Details on how Bugsnag processes and stores your data.
Last updated: May 24, 2018
Bugsnag complies with the requirements of the EU-U.S. Privacy Shield Framework (“Privacy Shield”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of Personal Information transferred from the European Economic Area to the United States. Bugsnag has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Bugsnag’s certification, please visit https:// www.privacyshield.gov. Additionally, Bugsnag may protect information through other legally valid methods, including international data transfer agreements.
This Policy applies to all Bugsnag’s operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates certified under the Privacy Shield, and any additional subsidiary, affiliate, or branch of Bugsnag that we may subsequently form.
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Bugsnag and the requirements of applicable law. Some of the ways that Bugsnag may collect Personal Information include:
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
Bugsnag collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Bugsnag, purchasing a Plan from Bugsnag, requesting Services or information, or contacting us directly through the “Contact Us” feature or by some other method, we may ask you to provide some or all of the following types of information:
Information Submitted Via Services. You agree that Bugsnag is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Bugsnag will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or © we are required to do so by law.
Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you (for example, lead or data enrichment services). . This supplemental information allows us to verify information that you have provided to Bugsnag and to enhance our ability to provide you with information about our business, products, and Services. Through cookies we place on your browser or device, we may also collect information about your online activity after you leave our Site. We use this information to improve the Site and customize your online experience.
Event Data Information. The Bugsnag Services monitor errors in web, mobile and server applications and programs under the direction of its Customers, to provide session, error and crash Event Data. Each Bugsnag Customer provides Bugsnag with session, error and crash Event Data from the Customer’s applications and programs. Event Data may contain personal information of the Customer’s end user. This means that if you are an end user of a service provided by a Bugsnag Customer, then Bugsnag may receive Personal Information about you from the Bugsnag Customer. Not all Customers provide Personal Information about their end users to Bugsnag. Customers use the Services dashboard to control or block the use of end user Personal Information by the Services. Bugsnag itself does not collect this end user Personal Information and Bugsnag has no direct relationship with these individuals. For example, a Customer may direct Bugsnag to log certain software application’s end user information associated with Event Data, such as the end user’s device ID, email and name. Bugsnag is a data processor and follows the instructions of the Customer in these cases. To find out more about how our Customers issue these instructions to us and handle this Personal Information you will need to review the privacy policies of each Customer. An individual who wants to correct, amend or delete inaccurate data should direct his or her request to Bugsnag’s Customer (the data controller). Separately, if our Customer requests that we remove Event Data from the Services then we will respond promptly to this request.
No Sensitive Data or Sensitive Personal Information. Bugsnag does not collect Sensitive Data as defined under the laws of the European Union.
Bugsnag monitors web, mobile and server applications and programs under the direction of its Customers, to provide error Event Data about the Customer’s applications and programs to the Customer. Event Data may contain Personal Information of the individuals who use the Customer’s applications. Bugsnag itself does not collect this end user Personal Information and Bugsnag has no direct relationship with these individuals. For example, a Customer may direct Bugsnag to log certain software application’s end user information associated with Event Data, such as the end user’s device ID, email and name. Bugsnag is a data processor and follows the instructions of the Customer in these cases.
To find out more about how our Customers issue these instructions to us and handle this Personal Information you will need to review the privacy policies of each Customer. An individual who wants to correct, amend or delete inaccurate data should direct his or her request to Bugsnag’s Customer (the data controller). Separately, if our Customer requests that we remove Event Data from the Services then we will respond promptly to this request.
If you are a Customer then you are responsible for obtaining permission from your end users to share any data that may contain the end users’ Personal Information with the Bugsnag Platform. Customers use the Services dashboard to control or block the use of end user Personal Information by the Services. From time to time Bugsnag creates statistics about the way Customers generally use our Services. These statistics are derived from large sets of anonymized, aggregated Event Data. We refer to this information as “Aggregated Information.” Aggregated Information contains no Personal Information and no information that can be associated with any specific Customer. Bugsnag shares Aggregated Information with its Customers to educate them about the usefulness of the Services and to help them understand industry trends.
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. Bugsnag may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
Administrative Purposes. Bugsnag may use Personal Information about you for its administrative purposes, including to:
Marketing Bugsnag Products and Services. Bugsnag may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Bugsnag may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
Research and Development. Bugsnag may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Bugsnag may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Bugsnag’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
Anonymous and Aggregated Information Use. Bugsnag may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Bugsnag’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Bugsnag may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Bugsnag and with Third-Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Other Uses. Bugsnag may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Our uses of such Technologies fall into the following general categories:
If you would like to opt-out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Bugsnag does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk. Bugsnag’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes.
When you purchase a subscription for the Services, we process your payments through a Third-Party payment processor. The Third-Party payment processor may collect certain financial information from you to process a payment on behalf of Bugsnag, including your name, email address, address and other billing information.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Bugsnag has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. Bugsnag may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or Service that you have requested. Bugsnag may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Bugsnag. Bugsnag requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Bugsnag provided them.
Privacy Shield. With respect to onward transfers to Agents under Privacy Shield, Privacy Shield requires that Bugsnag remain liable should its Agents Process Personal Information in a manner inconsistent with the Privacy Shield Principles.
Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Bugsnag may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Bugsnag related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 5 below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Bugsnag policies or contracts; (v) to collect amounts owed to Bugsnag; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
All Personal Information collected via or by Bugsnag may be stored anywhere in the world, including but not limited to, the United States, Canada, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Bugsnag, you consent to the storage of your Personal Information in these locations.
You have the right to opt-out of certain uses and disclosures of your Personal Information. Where you have consented to Bugsnag’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting us at email@example.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
WE MAINTAIN TELEPHONE “DO-NOT-CALL” AND “DO-NOT-MAIL” LISTS AS MANDATED BY LAW. WE PROCESS REQUESTS TO BE PLACED ON DO-NOT-MAIL, DO-NOT-PHONE AND DO-NOT-CONTACT LISTS WITHIN 60 DAYS AFTER RECEIPT, OR SUCH SHORTER TIME AS MAY BE REQUIRED BY LAW
Bugsnag may occasionally send you push notifications through our mobile applications with information that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Bugsnag may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt-out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.
Although Bugsnag makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Bugsnag is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Bugsnag determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Bugsnag will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
The Services are not directed to children under 13 (and in certain jurisdictions in the EU under the age of 16) years of age, and Bugsnag does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions in the EU under the age of 16) years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. Bugsnag urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions in the EU under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.
If you are an EU citizen and feel that Bugsnag is not abiding by the terms of this Policy, or is not in compliance with the Privacy Shield Principles, please contact Bugsnag at the contact information provided above.
In addition, Bugsnag has agreed to refer unresolved complaints related to Personal Information to JAMS Privacy Shield Dispute Resolution Program. For more information and to submit a complaint regarding Individual data to JAMS, a dispute resolution provider which has locations in the United States and EU, visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.
Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Bugsnag’s compliance with the Privacy Shield.
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Bugsnag will endeavor to comply with the law or contract.
This Policy shall be implemented by Bugsnag and all its operating divisions, subsidiaries and affiliates. Bugsnag has put in place mechanisms to verify ongoing compliance with Privacy Shield Principles and this Policy. Any Bugsnag employee who violates these Privacy Shield Principles and/or this Policy will be subject to disciplinary procedures.
The following capitalized terms shall have the meanings herein as set forth below.