CircleCI のプライバシー ポリシー
Last Updated: June 16, 2022
While providing our Service, we may collect information about our customers’ Users on behalf of our customers. Our use of information on behalf of our customers is governed by our agreement with the applicable customer and the customer’s own privacy policies. We cannot control and are not responsible for the privacy policies or privacy practices of our customers or any other third parties.
Information We Collect And How We Use It
Collection of Information
We have collected the following categories of information from our users within the last twelve (12) months:
- Identifiers, including name, email address, phone number, IP address and cookie identifiers,
- Certain financial-related information, including credit card number and billing and shipping address,
- Protected classification information, such as age and gender,
- Commercial information, including purchasing history of our business customer’s employees and representatives who use our Service,
- Internet or other similar network activity, such as browsing history, information on your interaction with our Website, browser type, and referring site,
- Location data, and
- Professional or employment related data with respect to our job applicants and our business customer’s employees and representatives who use our Service, such as professional title.
Categories of Sources
We obtain the personal information of our users from the following categories of sources:
I. Personal Data That You Provide To Us
When you interact with the Website or the Service, CircleCI may gather information that, alone or in combination with other information, could be used to identify you (“Personal Data”), as described below. If you are an EU data subject, please see the “EU Data Subject” section below for information on your rights in relation to the Personal Data we hold about you.
a) Personal Data used to provide the Service and respond to requests
When users sign up for the Service, users are required to authenticate with their version control system identity (GitHub or Bitbucket). When users log in to the Service using sign-in services such as OAuth (for example, login with a GitHub account), these services will authenticate a user’s identity and provide the user with the option to share certain Personal Data, such as name and email address(es), with us. If you purchase one of our paid plans, we will also collect payment and billing information such as credit card details and billing address. We use this data to provide you with access to the Service and/or the Website, contact you regarding your access and use of the Service and/or the Website or to notify you of important changes to the Service. For EU data subjects, such use is necessary for the performance of the contract between you and us.
On some sections of the Website, you may complete a web form to give your Personal Data to us directly, such as on our “Contact Us” page. We also collect Personal Data (such as your name and contact details, such as your email and phone number) when you request information, including a product demo, ask to download content (such as white papers), register for a webinar or other event, or subscribe to email lists. We will use your contact information to respond to your request. For EU data subjects, such use is necessary to respond to or implement your request. If you send us a request or question regarding the use of the Service (for example via a support email or via one of our feedback mechanisms), we may publish it (in anonymous form only) in order to help us clarify or respond to your request or to help us support other users.
CircleCI collects Personal Data that you provide through the Service only insofar as is necessary or appropriate to fulfill the purpose of your interaction with CircleCI, such as providing you with the Service and/or answering any requests regarding the Service as described above. You can always refuse to supply Personal Data, however doing so may prevent you from accessing the Service or engaging in certain activities on the Website or the Service.
b) Personal Data used to process applications for employment
When you submit a job application through the Website, we will collect your resume and any additional information that you elect to provide to us, including but not limited to employment history and education. We will use your contact details and data about your employment history and education to conduct job interviews, evaluate your application, and as is otherwise needed for recruitment. For EU data subjects, this use is necessary to respond to your request to process your application for employment.
c) Personal Data used for marketing
We will use your email to tell you about your Service usage, new features, solicit your feedback, or just keep you up to date with what’s going on with CircleCI and our products, upcoming events or other promotions. If you change your mind about receiving information from us or about the use of information volunteered by you, please send us a request specifying your new choice. Please contact us as specified under the “Contact Us” section. You may also choose to opt out of receiving such emails by following the unsubscribe instructions included in these emails, or by accessing the email preferences in your account settings page. If you download content from the Website, we may also use your phone number to contact you directly by phone, in connection with such new products and services, upcoming events or other promotions.
Where required by applicable law (for example, if you are an EU data subject), we will only send you marketing information by email or mail, or contact you by phone, if you consent to us doing so. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you. In addition, if at any time you do not wish to receive future marketing communications or wish to have your name deleted from our mailing or calling lists, please click on the “Take Control” button at https://privacy.circleci.com/. Please note that if you opt out from marketing communications, we may still contact you regarding issues related to our Service and to respond to your requests.
II. Automatically Collected Information
Like most hosted service operators, CircleCI collects information 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 and store it in log files. CircleCI also collects Internet Protocol (“IP”) addresses, which can be used to identify the location from which your computer is connecting to the Website, for providing the Service and for support purposes.
Use of such automatically collected information is necessary for the performance of the contract between you and us, to the extent we process information that is needed for providing the Service and for support purposes, or is in our legitimate interest in understanding how the Service is being used by you and enhancing your experience on our Website and on the Service.
III. Information We Process On Behalf Of Our Customers
In providing the Service to our customers, we process on behalf of customers certain information that may include Personal Data, relating to customers’ employees, contractors or other users (“Users”) they transmit or otherwise submit to our Service. While our customers or Users decide what data to submit, this information typically includes email address and information relating to tests results.
CircleCI collects, aggregates, and stores metrics and data relating to, generated by, provided in connection with, or derived from customers’ use of the Service (“Usage Data”) in order to provide, maintain, support, enhance, develop and improve the Service and CircleCI’s service offerings. CircleCI will not disclose individual metric or usage data other than in an aggregated and de-identified form. For EU data subjects, this use of your Personal Data is necessary for our legitimate interests in understanding how the Service is being used by you and to improve your experience on it.
Bulletin Boards/Chat Rooms
If you submit a post or participate in a discussion on a bulletin board or chat room on the Website or the Service, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Data you choose to submit in these forums.
Disclosure Of Personal Data
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Certain financial-related information,
- Protected classification information,
- Commercial information,
- Internet or other similar network activity,
- Location data, and
- Professional or employment related data.
CircleCI may also disclose Personal Data when required to do so by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or when CircleCI believes in good faith that disclosure is reasonably necessary to protect the property or rights of CircleCI, third parties, or the public at large.
In the preceding twelve (12) months, we have not sold our users’ personal information.
Access and Deletion Requests
You may click on the “Take Control” button at https://privacy.circleci.com/ to request that we provide you with a copy of your personal information or that we delete your personal information that we maintain on our systems. We will respond to your request within a reasonable timeframe. If you are an EU data subject or California resident, see your additional rights below.
Rights of Certain California Residents
The California Consumer Privacy Act (CCPA) provides certain California residents with the additional rights listed below. The CCPA temporarily exempts from these CCPA rights certain personal information reflecting a written or verbal business-to-business communication or transaction as well as data about CircleCI’s employees, job applicants, contractors, controlling owners, directors, officers and medical staff (if any) in their capacities as such individuals at CircleCI.
Right to Access. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you,
- The categories of sources for the personal information we collected about you,
- Our business or commercial purpose for collecting that personal information,
- The categories of third parties with whom we share that personal information, and
- The specific pieces of personal information we collected about you (which will also allow you to exercise your data portability right).
Data Portability Right. You have the right request that we provide you with access to the information above (under Right to Access) in a readily useable format that allows you to transmit (i.e., port) the information to another entity without hindrance. If you make a request under your right to request access, you will receive access to your information in a readily useable format.
Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. You must contact the applicable business customers directly to delete your information that they have in their systems.
We may deny your deletion request or not delete some of your personal information, if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We may also limit our deletion to the extent permitted by applicable law.
Exercising Your Rights. To exercise your rights, please contact us as follows:
- Submit your request by visiting our Privacy Center at https://privacy.circleci.com/ and clicking on the “Take Control” button where you can select your specific request (e.g., right to access, right to portability, or right to delete); or
- Email us at email@example.com and provide the following information:
- Full name and email address associated with your use of our Service, and
- Your specific request (e.g., right to access, right to portability, or right to delete).
We will attempt to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
- Deny you goods or services,
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties,
- Provide you a different level or quality of goods or services, or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value to CircleCI and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We currently do not provide any financial incentives.
EU Data Subjects
Scope: This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein, Norway and, where applicable, Switzerland).
Data Controller: CircleCI is the data controller of Personal Data provided to, or collected by or for, our Website and the Service, but we may act as data processor on behalf of our customers for Personal Data that we process on their behalf when providing the Service.
Your Rights: Subject to applicable law, you have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies of the data, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so if we are processing your Personal Data for direct marketing and otherwise. However, if we are relying on a legitimate interest to process your Personal Data and we demonstrate compelling legitimate grounds for the processing we may continue.
- Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, that produce a significant legal effect on you, unless such profiling in necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent.
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to unsubscribe.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by visiting our Privacy Center at https://privacy.circleci.com/ and clicking on the “Take Control” button where you can select your specific request (e.g., right of access, right to erasure, etc.).
International Data Transfers from Europe
Your personal information may be transferred to CircleCI and its service providers in countries other than the country in which you are resident, including in the United States, and other locations where we have offices or employees. These countries may have data protection laws that are different from the laws of your country and may not provide the same level of protection as your country.
If you are located in the European Economic Area, the UK or Switzerland, we will protect your personal information when it is transferred outside of your jurisdiction by (a) processing it in a territory that provides an adequate level of protection based on its data protection laws; or (b) implementing appropriate safeguards to protect your personal information, such as relying on the European standard contractual clauses. CircleCI currently relies on these European standard contractual clauses (“Model Clauses”) for data transfers.
Privacy Shield Notice
As of July 16, 2020, the European Court of Justice issued a judgement declaring Privacy Shield invalid. CircleCI now relies on other transfer mechanisms, such as the Model Clauses described above, for the cross-border transfer of data.
Prior to the invalidation of Privacy Shield, we relied on our Privacy Shield certification to transfer Personal Data and other information that we receive from the EU and Switzerland to CircleCI in the U.S. As noted above, we currently rely on the Model Clauses.
We process this data in accordance with the Privacy Shield Principles of Notice and Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (“Privacy Shield Principles”), as described below.
Accountability for Onward Transfers: We may be accountable for the Personal Data we receive under the Privacy Shield that we may transfer to third-party service providers (as described in the “Disclosure of Personal Data” section above) if they process Personal Data in a manner inconsistent with the Privacy Shield Principles and we are responsible if they do so and for the harm caused.
Access: You have certain rights to access, correct, amend, or delete Personal Data where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. When we process Personal Data on behalf of our customers, the customer will be responsible to respond to requests for exercising your rights. We honor all customers’ requests from their Users to access, correct, amend, or delete Personal Data.
- Email: firstname.lastname@example.org
- Phone: +1-800-585-7075
- Postal Mail:
Circle Internet Services, Inc.
201 Spear Street, Ste 1200
San Francisco, CA, 94105
CircleCI has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If your complaint is not resolved through these channels, under certain conditions a binding arbitration option may be available before a Privacy Shield Panel. For additional information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CircleCI at:
CircleCI has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Personal Data received or transferred pursuant to the Frameworks.
Links to Other Websites
CircleCI, with its partnership and commitment to Security and Privacy with Microsoft, also provides a link to their Privacy Statement .
Social Media Widgets
Do Not Track
Currently, various browsers - including Microsoft Edge, Firefox, and Safari - offer a “do not track” or “DNT” option that relies on technology known as a DNT header, which sends a signal to the websites visited by the user about the user’s browsers DNT preference setting. CircleCI does not currently commit to responding to browser’s DNT preference across its Sites and Services, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. CircleCI takes privacy and choices regarding privacy seriously and will make efforts to continue to monitor the development around DNT browser technology and the implementation of a standard for DNT.
We take precautions to ensure the security of your Personal Data. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and once we receive it. When you enter your login information on the Service, all information to and from the service is encrypted using Transport Layer Security (TLS). For more information on our data security policies, please check here.
That said, like any hosted service provider, we cannot guarantee that unauthorized third parties or unauthorized personnel will not gain access to your Personal Data despite our efforts. You should note that in using the Website and the Service, your information will travel through third-party infrastructures which are not under our control.
If you have any questions about security on the Website or the Service, you can contact us.
If you wish to make a request regarding your personal information, please visit our Privacy Center at https://privacy.circleci.com/ and click on the “Take Control” button where you can select your specific request.
Circle Internet Services, Inc.
201 Spear Street, Ste 1200
San Francisco, CA, 94105