We collect data about you as described below when we provide our Services.  Please note that we need certain types of information to provide the Services to you.  If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain aspects of the Services.

a. Information you provide directly to us

We may collect information that you provide directly to us through:

• Your use of the Services;
• Your communications with us, such as when you inquire about our Services or contact customer support;
• Your registration for the Services, including when you register for trial accounts;
• Your subscription to newsletters or updates; and
• Your in-person communications with us, such as through conferences or events.

Information you provide directly to us may concern you and others and may include, but is not limited to:

• Contact Information and Identifiers.  You may provide us with contact information or other personal identifiers, such as your name, email address, mailing address, or telephone number.
• Financial Information.  We may collect payment information for our Services, such as when we engage payment processors to collect your payment information.
• Business Information.  We may collect general information about your employment or business, such as a business title, business phone, business email address, business product and service offerings, and other information you provide us when communicating with us.
• Transaction Information.  We may collect information about transactions with you, such as purchases, purchase amount, and date of purchase;
• Communications.  We may collect your communications with us, such as when you submit questions, communicate with our customer support, or otherwise communicate with LaunchDarkly.

You are not required to provide us with such information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.

b. Information from affiliates and non-affiliated parties

We may collect information about you or others through our affiliates and through non-affiliated parties.  We may also collect information about you from other users.  For example, users may provide us with information about colleagues or other prospective users of our Services.

We may combine information that we collect from you through the Services with information that we obtain from such other parties and information derived from other products or Services we provide.

c. Information we collect automatically

Device/Usage Information.  We and our vendors, which include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services.  As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); (i) version of our Services you’re using; and (j) the type of device that you use.  We may also track when and how frequently you access or use the Services, including how you engage with or navigate our website or mobile application.  We use this information (including the information collected by our vendors) for analytics (including to determine which portions of the Services are used most frequently and what our users like/do not like), to evaluate the success of our advertising campaigns, and as otherwise described in this Privacy Policy.

Cookies and Other Electronic Technologies.  We and our vendors may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Services.  These technologies, for example, may allow us to tailor the Services to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about usage of our Services.  We and our vendors also may use certain of these technologies in emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer.  If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly.  As we adopt additional technologies, we may also gather additional information through other methods. 

We do not currently recognize or respond to browser-initiated Do Not Track (DNT) signals.  Please note that DNT is different from the Global Privacy Control referenced in Section 11 below.

Location Information.  When you use the Services, we may collect general location information (such as general location inferred from an IP address).

We use your information for business and commercial purposes, such as:

• To provide you with the Services;
• To respond to your questions and inquiries, including to provide customer support and technical assistance;
• To communicate with you, including to send you emails about our products and services;
• To send service notices;
• To process transactions with you;
• To analyze and improve the Services or any other products and services we provide;
• To verify your identity;
• To comply with our legal obligations or as permitted by law;
• To protect the safety and/or integrity of our users, employees, other parties, members of the public, and/or our Services;
• To conduct analysis and develop insights that enable us to operate, protect, make informed decisions and report on our business;
• To prevent fraud and enforce our legal terms; and
• To administer and troubleshoot the Services.

We may also use or disclose aggregated and/or de-identified information collected through the Services.  We will not attempt to re-identify such information, except as permitted by law.

We may disclose the information we collect in the following circumstances:

Affiliates and Subsidiaries.  We may disclose information to our affiliates and subsidiaries.

Vendors.  We disclose your information to select vendors who perform services on our behalf.  They provide a variety of services to us, including data storage, analytics, billing, marketing, product content and features, customer service, data storage, security, fraud prevention, and legal services.

Safety and Protection of LaunchDarkly and Others.  We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of LaunchDarkly or other parties, including to defend or enforce our Privacy Policy, our Terms of Service, or any other contractual arrangement; (ii) respond to your requests for customer service; and/or (iii) protect the rights, property or personal safety of LaunchDarkly, its agents and affiliates, its employees, users and/or the public. 

Legal Requirements.  We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.

Business Transfers.  We may disclose certain information, in connection with or during negotiations or closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Consent/At Your Direction.  We may disclose your information to third parties based on your consent to do so.  For example, you may direct us to disclose information about you when you refer us or our Services to your colleagues or other acquaintances.

a. Analytics

We may use third-party web analytics services on the Services, such as those of Google Analytics.  These vendors use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive.  The information collected by the technology will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services.  We also use Google Analytics for certain purposes related to advertising, as described in the following section.  To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

b. Tailored Advertising

We may also allow third-party advertising technologies to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our websites and other third-party sites and (b) report how our marketing content impressions and interactions with these marketing impressions are related to visits to our websites.  We also allow other unaffiliated parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services.  Those parties may offer you a way to opt out of targeted advertising as described below.  You may receive tailored advertising on your computer through a web browser.  Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may disclose to a vendor in hashed, non-human-readable form.

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by participating companies by visiting the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Link, the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Link, and/or the European Interactive Digital Advertising Alliance.  To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page.  Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising.  In that case, the advertising content may not be tailored to your interests.  Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.  If your browsers are configured to reject cookies when you visit these opt-out pages, if you subsequently erase your cookies, or if you use a different computer or change web browsers, then your opt-out may no longer be effective.

a. Rights and choices

You have certain rights and choices with respect to your information such as:

• Profile Information:  You can update certain of your profile information by accessing your account.
• Marketing Communications:  You can unsubscribe from marketing emails by following the directions in those emails.  Please note that if you unsubscribe from marketing emails, we may still send you administrative emails regarding the Services, including, for example, notices of updates to our Terms of Service or this Privacy Policy.
• Cookies & Analytics:  You can opt out of certain cookie-related and analytics processing by following the instructions in this Privacy Policy (see the “Tailored Advertising” subsection above).

Your local law may provide you certain rights with respect to your personal data.  Depending on your jurisdiction, you may request that we:

• provide access to and/or a copy of certain information we hold about you;
• prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
• update information which is out of date or incorrect;
• delete certain information that we are holding about you;
• restrict the way that we process and disclose certain of your information;
• transfer your information to a third-party provider of services; and
• revoke your consent for the processing of your information.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation.  We may request you provide us with information necessary to confirm your identity before responding to your request.  To exercise any of these rights, please contact us as described in the “Contact Us” section below.

b. Additional rights of residents of the European Economic Area and United Kingdom

LaunchDarkly is considered the “data controller” of the personal data we handle under this Privacy Policy.  In other words, LaunchDarkly is responsible for deciding how to collect, use and disclose this data, subject to applicable law.  The laws of some jurisdictions such as the laws of the European Economic Area and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using or disclosing of your information.  To the extent those laws apply, our legal grounds are as follows:

• Contractual Commitments:  We may use or disclose information to honor our contractual commitments to you.  For example, we will process your personal data to comply with our agreements with you, and to honor our commitments in any contracts that we have with you.
• With Your Consent:  Where required by law, and in some other cases, we use or disclose information on the basis of your consent.
• Legitimate Interests:  In many cases, we use or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for the Services, preventing fraud, and managing legal issues.
• Legal Compliance:  We need to use and disclose information in certain ways to comply with our legal obligations.

In addition to those rights described herein and in the “Rights and choices” subsection above, you have the right to lodge a complaint with the relevant supervisory authority.  However, we encourage you to contact us first, and we will do our very best to resolve your concern.

c. Additional rights of residents of certain states

Please see Section 11 below for notices and additional information for residents of states that have consumer privacy laws, including California, Colorado, Connecticut, Utah, and Virginia.

d. Additional rights of residents of Nevada

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data to unaffiliated parties.  We do not currently sell your personal data as sales are defined in Nevada Revised Statutes Chapter 603A.

The Services are not designed for minors under 18.  Only persons 18 years of age or older may use the Services.  If we discover that an individual under 18 has provided us with personal data, we will close the account and delete the personal data to the extent required by the Children’s Online Privacy Protection Act.  We may, where permitted by law, retain certain information internally for purposes described in this Privacy Policy.

LaunchDarkly implements technical, administrative, and physical safeguards to help protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  However, no Internet or email transmission is ever fully secure or error free.  Therefore, we do not promise and cannot guarantee the security of your personal data or communications.

If you have reason to believe that your data or someone else’s data is no longer secure, please contact security@launchdarkly.com.

We keep your information for the time necessary for the purposes for which it is processed.  The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it.  We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Our services are global and data may be transferred to countries other than the country in which the data was originally collected, including to the United States and other countries, which may not have the equivalent data protection laws as those of your country.  Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent or participating in the EU-U.S. Data Privacy Framework as described below.

LaunchDarkly participates in the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework (collectively, “Data Privacy Framework” or “DPF”) issued by the U.S. Department of Commerce and approved by the European Commission, UK Information Commissioner’s Office and the Swiss Data Federal Data Protection Commission.  LaunchDarkly commits to comply with the Data Privacy Framework Principles with respect to personal data the company receives from the EU, UK, and Switzerland in reliance on the DPF.

If there is any conflict between the terms in this Privacy Policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern.  To learn more about the Data Privacy Framework program, please visit https://www.dataprivacyframework.gov.  To view our certification, please visit https://www.dataprivacyframework.gov/s/participant-search.

If third-party agents process personal data on our behalf in a manner inconsistent with the Data Privacy Framework Principles, we remain liable unless we prove we are not responsible for the event giving rise to any damages.  If you have a question or complaint related to our compliance with the Data Privacy Framework Principles, please contact us as described in Section 13 below.

For any complaints related to the DPF that cannot be resolved with us directly, you may refer the matter to JAMS pursuant to the JAMS Data Privacy Framework Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-data-privacy-framework.  JAMS mediation may be commenced as provided for in the JAMS rules.  Following the dispute resolution process, the mediator or the consumer may refer the matter to the U.S. Federal Trade Commission, which has Data Privacy Framework investigatory and enforcement powers over LaunchDarkly.  Under limited circumstances, and after other available dispute resolution mechanisms have been exhausted, consumers may be able to invoke binding arbitration to address complaints about LaunchDarkly’s compliance with the Data Privacy Framework Principles.

The Services may contain links to third-party websites or services.  We are not responsible for the content or practices of those websites or services.  The collection, use, and disclosure of your information will be subject to the privacy policies of those third-party websites or services, and not this Privacy Policy.  We urge you to read the privacy and security policies of these third parties.

California, Colorado, Connecticut, Utah, and Virginia have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Laws”). If you are a resident of one of these states, this Section 11 applies to you.  This Section 11 does not apply to personal data we collect from our employees and job applicants in their capacity as employees and job applicants, as such information practices are described in separate policies.

a. Categories of information we collect

Section 1 above describes the information we collect from and about you, Section 2 describes the purposes for which we use this information, and Section 3 describes when and to whom we disclose data.  As required by certain State Laws, we use the table below to list the personal data we collect by category along with the purposes of its use and the unaffiliated parties to which it is disclosed.

We collect the categories of personal data identified above from the following sources, as described further in Section 1 above:  (1) directly from you; (2) through your use of the Services; (3) affiliates; and (4) other parties such as marketers and other users.

b. Your privacy rights

Depending on where you live, you may request:

• To know more about and access your personal data (including in a portable format).
• Deletion of your personal data.
• Correction of inaccurate personal data that we maintain about you.

You also have the right to opt out of “sales,” “sharing,” and processing of your personal data for targeted advertising purposes, as described in subsection c below.  You may have the right to receive information about the financial incentives that we offer to you, if any.  You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.  Certain information may be exempt from such requests under applicable law.  We need certain types of information so that we can provide the Services to you.  If you ask us to delete it, you may no longer be able to access or use the Services.

If you would like to exercise any of these rights, please submit a request using one of the methods in Section 13, “Contact Us,” below.  We may ask you to verify your identity before we fulfill your request, and we may request additional information from you in order to do this.  You can also designate an authorized agent to make a request on your behalf.  To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf.  You may still need to verify your identity directly with us.

c. Sales, sharing, and targeted advertising

We may disclose your personal data to third parties for purposes of analytics and advertising.  We provide information to analytics providers to better understand how consumers use the Services so we can improve the Services and create new products and services.  We may also provide personal data to third-party advertising providers for targeted advertising purposes, so we can provide you with more relevant and tailored ads regarding our services.  These activities may be considered a “sales,” “sharing,” or processing for targeted advertising purposes under certain State Laws.

The following chart lists the categories of personal data we have sold, shared, or processed for targeted advertising purposes over the last 12 months and the categories of third party recipients:

To opt out of online disclosures, such as through cookie and pixel technology, that could be considered “sales,” “sharing,” or processing for targeted advertising purposes, please click here.  You can also submit a request to opt out of offline disclosures that are subject to these opt-out rights by emailing us at privacy@launchdarkly.com. 

Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control where required by State Law.  Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them.  For more information on how to use the Global Privacy Control, visit www.globalprivacycontrol.org.

We do not knowingly “sell” or “share” the personal data of children under 16.  We do not use or disclose “sensitive” personal data for the purpose of inferring characteristics about you.

d. Retention

Please see Section 8 above (“Data Retention”) for how we retain your personal data.

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of this Policy.  If we make a material change to this Privacy Policy, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification).

You may contact us by email at privacy@launchdarkly.com or by phone at +1 (888) 870 - 4974.