Data are defined in our agreement(s) covering Cloud Services
and represent the data that you and our customers provide for processing in Cloud
Services. For more information about how we process Customer Data and Partner Data, see
our
Google Workspace Data Processing Amendment,

Google Cloud Platform Data Processing and Security Terms (Customers) and

Google Cloud Platform Data Processing and Security Terms (Partners).

Service Data is the personal information Google collects or generates during the
provision and administration of the Cloud Services, excluding any Customer Data and
Partner Data. Service Data includes:

**Cloud payments and transactions.** We keep reasonable business records
of charges, payments, and billing details and issues.

**Cloud settings and configurations.** We record your configuration and
settings, including resource identifiers and attributes. This includes service and
security settings for data and other resources.

**Technical and operational details of your usage of Cloud Services.** We
collect information about usage, operational status, software errors and crash
reports, authentication credentials, quality and performance metrics, and other
technical details necessary for us to operate and maintain Cloud Services and related
software. This information may include device identifiers, identifiers from cookies
or tokens, and IP addresses.

**Your direct communications.** We keep records of your communications
and interactions with us and our partners, for example, when you provide feedback or
contact information, ask questions or seek technical support.

#### Why We Process Data

Google processes Service Data for the following purposes:

**Provide Cloud Services you request.** Service Data is primarily used to
deliver the Cloud Services that you and our customers request. This includes a number
of processing activities that are necessary to provide the Cloud Services, including
processing to bill for services usage, to ensure services are working as intended, to
detect and avoid outages or other problems you might experience, and to secure your
data and the services you use.

**Make recommendations to optimize use of Cloud Services.** We may
process Service Data to provide you and our customers with recommendations and tips.
These suggestions may include ways to better secure your account or data, options to
reduce service charges or improve performance, and information about new or related
products and features. We may also evaluate your response to our recommendations.

**Maintain and improve Cloud Services.** We evaluate Service Data to help
us improve the performance and functionality of Cloud Services. As we optimize Cloud
Services for you, this may improve them for our customers and vice versa.

**Provide and improve other services you request.** We may use Service
Data to deliver and improve other services that you and our customers request,
including Google or third-party services that are enabled via the Cloud Services,
administrative consoles, APIs, or the Google Cloud Platform Marketplace or Google
Workspace Marketplace.

**Assist you.** We use Service Data when needed to provide technical
support and professional services as requested by you and our customers, and to assess
whether we have met your needs. We also use Service Data to improve our online
support, and to communicate with you and our customers. This includes notifications
about updates to Cloud Services, and responding to support requests.

**Protect you, our users, the public, and Google.** We use Service Data
to improve the safety and reliability of our services. This includes detecting,
preventing, and responding to fraud, abuse, security risks, and technical issues that
could harm our users, our customers, the public, or Google. These activities are an
important part of our commitment to secure our services.

**Comply with legal obligations.** We may need to process Service Data to
comply with our legal obligations, for example, where we’re responding to legal
process or an enforceable governmental request, or to meet our financial
record-keeping obligations.

**Other purposes with your consent.** We may ask for your consent to
process information for other purposes not covered in this Privacy Notice. You have
the right to withdraw your consent at any time.

To achieve these purposes, we may use Service Data together with information we collect
from other Google products and services. We may use algorithms to recognize patterns in
Service Data. Manual collection and review of Service Data may also occur, such as when
you interact directly with our billing or support teams. We may aggregate and anonymize
Service Data to eliminate personal details, including for internal reporting and
analysis of product and business operations described above.

#### Where Data Is Stored

We maintain data centers around the world, and provide Google Workspace from

these locations
and Google Cloud Platform from these locations.
Service Data may be processed on servers located outside of the country where our users
and customers are located because Service Data is typically processed by centralized or
regionalized operations like billing, support, and security.

Regardless of where Service Data is processed, we apply the same protections described
in this Privacy Notice. When transferring Service Data outside of the European Economic
Area, we comply with certain

legal frameworks.

#### How We Secure Data

We build Cloud Services with strong security features to protect information. The
insights we gain from providing our services help us detect and automatically block
security threats from ever reaching you.

We work hard to protect you and Google from unauthorized access, alteration, disclosure,
or destruction of information we hold, including:

We encrypt Service Data at rest and while in transit between our facilities.

We regularly review our information collection, storage, and processing practices,
including physical security measures, to prevent unauthorized access to our systems.

We restrict access to personal information to Google employees, contractors, and
agents who need that information in order to process it for us. Anyone with this
access is subject to strict contractual confidentiality obligations and may be
disciplined or terminated if they fail to meet these obligations.

#### How We Share Data

We do not share Service Data with companies, organizations, or individuals outside of
Google except in the following cases:

With your consent

We’ll share Service Data outside of Google when we have your consent. For example,
when you or our customer chooses to procure a third-party service through the Google
Cloud Platform Marketplace or Google Workspace Marketplace, or use a third-party
application that requests access to your information, we’ll seek permission to share
information with that third party.

With your administrators and authorized resellers

When you use Cloud Services, your administrator and resellers authorized to manage
your or your organization’s account will have access to certain Service Data. For
example, they may be able to:

- View account and billing information, activity and statistics

- Change your account password

- Suspend or terminate your account access

Access your account information in order to satisfy applicable law, regulation,
legal process, or enforceable governmental request

Restrict your ability to delete or edit your information or your privacy settings

- For external processing

We provide information to our affiliates, partners and other trusted businesses or
persons to process it for us, based on our instructions and in compliance with this
Privacy Notice and other appropriate confidentiality and security measures.

- For legal reasons

We may share Service Data outside of Google if we have a good-faith belief that access
to, or use, preservation, or disclosure of the information is reasonably necessary to:

Comply with applicable law, regulation, legal process, or enforceable governmental
request. We share information about the number and type of requests we receive from
governments in our
Transparency Report.

Enforce applicable agreements, including investigation of potential violations.

Detect, prevent, or otherwise address fraud, security, or technical issues.

Protect against harm to the rights, property or safety of Google, our customers,
users, and the public as required or permitted by law.

If Google is involved in a reorganization, merger, acquisition, or sale of assets,
we’ll continue to ensure the confidentiality of your personal information and give
affected users notice before personal information becomes subject to a different
privacy policy.

#### Access to Data

Your organization may allow you to access and export your data in order to back it up or
transfer it to a service outside of Google. Some Google Cloud Services enable you to
directly access and download the data you have stored in the services. For example,
as further described in our
Google Workspace Data Subject Requests Guide, you or
your organization may use various tools to access, control, and export data.

You and your organization’s administrator can access several categories of Service Data
directly from Google Cloud, including your billing contact information, payment and
transaction information, as well as product and communication settings and
configurations.

If you’re otherwise unable to access your data, you can always request it
here.

#### Deletion and Retention of Data

We retain Service Data for different periods of time depending on what it is, how we use
it, and how you configure your settings.

Service Data is deleted or anonymized once it is no longer needed. For each type of data
and operation, we set retention timeframes based on the purpose for its collection, and
ensure it is kept for no longer than necessary.

Sometimes we need to retain certain information for an extended period of time for
legitimate business or legal purposes. For example, when Google processes a payment for
you, or when you make a payment to Google, we’ll retain data about those transactions as
required for tax or accounting purposes. Other legitimate business or legal purposes
that may require us to retain data include security, fraud and abuse prevention,
ensuring continuity of our services, and complying with legal or regulatory
requirements.

When we delete data, we follow detailed steps to make sure that the data is securely and
completely removed from our active systems or retained only in anonymized form. We take
measures to ensure that our services protect information from accidental or malicious
deletion through the use of backup systems.

#### Using Google Accounts and Products

Your Google Account is your connection to all Google products and services, not just
Cloud Services. When you choose to use Google products and services outside of Cloud
Services, the
Google Privacy Policy
describes how data (including your Google Account profile information) is collected and
used. You and your administrator can control which other Google services you may use
while logged into a Google Account managed by your organization.

If you interact with Cloud Services using a Google Account managed by an organization,
then your personal information may be subject to your organization’s privacy policies
and processes, and you should direct privacy inquiries to your organization.

#### Updates to this Notice

We may update this Privacy Notice from time to time. We will not make any significant
changes without notifying you in advance by posting a prominent notice on this page
describing the changes or by sending you a direct communication. We encourage you to
regularly review this Privacy Notice, and we will always indicate the date the last
changes were published.

#### EU Privacy Standards and GDPR

If European Union (EU), UK or Swiss data protection law applies to the processing of
information about you, you have certain rights, including the rights to access, correct,
delete and export your information, as well as to object to or request that we restrict
processing of your information.

For users based in the European Economic Area, UK or Switzerland, the data controller
responsible for Service Data is Google Ireland Limited. However, where our customer has
entered into an agreement covering Cloud Services with a different Google affiliate,
that affiliate will be the data controller responsible for processing Service Data
in connection with billing for the Cloud Services only.

If you want to exercise your data protection rights with regard to information we
process in accordance with this Privacy Notice and are not able to do so via the tools
available to you or your organization’s administrator, you can always contact Google
via our
Privacy Help Center. And you can contact your local data
protection authority if you have concerns regarding your rights under local law.

In addition to the purposes and grounds described in this Privacy Notice, we may process
information on the following legal grounds:

Where necessary for the performance of a contract with you

We may process your information where necessary for us to enter into a contract with
you or to comply with our contractual commitments to you.

When we’re complying with legal obligations

We’ll process your information when we have a legal obligation to do so.

When we’re pursuing legitimate interests

We may process Service Data based on our legitimate interests and those of third
parties while applying appropriate safeguards that protect your privacy. This means
that we process your information in the interests of providing Cloud Services you
request;
making recommendations to optimize use of Cloud Services; maintaining and improving
Cloud Services; providing and improving other services you request; assisting you;
and protecting against harm to the rights, property or safety of Google, our users,
our customers, and the public, as required or permitted by law.

#### Brazil Requirements

If Brazilian data protection law applies to the processing of information about you, you
have certain rights, including the rights to access, correct, delete or export your
information, as well as to object to or request that we restrict processing of your
information. You also have the right to object to the processing of your information or
to export your information to another service.

For users based in Brazil, the data controller responsible for Service Data we collect
for Google Workspace is Google LLC, and the data
controller responsible for Service
Data we collect for Google Cloud Platform is Cloud Brasil Computação e Serviços
de Dados Ltda. If you want to exercise your data protection rights with regard to
information we process in accordance with this Privacy Notice and are not able to do
so via the tools available to you or your organization’s administrator, you can always
contact Google via our
Privacy Help Center. And you can contact your data protection
authority if you have concerns regarding your rights under Brazilian law.

In addition to the purposes and grounds described in this Privacy Notice, we may process
information on the following legal grounds:

Where necessary for the performance of a contract with you

We may process your information where necessary for us to enter into a contract
with you or to comply with our contractual commitments to you.

When we’re complying with legal obligations

We’ll process your information when we have a legal obligation to do so.

- When we’re pursuing legitimate interests

We may process Service Data based on our legitimate interests and those of third
parties while applying appropriate safeguards that protect your privacy. This means
that we process your information in the interests of providing Cloud Services you
request;
making recommendations to optimize use of Cloud Services; maintaining and improving
Cloud Services; providing and improving other services you request; assisting you;
and protecting against harm to the rights, property or safety of Google, our users,
our customers, and the public, as required or permitted by law.

#### California Requirements

The California Consumer Privacy Act (CCPA) requires specific disclosures for California
residents.

This Privacy Notice is designed to help you understand how Google handles your
information:

We explain the categories of information Google collects and the sources of that
information in
Information We Collect.

We explain how Google uses information in
Why We Process Data.

We explain when Google may share information in
How We Share Data. Google does not sell
your personal information.

The CCPA also provides the right to request information about how Google collects, uses,
and discloses your personal information. And it gives you the right to access your
information and request that Google delete that information. Finally, the CCPA provides
the right to not be discriminated against for exercising your privacy rights.

We provide the
information and tools described in this
Notice so you can exercise these rights. When you use them, we’ll validate your request
by verifying your identity (for example, by confirming that you’re signed in to your
Google Account). If you have questions or requests related to your rights under the
CCPA, you (or your authorized agent) can also
contact Google.

The CCPA requires a description of data practices using specific categories. This table
uses these categories to organize the information in this Privacy Notice.

Categories of personal information we collect

Business purposes for which information may be used or disclosed

Parties with whom information may be shared

Service Data is the personal information Google collects or generates during
the provision and administration of the Cloud Services, excluding any Customer
Data and Partner Data. Service Data includes:

**Identifiers** such as your name, phone number, and address, as
well as unique identifiers tied to the browser, application, or device you’re
using.

**Demographic information,** such as your preferred language.

**Commercial information** such as records of charges, payments,
and billing details and issues.

**Internet, network, and other activity information** such as
device identifiers, identifiers from cookies or tokens, IP addresses, and
information about usage, operational status, software errors and crash reports,
authentication credentials, quality and performance metrics, and other technical
details necessary for us to operate and maintain Cloud Services and related
software.

**Geolocation data,** such as the country you’re in, as may be
determined by GPS or IP address, depending in part on your device and account
settings.

**Audio, electronic, visual and similar information,** such as
audio recordings of your calls with our technical support providers.

**Inferences** drawn from the above, like aggregated performance
metrics for a new product feature to determine product strategy.

**Google processes Service Data for the following purposes:**

Protecting against security threats, abuse, and illegal activity.
Google uses and may disclose Service Data to detect, prevent and respond to
security incidents, and for protecting against other malicious, deceptive,
fraudulent, or illegal activity. For example, to protect our services, Google
may receive or disclose information about IP addresses that malicious actors
have compromised.

**Auditing and measurement.** Google uses Service Data for
analytics and measurement to understand how our services are used, and to
provide you and our customers with recommendations and tips.

**Maintaining our services.** Google uses Service Data to provide
Cloud Services, technical support, and other services you request, and ensure
they are working as intended, for example by tracking outages or troubleshooting
bugs and other issues that you report to us.

**Product development.** Google uses Service Data to improve Cloud
Services and other services you request, and to develop new features and
technologies that benefit our users and customers.

**Use of service providers.** Google shares Service Data with
service providers to perform services on our behalf, in compliance with this
Privacy Notice and other appropriate confidentiality and security measures.
For example, we may rely on service providers to help provide technical support.

**Legal reasons.** Google also uses Service Data to satisfy
applicable laws or regulations, and discloses information in response to legal
process or enforceable government requests, including to law enforcement.
We provide information about the number and type of requests we receive from
governments in our
Transparency Report.

**We do not share Service Data with companies, organizations, or
individuals outside of Google except in the following cases:**

**With your consent.** We’ll share Service Data outside of Google
when we have your consent. For example, when you or our customer chooses to
procure a third-party service through the Google Cloud Platform Marketplace or
Google Workspace Marketplace, or use a third-party application that requests
access to your information, we’ll seek permission to share information with
that third party.

**With your administrators and authorized resellers.** When you
use Cloud Services, your administrator and resellers authorized to manage your
or your organization’s account will have access to certain Service Data. For
example, they may be able to:

View account and billing information, activity and statistics

Change your account password

Suspend or terminate your account access

Access your account information in order to satisfy applicable law,
regulation, legal process, or enforceable governmental request

Restrict your ability to delete or edit your information or your privacy
settings

**For external processing.** We provide information to our
affiliates, partners and other trusted businesses or persons to process it for
us, based on our instructions and in compliance with this Privacy Notice and
other appropriate confidentiality and security measures.

**For legal reasons.** We may share Service Data outside of Google
if we have a good-faith belief that access, use, preservation, or disclosure of
the information is reasonably necessary to:

Comply with applicable law, regulation, legal process, or enforceable
governmental request. We share information about the number and type of
requests we receive from governments in our
Transparency Report.

Enforce applicable agreements, including investigation of potential
violations.

Detect, prevent, or otherwise address fraud, security, or technical issues.

Protect against harm to the rights, property or safety of Google, our
customers, users, and the public as required or permitted by law.

#### Korea Requirements

If Korean data protection law applies to the processing of your Service Data, we provide
the following additional information for users of Cloud Services residing in Korea.

**Items of personal information collected.**
When you use our Cloud Services, the following Service Data is collected: (i) business
records of charges, payments, billing issues, credit card info and connecting info
(ii) configuration and settings, including resource identifiers and attributes.
(iii) usage, operational status, quality and performance metrics, and other technical
details, device identifiers, identifiers from cookies or tokens, and IP addresses,
(iv) your feedback,
contact information and your other communications with us, each as further described
here.

The above personal information may be transmitted to our
data centers located abroad through
our network for the purposes listed below and stored for the retention period below.

We may use cookies (small text files placed on the user's device) and similar
technologies for a variety of purposes, including user preferences or settings,
authentication information, and interest-based advertising or analysis.
Most web browsers accept cookies automatically, but provide controls that allow you
to block or delete cookies.

**Purpose of collection and use of personal information.**
Google collects and uses Service Data (i) to provide Cloud Services you request, (ii)
to make recommendations to optimize use of Cloud Services, (iii) to maintain and improve
Cloud Services, (iv) to provide and improve other services you request (v) to assist
you, (vi) to protect you, our users, the public and Google, (vii) to comply with legal
obligations, and (viii) for other purposes with your consent, each as further described
here.

**Retention period of personal information.**
Service Data is deleted or anonymized once it is no longer needed for the purposes
described above. For each type of data and operation, we set retention timeframes based
on the purpose for its collection, and ensure it is kept for no longer than necessary.

**Deletion of personal information.**
If the retention period expires or you request deletion, Google will faithfully endeavor
to delete such personal information unless there is a legal obligation that requires
processing or another lawful basis for retaining the information. When we receive a
request to delete personal information, the retention period of the archive copy
expires, and then Google's archiving system has a mechanism to overwrite the expired
data. In some cases, it may be necessary to store some data for a variety of other
reasons, such as complying with legal obligations.

**Consignment of personal information processing.**
We provide information to affiliates (listed
here
for Google Cloud Platform and
here for Google Workspace)
and other trusted businesses or persons to process it for us, based on our instructions
and in compliance with this Privacy Notice and other appropriate confidentiality and
security measures.

Google has contracts with the third-party service providers listed below to provide
Cloud Services to Korean residents. The contracts impose obligations on those companies
to prohibit the processing of personal information other than for the purposes we
specify, to return or destroy personal information after the end of processing, and to
implement processes to ensure those companies comply with these obligations.

Third-party vendor
Role
Note

EPAM Systems Japan G.K
Customer Support for Cloud
In order for Google to provide Cloud Services to Korean residents,
these companies can process Service Data remotely from abroad during the
retention period described above.

Telus International US Corp, EPAM Systems Japan G.K
Cloud Billing Support

Sellbytel Services Malaysia Sdn. Bhd
Customer Support for Google Workspace

Toss Payments Co., Ltd. (Korean Company)
Payment and notification services

D-Agent (Korean company)
Local representative for user's privacy inquiries

**Legal minors.**
Our basic policy is not to collect personal information of Korean residents under the
age of 14. If you are Korean residents under the age of 14, you may use Cloud Services
only with the consent of a parent or legal representative.

**Contact Information.**
If you have any questions about Google's privacy policy or privacy practices, please
contact our Google privacy team
(Email: googlekrsupport@google.com). For
local representatives under the Act on Promotion of Information and Communication
Network Utilization and Information Protection, please see below:

Name and Representative: D-Agent Co., Ltd. (CEO Jong-Won Park)

Address and Contact Information: 11th floor, Platinum Building, Gwanghwamun 28,
Saemunan-ro 5-ga-gil, Jongno-gu, Seoul, 02-737-0346, d.agent2019@gmail.com

Except as otherwise noted, the content of this page is licensed under the Creative Commons Attribution 4.0 License, and code samples are licensed under the Apache 2.0 License. For details, see the Google Developers Site Policies. Java is a registered trademark of Oracle and/or its affiliates.

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