Your privacy
is fundamental

Who We Are and What This Policy Covers

This Privacy Policy applies to information collected by Terrateam B.V., trading under the name Stategraph (hereinafter "Stategraph"), when any party uses the following services:

• Our websites
  • https://stategraph.com/
  • https://app.stategraph.cloud/
• Our other Stategraph products, services, and features that are available on or through our websites, including Stategraph Cloud, Stategraph Self-Hosted, and Stategraph BYOC

This Privacy Policy describes how Stategraph handles personal information as a controller. Where Stategraph processes personal information on behalf of a customer as a processor (for example, personal data stored in Stategraph Cloud or in a Stategraph BYOC deployment), our processing is governed by the data processing terms in our Terms of Service and any applicable Master Services Agreement, not by this Privacy Policy.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect information primarily from four sources: if and when you provide information to us, automatically through operating our websites, automatically through operating the Software we provide to you ("Service Data"), and from outside sources.

Information You Provide To Us

We collect information that you provide to us directly. Here are some examples:

• Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Stategraph account to provide an email address and password, along with a username or name. We reserve the right to request additional information that Stategraph deems necessary to administer your account.
• Payment and contact information: If you buy something from us, we'll collect information to process those payments and contact you including, but not limited to: your name, billing address, payment instrument details (processed by our payment processor), and contact information. We also keep a record of the purchases you've made. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
• Communications with us: You may also provide us with information when you respond to surveys, communicate with our staff about a support question, sign up for a newsletter, apply to our design partner program, or participate in product feedback sessions. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).

Information We Collect Automatically From Our Websites

We also collect some information automatically when you use our websites:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
• Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Stategraph uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to measure the performance of our marketing.

Service Data Collected from the Software

When you run the Software (whether on Stategraph Self-Hosted, Stategraph Cloud, or Stategraph BYOC), the Software collects and transmits to Stategraph certain operational metadata that we call Service Data. Service Data includes:

• BIU counts (the number and class of billable infrastructure units the Software is managing);
• Version, build, and configuration information about the Software;
• License and entitlement information;
• Error reports, performance metrics, and crash diagnostics;
• Aggregate usage statistics about how the Software is used (for example, which commands or APIs are invoked, how frequently, and with what latency); and
• Identifiers for the deployment and, in connection with paid Plans, the customer organization.

Service Data does not include:

• Customer Content (such as Terraform state, plans, HCL, resource names, or resource attributes);
• Cloud provider credentials, API tokens, or secrets;
• The contents of variables, locals, or outputs in your Terraform configurations.

Where personal data appears in Service Data, it is typically limited to identifiers such as deployment IDs, organization identifiers, and the names or email addresses of the users who administer the Software. We process Service Data as a controller for the legitimate business purposes described under How and Why We Use Information below.

For Stategraph Self-Hosted deployments on the Enterprise Plan, and for Stategraph BYOC deployments, Customer may elect air-gapped operation. In air-gapped operation:

• For Self-Hosted, no Service Data is transmitted to Stategraph; BIU counts and license attestations are instead provided by Customer on a quarterly basis.
• For BYOC, no Service Data is transmitted to Stategraph endpoints outside Customer's cloud provider account; Stategraph obtains BIU counts and operational metrics through its control-plane access to the deployment within Customer's cloud provider account.

Information From Outside Sources

We may receive information about you from third parties, for example, from publicly available sources such as business directories and professional networking sites, from event organizers or partners when you engage with us at industry events, and from referrers who introduce you to us.

How and Why We Use Information

We use information about you for the purposes listed below:

• To provide our services. For example, to set up and maintain your account, provide customer service, process payments and orders, verify user information, meter BIU consumption, validate license entitlements, deliver software updates, and respond to support requests.
• To secure our services and our customers. For example, to detect, investigate, and respond to security incidents, fraud, abuse, and breaches of our Terms of Service.
• To improve our services. For example, by analyzing Service Data to identify performance bottlenecks, prioritize features, detect bugs, and measure the effectiveness of changes to the Software.
• To market our services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular Plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a paid Plan after receiving a marketing message), and understanding and forecasting user retention.
• To fix problems with our services. For example, by monitoring, debugging, repairing, and preventing issues.
• To customize the user experience. For example, to personalize your experience by serving you relevant notifications and product communications.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Stategraph. If you don't want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we'll still send you important updates relating to your account, security, and license.)
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

Legal Bases For Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

1. The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device, charge you for a paid Plan, or operate the Software you have licensed from us; or

2. The use is necessary for compliance with a legal obligation; or

3. The use is necessary in order to protect your vital interests or those of another person; or

4. We have a legitimate interest in using your information — for example, to provide and update our Services; to meter BIU consumption and enforce license entitlements; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our marketing; to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or

5. You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on, as described in our cookie policy.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy.

• Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you. This includes vendors that help us provide our Services to you (for example, our cloud hosting provider for Stategraph Cloud, payment processors that process your billing information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer support tools that help us communicate with you), vendors that assist us with our marketing efforts, vendors that help us understand and enhance our Services (like analytics providers), vendors that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams), and other third-party tools that help us manage operations. Notably, Stategraph Cloud is hosted in the United States via Northflank Inc. as our cloud platform sub-processor. We require vendors to agree to privacy commitments in order to share information with them.
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
• To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Stategraph, third parties, or the public at large.
• Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Stategraph goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
• With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
• Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

We have a long-standing policy that we do not sell our users' data. We aren't a data broker, we don't sell your personal information to data brokers, and we don't sell your information to other companies that want to spam you with marketing emails.

How Long We Keep Information

We generally discard information about you when it's no longer needed for the purposes for which we collect and use it. Service Data is generally retained for as long as you have an active subscription with us plus a reasonable period thereafter to support license reconciliation, audit, and security investigations. Aggregated and de-identified data may be retained for longer periods.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

• Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
• Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account, security, license entitlements, and legal notices.
• Set your browser to reject cookies.
• Elect air-gapped operation: For Stategraph Self-Hosted (Enterprise Plan) and Stategraph BYOC deployments, you may elect air-gapped operation to limit or eliminate Service Data transmitted to Stategraph, as described under Service Data Collected from the Software above.
• Close your account.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (the "GDPR"), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority. In the Netherlands, the relevant authority is the Autoriteit Persoonsgegevens.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act ("CCPA") requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);
• Commercial information (your billing information and purchase history, for example);
• Internet or other electronic network activity information (such as your usage of our Services and Service Data from the Software);
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Professional or employment-related information (for example, your company and team information); and
• Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above. We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

• Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
• Request deletion of personal information we collect or maintain;
• Opt out of any sale of personal information; and
• Not receive discriminatory treatment for exercising your rights under the CCPA.

How To Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us via privacy@stategraph.com.

Other Things You Should Know

Transferring Information

Stategraph is based in the Netherlands, and Stategraph Cloud is hosted in the United States. The information about you that we process when you use the Services may therefore be used, stored, and accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors and sub-processors, including in the United States.

When we transfer personal information from the EEA, the United Kingdom, or Switzerland to countries that have not received an adequacy decision, we rely on one or more of the following safeguards:

• The European Commission's standard contractual clauses (SCCs), supplemented where appropriate by additional technical and organizational measures;
• The EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data Privacy Framework, where the recipient is certified under those frameworks;
• Your explicit consent, where applicable; or
• Other appropriate safeguards permitted by applicable data protection law.

For Stategraph Cloud customers in the EEA who require their Content to remain within the EEA, Stategraph BYOC offers deployment within a cloud account of the customer's choosing in any region supported by their cloud provider. You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Privacy Policy Changes

Although most changes are likely to be minor, Stategraph may change its Privacy Policy from time to time. Stategraph encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by email or via a notice on our website. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Translation

Our Privacy Policy was originally written in English (US). We may translate it into other languages. In the event of a conflict between a translated version of our Privacy Policy and the English version, the English version will control.