Privacy Policy

Effective date: 05/05/2021

  

Introduction

This privacy policy (“Privacy Policy”) applies to all visitors and users of the openreplay.com hosted services and websites (collectively, the “Website” or “Websites”) and self-managed installations, which are offered by Asayer SAS and/or any of its affiliates (“OpenReplay” or “we” or “us”). Please read this Privacy Policy carefully. By accessing or using any part of the Websites or self-managed installations, you acknowledge you have been informed of and consent to our practices with regard to your personal information and data.

OpenReplay is an open source project and collaborative community, as well as a company (Asayer, SAS). This means that many portions of our Websites, including information you voluntarily provide, will be public-facing for the open sharing of innovative developments, ideas, and information that makes our collaborative community so great. While we are committed to open sharing, we strive to respect the privacy of individual community members and will minimize the information we collect and share. If you do not want to share your information, including personally identifiable information, with other community members and the public, please be thoughtful as to how you interact with our Websites and what information you provide through the Websites (for example, through creating a GitHub public profile, project contributions, comments and blog posts).

Data Protection

Oversight of Data Security is handled by OpenReplay's respective Data Protection Officers. Should you wish to make modifications, deletions, or additions to any personal data you believe to be captured by OpenReplay, or if you have any general security concerns, please contact us at privacy@openreplay.com.

What Information OpenReplay Collects and Why

Information from Website Visitors

Like most website operators, OpenReplay collects basic non-personally-identifying information from Website visitors of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. We collect this information to better understand how visitors use the Website, to improve our Websites and experience for visitors, and to monitor the security of the Websites. We use Google Analytics to achieve that.

OpenReplay also collects potentially personally-identifying information like email and Internet Protocol (IP) addresses from visitors. OpenReplay does not use such information to identify or track individual visitors, however. We collect this information to understand how visitors use the Websites, improve performance and content, and to monitor the security of the Websites.

For logged-in users to OpenReplay Cloud offering, OpenReplay tracks potentially personally-identifiable user behavior through session replay using our own software, to help us reproduce and fix issues, and to understand how to make the website more useful for all.

OpenReplay may collect statistics about the behavior of visitors to our Websites. For instance, OpenReplay may reveal how many downloads a particular version got using aggregated statistics that contain anonymous user information only.

Usage Data Information from Self-managed OpenReplay Instances

OpenReplay collects information about usage from each self-managed OpenReplay instance (Community Edition and Enterprise Edition). It is possible to opt out of personally identifiable information being transferred, and for self-managed OpenReplay instances, we do not track your end users' at all. OpenReplay tracks the usage of these instances at an aggregate level - it is also possible to prevent this through modifying the code, which is made available to you.

Personally-Identifying Information

Users of the Websites may choose to interact with OpenReplay in ways that provide us with their personally-identifying information. In some instances, a User ID is generated for form and url tracking, page views, page pings and usage counts in order to ascertain product performance and development. The amount and type of information that OpenReplay gathers depends on the nature of your interaction with us, as well as the amount of information you choose to share. For example, we ask visitors who use our community slack group to provide a username and email address. We will also collect the information you provide with us in connection with creating an account on the Website. If you report a security vulnerability to OpenReplay and request public acknowledgement, then we may publicly disclose the personal information you provided to us in connection with the report, including your name to fulfill your request for acknowledgement. In each case, OpenReplay collects such personally-identifiable information only insofar as is necessary or appropriate to fulfill the purpose of the user’s interaction with or request of OpenReplay. We will not disclose personally-identifying information other than as described in this Privacy Policy.

Visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent you from engaging in certain Website-related activities or being able to access and use certain features and services.

Information OpenReplay Does Not Collect

OpenReplay does not intentionally collect sensitive personal information, such as social security numbers, credit card details, genetic data, health information, gender, race or religious information. Although OpenReplay does not request or intentionally collect any sensitive personal information, we realize that users might store this kind of information in an OpenReplay instance by pushing it to us through our plugins or API. If you store any sensitive personal information on OpenReplay’s servers, you are consenting to our storage of that information on our servers (hosted by Amazon AWS), which are located in the European Union (EU).

If you're a child under the age of 13, you may not have an account on the Website. OpenReplay does not knowingly collect information from or direct any of our Website or content specifically to children under 13. If we learn or have reason to suspect that a user is under the age of 13, we will close the child’s account.

Other countries may have different minimum age limits. If you are below the minimum age for providing consent for data collection in your country, you may not use OpenReplay.

Basis for Processing Your Information

Performance of a contract. The use of your information may be necessary to perform the contract that you have with us. For example, if you use our Websites to purchase OpenReplay product subscriptions or services, contribute to a project, create a profile, post and comment through our Websites, or request information through our Websites, we will use your information to carry out our obligation to complete and administer that contract or request.

Legitimate interests. We use your information for our legitimate interests, such as to provide you with the best content through our Websites and communications with users and the public, to improve and promote our products and services, and for administrative, security, fraud prevention and legal purposes.

Payment. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processor we work with is Stripe.

Support. The use of your information may be necessary for providing support. For example, if you face issues while using our Websites and request our help to fix the problems, we may use your information to carry out our obligation to fulfill your request.

Consent. We may rely on your consent to use your personal information for certain direct marketing purposes, such as sending you newsletter updates about OpenReplay products. You may withdraw your consent at any time through the unsubscribe feature provided with each marketing email or by contacting us at the addresses given at the end of this Privacy Policy.

How OpenReplay Uses and Protects Personally-Identifying Information

Sharing Your Information

OpenReplay only discloses potentially personally-identifying and personally-identifying information to those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process it on OpenReplay's behalf or to provide services available on the Website, and (ii) that have agreed not to disclose it to others.

OpenReplay will never rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors, and affiliated organizations, as described above, OpenReplay discloses potentially personally-identifying and personally-identifying information only when required to do so by law, or when OpenReplay believes in good faith that disclosure is reasonably necessary to protect the property or rights of OpenReplay, third parties, or the public at large.

OpenReplay takes measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.

OpenReplay at its sole discretion may make use of company logos where those companies are using the software that we provide. If you have concerns over the use of your logo, please email logos@openreplay.com.

International Transfer of Information

The Website is hosted in the European Union (EU) and information we collect will be stored and processed on our servers (hosted by Amazon AWS) in the European Union (EU). Our employees, contractors and affiliated organizations that process information for us as described above may be located in the European Union (EU) or in other countries outside of your home country; by using the Websites, you consent to the international transfer of your information by OpenReplay.

OpenReplay Communications with You

If you are a registered user of the Websites and have supplied your email address, OpenReplay may occasionally send you an email to tell you about security, system information, new features, solicit your feedback, or just keep you up to date with what's going on with OpenReplay and our products. We primarily use our blog to communicate this type of information, so we expect to keep this type of email to a minimum. There's an unsubscribe link located at the bottom of each of the marketing emails we send you so you can stop receiving such emails at any time.

If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish your request in order to help us clarify or respond to your request or to help us support other users. We will not publish your personally-identifiable information in connection with your request.

Cookies, Tracking Technologies and Do Not Track

Cookies

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. OpenReplay relies on cookies to help OpenReplay identify and track visitors, their user behavior and usage of the Websites, and their Website access preferences. OpenReplay visitors who do not wish to have cookies placed on their computers may set their browsers to refuse cookies before using the Websites. Disabling browser cookies may cause certain features of OpenReplay's websites to not function properly.

Certain pages on the Website may set other third party cookies. For example, we may embed content, such as videos, from another site that sets a cookie. These sites set their own cookies and we do not have access or control over these cookies. The use of cookies by third parties is not covered by our Privacy Policy.

Tracking Technologies

We may use third party tracking services, but we don’t use these services to track you individually or collect your personally identifiable-information. We may use these services to collect information about how the Website performs and how users navigate through and use the Website so we can monitor and improve our content and Website performance.

Third party tracking services gather certain simple, non-personally identifying information over time, such as your IP address, browser type, internet service provider, referring and exit pages, timestamp, and similar data about your use of the Website. We do not link this information to any of your personal information such as your user name.

Do Not Track

"Do Not Track" is a privacy preference you can set in your browser if you do not want online services to collect and share certain kinds of information about your online activity from third party tracking services. OpenReplay does not track your online browsing activity on other online services over time and we do not permit third-party services to track your activity on our site beyond our basic tracking, which you may opt out of. Because we do not share this kind of data with third party services or permit this kind of third party data collection for any of our users, and we do not track our users on third-party websites ourselves, we do not need to respond differently to an individual browser's Do Not Track setting.

Global Privacy Practices

Information we collect will be stored and processed in the European Union (EU) in accordance with this Privacy Policy but we understand that users from other countries may have different expectations and rights with regard to their privacy. For all Website visitors and users, no matter their country of location, we will:

  • provide clear methods of unambiguous, informed consent when we do collect your personal information;
  • only collect the minimum amount of personal data necessary for the purpose it is collected for, unless you choose to provide us more;
  • offer you simple methods of accessing, correcting, or deleting your information that we have collected, with the exception of information you voluntarily provide that is necessary to retain as is for the integrity of our project code as described further below; and
  • provide Website users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement.

If you are a resident of the European Union (EU) and European Economic Area (EEA), you are entitled to the following rights with regard to your personal information and data (GDPR):

  • Right of access to your personal data, to know what information about you we hold
  • Right to correct any incorrect or incomplete personal data about yourself that we hold
  • Right to restrict/suspend our processing of your personal data
  • Right to complain to a supervisory authority if you believe your privacy rights are being violated
  • Additional rights that may apply to you in certain instances:

    • Right of data portability (if our processing is based on consent and automated means)
    • Right to withdraw consent at any time (if processing is based on consent)
    • Right to object to processing (if processing is based on legitimate interests)
    • Right to object to processing of personal data for direct marketing purposes
    • Right of erasure of your personal data from our system (“right to be forgotten”) if certain grounds are met

    To exercise your privacy rights, you can email us at the address given below in the ‘Contacting OpenReplay About Your Privacy’ section of this Privacy Policy. Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.

    Data Retention and Deletion

    If you already have an account on the Websites, you may access, update, alter, or delete your basic user profile information by logging into your account and updating profile settings.

    OpenReplay will retain your information for as long as your account is active or as needed to perform our contractual obligations, provide you services through the Website, to comply with legal obligations, resolve disputes, preserve legal rights, or enforce our agreements.

    Please note that due to the open source nature of our products, services, and community, we may retain limited personally-identifiable information indefinitely in order to ensure transactional integrity and nonrepudiation. For example, if you provide your information in connection with a blog post, GitHub issue or comment, we may display that information even if you have deleted your account as we do not automatically delete community posts. Also, as described in our Terms of Use, if you contribute to an OpenReplay project and provide your personal information in connection with that contribution, that information (including your name) will be embedded and publicly displayed with your contribution and we will not be able to delete or erase it because doing so would break the project code.

    Contacting OpenReplay About Your Privacy

    If you have questions or concerns about the way we are handling your information, or would like to exercise your privacy rights, please email us with the subject line "Privacy Concern" at privacy@openreplay.com.

    We will respond within 30 days of receiving your message at the latest but please note for promptest response, we recommend emailing us.

    Privacy Policy Changes

    Although most changes are likely to be minor, OpenReplay may change its privacy policy from time to time, and in OpenReplay's sole discretion.

    We may also provide notification to users who have provided us email addresses of material changes to this Privacy Policy through our Website. OpenReplay encourages visitors to frequently check this page for any minor changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

    Credit to GitLab for the initial wording of the above policy.