On ArcGIS Spatial Analyst's Privacy Page you can request and collect all the privacy and GDPR related information that ArcGIS Spatial Analyst is providing.
The privacy policy by is a legal document or statement that discloses how ArcGIS Spatial Analyst gathers, uses, discloses, and manges their customers' data.
The basis for Esri sharing, adding, uploading, hosting, accessing or sending personal data out of Europe. Vendors can also add a description of their own impact assessment for data transfers.