Last updated: Jan 1st, 2021
Who Are We
Categories of Personal Information Collected. Generally, we collect the following types of personal information:
- Identifiers: Includes direct identifiers, such as name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers.
- Customer Records: Includes personal information, such as name, account name, user ID, contact information, education and employment information, payment information that individuals provide us in order to purchase or obtain our products and services.
- Commercial Information: Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
- Audio, Video and Electronic Data: Includes audio, electronic, visual, thermal, olfactory, or similar information such as photographs and images (e.g., that you provide us) and call recordings (e.g., of customer support calls).
- Usage Data: Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other services, and our marketing emails and online ads.
- Professional information: Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).
- Education Information: Information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).
- Inferences: Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes.
Use of Personal Information. In general, we may use and disclose the personal information we collect for the following business and commercial purposes:
- Providing Support and Services
- Analyzing and Improving Sites and Services and Operations
- Personalizing Content and Experiences
- Advertising, Marketing and Promotional Purposes
- Securing and Protecting Our Business
- Defending our Legal Rights
- Auditing, Reporting, Corporate Governance, and Internal Operations
California residents: If you are a California resident, please refer to the California Privacy Disclosures section below for important information about the categories of personal information we collect and disclose, as well as your rights under California privacy laws, including your right to submit a “Do Not Sell My Info” request (i.e., to opt of the sale of your personal information by us).
What Personal Data Do We Collect?
The personal data that we collect when you visit our Sites or use our Services may include the following:
- Information you provide to Lightbend - we collect personal data that you choose to provide to us when you are using our Sites and Services. Personal data may include your name, email address, state and country of residence, job title and company name. When you register for the Academy Platform, we collect personal data about you including your user name, account name, and user ID. As part of the Services, we may collect information about the courses you complete and any accreditation or certifications you receive. We may also collect personal data from your communications with us, including through email or forms on our Sites, such as your photo, phone number, fax number and address. When you make purchases through the Sites or for the Services, we collect payment information such as credit card and account numbers. When engaging with our sales teams, we may collect your contact information, as well as information about your previous purchases and sales activity.
- Information from third parties – we collect personal data from third parties and public databases for lead generation purposes.
Sources of Personal Data We Collect
We collect personal data directly from you, automatically through your use of our Sites and Services, or from third parties. For example, we collect personal data:
- From you directly, including through any form you may complete and submit through our Sites;
- From your employer (or other corporate or enterprise level customer) who provides us information about you; and
- From 'cookies' and other similar tools deployed on parts of our Sites, including cookies that can only be accessed by authenticated users who are logged into the Sites (for further information regarding cookies used on our Sites, please see below).
Legal bases and purposes For Processing Personal Data
Certain laws, including the EU General Data Protection Regulation, require that we inform you of the legal bases for our processing of your personal data. Accordingly, we collect and use your personal data for the purposes described below and on the following lawful bases:
- For the performance of our agreement with you - to perform contracts that you may have with us (for example, if you use our Services);
- Compliance with laws – to comply with our legal obligations;
- For our legitimate interests as a business when those interests are not overridden by your interests, fundamental rights or freedoms - Our legitimate interests:
- to analyse visits to and use of the Sites to improve and develop our Services.
- to understand our customers both on aggregated and on individual basis.
- to analyse your use of our Sites and Services and use this information to improve them and to give you a better experience (e.g. we analyse what webpages you visit, which Services you use and like and how you use these Services, which enables us to create personal profiles and to assess what may be interesting to you, which recommendations we can give you when you purchase our Services). Creating such personal profiles of our customers, enables us to send you marketing materials that directly relate to your use of the Sites and Services, if you have chosen to receive such materials by opting-in. With respect to our customers who purchased one of our Services, we may send marketing material regarding similar Services.
- to ensure the security of our Services.
- to prevent fraud, hacking, cheats and spamming; and to facilitate our response to legal processes (e.g., a court order, warrant or subpoena).
- Based on your consent - We use your personal data based on your consent when you sign up to receive our newsletters, marketing or promotional material and other information that may be of interest to you through our Sites or otherwise expressly consent to the use of your personal data. You can withdraw your consent at any time by sending an email to firstname.lastname@example.org or by opting-out by following the opt-out instructions in the relevant marketing communication.
Purpose for using personal data. While the purposes for which we may process personal data will vary depending upon the circumstances, in general we use personal data for the purposes set forth below. Where GDPR or other relevant laws apply, we have set forth the legal bases for such processing (see above for further explanation of our legal bases) in parenthesis.
- Providing Support and Services: Including to provide our Sites and Services; to communicate with you about your access to and use of our Sites and Services; to respond to your inquiries; to provide troubleshooting, fulfill your orders and requests, process your payments and provide technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and our legitimate interests)
- Analyzing and Improving Sites and Services and Operations: Including to better understand how users access and use our Sites and Services, to evaluate and improve our Sites and Services and business operations, and to develop new Sites and Services; to conduct surveys and other evaluations (such as customer satisfaction surveys); and for other research and analytical purposes. (Legal basis: our legitimate business interests)
- Personalizing Content and Experiences: Including to tailor content we send or display on our Sites and Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. (Legal basis: our legitimate business interests and/or with your consent)
- Advertising, Marketing and Promotional Purposes: Including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Sites and Services or information we think may interest you; and to administer promotions and contests. (Legal basis: our legitimate business interests and/or with your consent)
- Securing and Protecting Our Business: Including to protect and secure our business operations, assets, Sites, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct. (Legal basis: our legitimate business interests and/or compliance with laws)
- Defending our Legal Rights: Including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties. (Legal basis: our legitimate business interests and/or compliance with laws)
- Auditing, Reporting, Corporate Governance, and Internal Operations: Including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business. (Legal basis: our legitimate business interests and/or compliance with laws)
Who We Share Your Personal Data With
We do not share your personal data other than as described in this paragraph:
- Affiliates, service providers and processors - We engage third party companies, individuals and affiliated entities to facilitate our Sites and Services and to provide the Sites and Services on our behalf, to perform Sites- and Services-related services, to assist us in analyzing how our Sites and Services are used, and to provide data storage and other services. These third parties have access to your personal data only to perform specific tasks on our behalf and are obligated not to retain, disclose, sell or use your personal data for any other purpose.
- Third parties in case of legal requirement - We will also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law or breaches of security; to respond to any claims against us; and, to protect the rights, property, or safety of Lightbend, our customers, or the public.
- Third parties with consent - We will also disclose information about you, including personal data, to any other third parties, where you have expressly consented or requested that we do so.
- Third parties in case of a corporate transaction - In addition, your personal data may be disclosed as part of any merger, sale, reorganization, transfer of Lightbend's assets or businesses, acquisition, bankruptcy, or similar event.
In order to protect your personal data we have implemented reasonable, commercially acceptable security procedures and practices appropriate to the nature of the personal data we store, in order to protect it from unauthorized access, destruction, use, modification or disclosure. Your personal data is contained behind secured networks and is only accessible by a limited number of people, who have special access rights and are required to keep the personal data confidential.
Please keep in mind that no website or internet transmission is completely secure. Therefore, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe, such as closing your web browser when finished using the Sites.
Children Under The Age Of 16
Our Sites and Services are not directed to anyone under the age of 16, and we do not knowingly collect personal data from minors under the age of 16.
You can manage your preferences regarding third party ad company cookies deployed on our Site by using our cookie preference manager.
We will generally retain the personal data we processed through our Sites and Services for as long as it is required for purposes for which the data were collected. Unless we inform you otherwise, this will usually be the period of 3 years after the last interaction with you plus the length of any applicable statutory retention period following such activity.
Your personal data may be transferred to -and maintained on- computers located outside of your state, province, country or governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside the USA, please note that the personal data you provide (as described above under "What Personal Data Do We Collect") will be transferred to the USA, where the level of data protection may not be equivalent to the level of protection applicable at your location.
Where we are legally required to do so, transfers of personal data to parties outside the EU/EEA may be made pursuant to the European Commission-approved Standard Contractual Clauses or other legally acceptable mechanisms that ensure an adequate level of protection. Where applicable, you are entitled to receive a copy of the relevant contract (such as Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your personal data during such transfer.
How You Can Contact Us
Links To Other Websites
Changes To The Policy
Additional Information for Residents in Certain Jurisdictions
In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA. Importantly, this section also does not apply to our handling of customer data (including any personal information contained therein) that is uploaded to the Site or that is provided as part of the Service, where we are acting as a service provider or processor (depending on applicable privacy law).
A. California Privacy Disclosures
Personal Information under the California Consumer Privacy Act (CCPA). We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
California Privacy Rights. If you are a California resident, you have the right to:
- Request the deletion of your personal information that we collected;
- Opt-out of the sale of your personal information (if we sell it) Do Not Sell My Info;
- Request that we disclose information about our collection and use of your personal information over the past 12 months including:
- The specific pieces and categories of personal information we collected;
- What personal information we collect, use, disclose, or sell about you;
- The categories of sources of the personal information we collected about you; and
- Our business purpose for collecting or selling (if any) the personal information.
- For each category of personal information, request the categories of third parties to whom the personal information was disclosed or sold; and
- Be free from discriminatory adverse treatment for exercising these rights.
In order to protect your privacy and verify your request, we may require additional information from you. Please note that these rights are subject to certain exceptions under applicable law.
Instructions: You or your authorized agent can submit your request by emailing us at email@example.com, or calling us at 1-877-989-7372 (toll free). If you have questions or concerns about our privacy practices, you may contact us at firstname.lastname@example.org.
Categories of Personal Information Collected and Disclosed: The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the Purpose for using personal data section above.
|Personal Information Collected||May We Disclose this Information?||Categories of Third Parties to Whom We May Disclose this Information|
|Identifiers||Includes direct identifiers, such as name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers.||YES||
|Customer Records||Includes personal information, such as name, account name, user ID, contact information, education and employment information, payment information that individuals provide us in order to purchase or obtain our products and services.||YES||
|Commercial Information||Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.||YES||
|Audio, Video and Electronic Data||Includes audio, electronic, visual, thermal, olfactory, or similar information such as photographs and images (e.g., that you provide us) and call recordings (e.g., of customer support calls).||YES||
|Usage Data||Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other services, and our marketing emails and online ads.||YES||
|Professional information||Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).||YES||
|Education Information||Information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).||YES||
|Inferences||Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes.||YES||
Do We “Sell” Personal Information? Under the CCPA, a “sale” includes disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Websites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. As defined by the CCPA, we may “sell” Usage Data and Identifiers to third party advertising networks, social networks and data analytics providers. To opt of our sale of your personal information, you may click on Do Not Sell My Info.
Sources: We collect the above categories of personal data from the sources described in Sources of Personal Data We Collect (above) and for the purposes described in Purposes For Which We Use Personal Data (above).
Financial Incentives: We currently do not offer financial incentives to California residents related to use of personal information. If we make available certain programs or offerings that are considered “financial incentives” under the CCPA, we will provide you with a description of the material terms of such program(s) so that you may choose whether or not you would like to participate. We will not opt you in to any financial incentives without your prior consent, and you may subsequently opt out any anytime.
For any questions or concerns about our privacy policies or practices, you can contact email@example.com.
B. European Union (EU) / European Economic Area (EEA)
Residents of the EU and EEA have the following rights under the GDPR regarding their personal data. We will take steps in accordance with applicable legislation to keep your personal data accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified). You also have the right to request access to your personal data and to obtain a copy of it as well as additional information about the processing and to request us to erase the personal data we hold about you. In cases where we rely on your consent for using your personal data, you can withdraw such consent at any time by sending an email to: firstname.lastname@example.org.
The following rights apply in addition to the above to European residents:
- Right to restriction: you have the right to restrict the processing of your personal data, for example in case we no longer need your personal data in view of the initial purposes but they are required by us for the establishment, exercise of defence of legal claims.
- Right to object: you have the right to object to our processing of your personal data which is based on our legitimate interests. We will no longer process your personal data upon your request, unless we have compelling legitimate grounds for the continuation of the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You may also object to our use of your data for direct marketing purposes. To that end, you may also use the unsubscribe button provided for in every email we send.
- Right to data portability: under circumstances, you have the right to have your personal data transmitted to another data controller in a structured, commonly used and machine-readable format.
- Right to obtain a copy of personal data safeguards used for transfers outside your location: you can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms.
- Right to lodge a complaint: in case you have a question or complaint about how we process your personal data, you can send an email to email@example.com. It is also a possibility to lodge a complaint with a supervisory data protection authority.
- If you reside in France, you also have the right to issue directives relating to your digital legacy.
For further information regarding your rights, or to exercise any of your rights, please contact us at firstname.lastname@example.org or see section ‘How you can contact us’ for more details. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
C. Canadian Anti-Spam Legislation
If you are a Canadian resident we have the right to send you commercial electronic messages ("CEM's") under certain conditions. We are committed to ensuring that all applicable recipients of our CEM's receive them in a manner that is consistent with Canada's Anti-Spam Legislation. We will continue to send CEM's to applicable recipient in the following contexts:
- You have provided us with your email address directly without indicating a desire not to receive CEM's.
- You have published your email address online or otherwise.
- You have explicitly informed us (verbally or otherwise) that you are interested in continuing to receive CEM's.
- You have a business relations with us.
- A third-party with whom you may have an existing relationship has referred us to you.
In the event you no longer wish to receive CEM's from us, email us at email@example.com or reply to the electronic message / email address sent to you with the word "Unsubscribe", you may also use the unsubscribe button provided for in every email we send. Our CEM's also contain information on how to unsubscribe from receiving CEM's. Your request will be processed as soon as possible, and no later than ten (10) days after you send the request.