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Privacy Policy

Privacy Policy

Last updated: November 25, 2021

The privacy of your data — and it is your data, not ours! — is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.

This policy applies to Statsignal or another product built and maintained by 19 Signals LLC.

What we collect and why

Our guiding principle is to collect what we need only. Here’s what that means in practice:

Identity & access

When you sign up for a 19 Signals product, we typically ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our product, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

When you pay for a 19 Signals product, we ask for your credit card and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card number is passed directly to our payment processor provider and is never saved on our servers. We store a record of the payment information, including the last 4 digits of the credit card number, the expiration date, and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States or VAT in the EU, to detect fraudulent credit card transactions, and to print on your invoices.

Geolocation data

We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.

We also log full IP addresses used to sign up a product account. We keep this record because they are used to mitigate spammy signups.

Web analytics data — described further in the Website Interactions section.

Website interactions

When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data could be tied to your user account if applicable and you are signed into our Services. We use third-party web analytics software.

Anti-bot assessments

We use CAPTCHA services across our applications to mitigate brute force logins. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your accounts and fill specific forms in our products, the CAPTCHA service evaluates various information (e.g IP address, how long the visitor has been on the app, mouse movements) to check whether the data is possibly filled out by an automated program instead of a human. We retain these data via our subprocessor forever because they are used for anti-spam mitigation.

Cookies

We do use persistent first-party cookies to store certain preferences and session information, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: allaboutcookies.org.

Voluntary correspondence

When you write to 19 Signals with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.

We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.

Information we do not collect

We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities.

We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.

When we access or share your information

Our default practice is to not access your information. The only times we’ll ever access or share your info are:

In order to diagnose a problem you are having with our Service, we may need to access your created data in Statsignal or another 19 Signals product. We never will share this data with a third party, and this data only will be used to diagnose the problem that you have reported.

To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.

When required under applicable law.

19 Signals, LLC is a US company.

  • If US law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. In the event a government authority outside the US approaches 19 Signals with a request, our default stance is to refuse unless the US government compels us to comply through procedures outlined in a mutual legal assistance treaty or agreement. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.
  • Similarly, if 19 Signals receives a request to preserve data, we refuse unless compelled by either the US Federal Stored Communications Act, 18 U.S.C. Section 2703(f) or a properly served US subpoena for civil matters. In both of these situations, we have to comply. In these situations, we notify affected customers as soon as possible unless we are legally prohibited from doing so. We do not share preserved data unless absolutely required under the Stored Communications Act or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we destroy any preserved copies we made of customer data once the preservation period lapses.
  • If we get an informal request from any person, organization, or entity, we do not assist. If you are an account owner who wants to export data from their accounts, you can do so directly through the 19 Signals Product user interface.
  • If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we only share the bare minimum needed, such as billing addresses and tax exemption information.

Finally, if 19 Signals, LLC is acquired by or merged with another company — we don’t plan on that, but if it happens — we’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.

Your rights with respect to your information

At 19 Signals, we apply the same data rights to all customers, regardless of their location. Currently, some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and Wyoming's Consumer Protection Act in the US. 19 Signals recognizes all of the rights granted in these regulations, except as limited by applicable law.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser.

Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest. For more information about how we keep your information secure, please review our Security overview.

What happens when you delete data in your product accounts

When you delete an instance of one of our services, the data are no longer accessible via the application and are deleted from our active servers within the next 30 days, so if you change your mind you’ll need to do so before your data are deleted from our active servers.

We also delete your data after an account is cancelled. In this case, your data are purged within 30 days. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts. Please refer to our Cancellation policy for more details.

Location of site and data

19 Signals products are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

When transferring personal data from the EU

The GDPR requires that any data transferred out of the EU must be treated with the same level of protection that the EU privacy laws grant. The privacy laws of the United States generally do not meet that requirement. However, we have incorporated a Data Processing Agreement to our Terms of Service that is in effect when the GDPR applies to your use of 19 Signals Services to process Customer Data as defined in the DPA.

You can find the DPA linked within clause 7 of the Uptime, Security and Privacy section. The DPA includes the European Commission’s Standard Contractual Clauses (both controller-processor and controller-controller) to extend GDPR privacy principles, rights, and obligations everywhere personal data is processed.

There are also a few ad-hoc cases where EU personal data may be transferred to the US related to 19 Signals, LLC operations. For instance, if someone in the US comments on our company blog or a customer participates in one of our infrequent surveys or someone applies to one of our open positions. Such transfers are only occasional and transferred under the Article 49(1)(b) derogation under GDPR.

Changes & questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our company blog.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at [email protected] and we’ll be happy to answer them!

19 Signals policies are open source, licensed under CC BY 4.0. Adapted from the Basecamp open-source policies / CC BY 4.0.
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