Privacy Policy

Effective date: August 24, 2026

This Privacy Policy is applicable to Xanadu Quantum Technologies Inc. ("Xanadu" or the "Company") and sets out Our policy on the gathering and use of information on PennyLane.ai (the "Service"). Xanadu is committed to providing safe websites for all visitors and has implemented this Privacy Policy to demonstrate Our commitment to Your privacy. If You have any questions about this Privacy Policy, You can contact Us at privacy@xanadu.ai.

When You clicked "accept" or "agree" in connection with registering Your Account, We made available to You this Privacy Policy. This Privacy Policy only covers Xanadu's practices regarding Personal Data, and not information more generally. We may use aggregated, anonymized data that We derived from Your Personal Data before You deleted it, but not in a manner that incorporates any of Your Personal Data or would identify You personally.

There may be links from Our Service to other websites. This Privacy Policy applies only to Our Service and not to any third-party activities, including third-party websites linked from Our Service. We are not responsible for the privacy practices or content of such third parties. We encourage You to read the privacy statements of those third parties.

You may be asked to provide Us with Personal Data when You visit certain sections of Our Service (note that registration is required to access certain features). Your use of Our Service signifies Your acknowledgement and consent to Our Privacy Policy. If You do not agree to this Privacy Policy, please do not continue to use Our Service.

Interpretation and Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

• "Account" means a unique account created for You to access the Service or parts of the Service.

• "Company" (referred to as either "the Company", "We", "Us", or "Our" in this Agreement) refers to Xanadu Quantum Technologies Inc. (or "Xanadu").

  • For the purpose of the GDPR (General Data Protection Regulation), the Company is the Data Controller.

• "Cookies" are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• "Data Controller", for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• "Device" means any device that can access the Service such as a computer, a cell phone, or a digital tablet.

• "Do Not Track (DNT)" is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

• "Personal Data" is any information that relates to an identified or identifiable individual.

  • For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.

• "Service" refers to the Website.

• "Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

• "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• "Website" refers to PennyLane.ai, accessible from https://pennylane.ai/.

• "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

  • Under GDPR, You can be referred to as the Data Subject or as the User as You are the individual using the Service.

Personal Data Xanadu Collects

We collect information in order to provide, maintain, and improve Our Service.

While using Our Service, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You. Personal Data may include Your:

• Email address
• First name and last name
• Country, state, province, and/or city
• Username
• Social media profiles
• Place of work and/or education
• Background and experience in quantum computing, which may include Your level of education
• Job title
• Usage Data
• Profile pictures

The specific Personal Data from this list that We may ask You to provide Us may vary depending on the specific features of the Service You use.

Usage Data is collected automatically when using the Service. The Usage Data Xanadu collects when You use the Service may include:

• Your Device's Internet Protocol address (IP address)
• Browser type
• Browser version
• Pages of Our Service that You visit
• Time spent on the pages You visit
• Time and date of Your visit
• Time and date of Your Account registration
• Time and date of login to Your account
• Unique device identifiers
• Other diagnostic data

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers, and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

We also collect the content You create, upload, or receive from others when using Our Service. This may include, but is not necessarily limited to, things like messages You write and receive, forum posts, profile pictures, notebooks, datasets, and code submissions.

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A Cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our Service may use Cookies.

• Web Beacons. Certain sections of Our Service and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  • Type: Session Cookies
  • Administered by: Third Parties
  • Purpose: These Cookies are essential to provide You with services available through the Service and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance Cookies
  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies identify if users have accepted the use of Cookies on the Service.
• Functionality Cookies
  • Type: Persistent Cookies
  • Administered by: Us and Third Parties
  • Purpose: These Cookies allow Us to remember choices You make when You use the Service, such as remembering Your login details or preferences. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.
• Tracking and Performance Cookies
  • Type: Persistent Cookies
  • Administered by: Third Parties
  • Purpose: These Cookies are used to track information about traffic to the Service and how users use the Website. The information gathered via these Cookies may directly or indirectly identify You as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device You use to access the Website. We may also use these Cookies to test new pages, features, or new functionality of the Website to see how Our users react to them.

For more information about the Cookies We use and Your choices regarding Cookies, please visit Our Cookies Policy.

When You link an account You may have on a third-party service (such as a third-party social networking site or email provider) to Your account on the Service, Xanadu collects certain information stored in connection with that account that You have configured that service to make available, including Your email address, provider ID, first and last name, and profile picture. By linking Your accounts in this manner, You authorize Xanadu to access and use Your account on the third-party service in connection with Your use of Our Service.

The Ways Xanadu Uses Information

Xanadu does not sell Your Personal Data to third parties without Your consent. However, We may use and share Your information in the ways described below and as otherwise permitted under applicable law. For the purposes of this Privacy Policy, "sell" means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a user's Personal Data by Us to a third party for valuable consideration. Valuable consideration may be, but is not necessarily, monetary.

Xanadu may use Personal Data for the following purposes:

• To provide and maintain Our Service, including to monitor the usage of Our Service. This also includes events such as QHack, and other events that are hosted through the Service.
• To create Your Account: to create and administer Your Account so You can use the Service. We strongly recommend that You do not disclose Your Account password to anyone. We will never ask You for Your password in any unsolicited communication (such as letters, phone calls, or email messages). If You become aware of any unauthorized access to or use of Your Account, You are required to notify us immediately.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• To prevent fraud: to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.
• To contact You: to contact You by email, telephone calls, SMS, social media platforms, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products, or contracted services, including security updates, when necessary or reasonable for their implementation, or to respond to any questions, comments, or complaints We receive from You.
• To provide You with news, special offers, Our newsletter, and general information about other goods, services, and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: to attend and manage Your requests to Us.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and to evaluate and improve Our Service, products, services, marketing, and Your experience.

We may share, transfer, or disclose Your Personal Data in the following situations:

• With Service Providers: We may share, transfer, or otherwise make available Your Personal Data with Service Providers to facilitate the Service, perform services related to the Service, monitor and analyze the use of the Service, or to contact You. Our Service Providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose Personal Data for their own marketing or other purposes. Our Service Providers may be located outside of the province or state in which You reside (which may include transfer outside of Quebec for Quebec residents) in the U.S., Canada, or other foreign jurisdictions.
• For business transfers: We may share or transfer Your Personal Data as an asset in connection with, or during negotiations of, any proposed or completed merger, sale (including transfers made as part of insolvency or bankruptcy proceedings) of Company assets, financing, or acquisition of all or a portion of Our business to another company or as part of a corporate reorganization or other change in corporate control.
• With affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include any other subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us.
• With other users: when You share Personal Data or otherwise interact in the public areas (such as message boards) with other users, such information may be viewed by all users and may be publicly distributed outside of Our Service.
  • When You create an Account with Us, a public profile page is created for You which includes Your username. This profile is viewable by any member of the public. Our Service allows You to choose to make additional Personal Data that You provide Us appear on Your public profile, with control over how and what You share. The Personal Data that may appear on Your public profile includes Your name, profile picture, and any other additional information that You choose to share. Please do not post or add Personal Data to Your public profile that You would not want to be publicly available.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent and subject to requirements under applicable privacy law.
• For legal and compliance purposes: We and Our Canadian, U.S., and other foreign service providers and affiliates may disclose Your Personal Data in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing, or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S., or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement, or other government authorities. Your Personal Data may also be disclosed where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

In the situations outlined above, the sharing and transfer of Your Personal Data will always be done in compliance with this Privacy Policy and any applicable laws.

Retention of Your Personal Data

Xanadu will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

Xanadu will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

We have record retention processes designed to retain Personal Data for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at Xanadu's operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

Xanadu will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other Personal Data.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

We have implemented reasonable administrative, technical, and physical measures in an effort to safeguard the Personal Data in Our custody and control against theft, loss, and unauthorized access, use, modification, and disclosure. We restrict access to Personal Data on a need-to-know basis to employees and authorized Service Providers who require access to fulfil their job requirements.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

We use third-party Service Providers to monitor and analyze the use of Our Service. These third-party Service Providers include:

• Hotjar
• Google Analytics
• Google Optimize
• Google Search Console

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials, and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. We may also use third-party Service Providers to facilitate these communications, including:

• Mailchimp

Other Service Providers may be used to facilitate and provide the Service to You, with whom We may share Your Personal Data. These Service Providers include, but are not necessarily limited to:

• Amazon Web Services (AWS)
• Auth0
• HubSpot
• MathJax
• Utteranc.es

Canadian Requirements

If You submit Personal Data via Our Service or otherwise provide Us with Your Personal Data, You may withdraw Your consent or request access, update, port, rectification, or correction of Your Personal Data by submitting a written request to the Chief Privacy Officer (see "Contact Us" below). You may also withdraw Your consent to Our collection, use, and disclosure of Personal Data (subject to legal and contractual restrictions). We may request certain Personal Data for the purposes of verifying Your identity.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the privacy policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions or comments about this Privacy Policy or the manner in which We or Our service providers treat Your Personal Data, or to request access to Your Personal Data in Our records, You can contact Us at privacy@xanadu.ai.