Last updated: May 19th, 2023
The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise we never sell your data: never have, never will.
This policy is split into sections. For your convenience, links to each of those sections is as follows:
- What we collect and why
- When we access or disclose your information
- Your rights with respect to your information
- How we secure your data
- What happens when you delete content in your product accounts
- Data retention
- Location of site and data
- When transferring personal data from the EU
- Changes & questions
This policy applies to all products built and maintained by Pijul OÜ (“Pijul”), including all versions of The Nest.
This policy applies to our handling of information about site visitors, prospective customers, and customers and authorised users (in relation to their procurement of the services and management of their relationship with Pijul OÜ). We refer collectively to these categories of individuals as “you” throughout this policy.
If you are a California resident, please click here to see our California Notice at Collection, which includes additional disclosures as required by California law.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for a Pijul product, we ask for identifying information such as your email address, and maybe a company name. That’s so you can personalise your new account, and we can send you product updates and other essential information.
We also give you the option to add a profile picture that displays in the Nest.
We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.
If you sign up for a paid Pijul product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit Pijul servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.
We store on our servers the content that you upload or receive or maintain in your Nest accounts. This is so you can use our products as intended, for example, to create repositories or to contribute to other projects in The Nest. We keep this content as long as your account is active. If you delete your account, we will pseudonymise your comments on discussions within 24 hours and we will delete the other content within 60 days.
General Geolocation data
For the Nest, we log the full IP address used to sign up a product account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active.
We use persistent first-party cookies for the sake of authentication, and temporary cookies (with time to live of at most two minutes) for the proper functioning of our services.
When you email Pijul with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.
When we access or disclose your information
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.
Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.
When required under applicable law. Pijul OÜ is an Estonian company, subject to Estonian and European rules and laws.
Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. It is Pijul’s policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.
If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.
Your rights with respect to your information
At Pijul, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To Be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfilment of some data deletion requests may prevent you from using Pijul services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed. (Again: we never have and never will sell nor share your personal data.)
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party. If you want to export data from your accounts, you can contact firstname.lastname@example.org.
- Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.
In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at email@example.com. If an authorised agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.
How we secure your data
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. In addition, we go to great lengths to secure your data at rest. Most data are not encrypted while they live in our database (since they need to be ready to send to you when you need them).
What happens when you delete content in your accounts
In the Nest, we give you the option to trash content. Anything you trash in your product accounts will become unavailable. The trashed content cannot be accessed via the application and we are not able to retrieve it for you.
If you choose to cancel your account, your content will become immediately inaccessible and should be purged from our systems in full within 60 days, with the exception of content contributed to other projects, when necessary for the correct function of these projects. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts.
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. Through this policy, we have provided specific retention periods for certain types of information.
Location of site and data
Our products and other web properties are operated on a globally-replicated infrastructure. If you are located in the European Union, UK, please be aware that any information you provide to us will be transferred to and stored in multiple places, including outside of the EU or UK. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.
When transferring personal data from the EU
The European Data Protection Board (EDPB) has issued guidance that personal data transferred out of the EU must be treated with the same level of protection that is granted under EU privacy law. UK law provides similar safeguards for UK user data that is transferred out of the UK. Since the data handled by Pijul is stored on Cloudflare’s infrastructure, including on a global, distributed database, data produced in the EU or UK may be replicated elsewhere. See Cloudflare’s DPA for more information. Moreover, we use Amazon Web Services to send our emails, see the AWS DPA.
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.
Adapted from the Basecamp open-source policies / CC BY 4.0.