September 21, 2022
Please read this policy carefully before using our website or the Snyk Platform.
This Policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. It applies to those visiting our website https://www.snyk.io or using the Snyk platform (together, the “Platform”).
This Policy is provided in a layered format so you can click through to the specific areas set out below.
Information we may collect from you
Legal Basis for our processing personal data
Disclosure of your information
Where we store your personal data
For the purpose of the relevant data protection legislation, the data controller is Snyk Limited of Highlands House, Basingstoke Road, Spencers Wood, Reading, Berkshire, RG7 1NT United Kingdom (“Snyk”, “us”, “our” or “we”), or (if you have entered into an agreement with another Snyk entity) that Snyk entity. Our ICO Registration Number is: ZA232876.
Please note that this Policy does not apply to, or limit, our use or disclosure of non-personal information (i.e. information which is not relevant to you or able to identify you) we may collect from you via your use of the Platform.
Information we may collect from you
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on our Platform, when you log in to the Platform, or by corresponding with us by phone, e-mail, chat, or otherwise. This includes (but is not limited to) information you provide when you use our service and when you report a problem with our Platform or the services available on it. The information you give us will depend on the circumstances but, as you are giving it to us, you will always know what information we are receiving. We may keep a record of that correspondence or information in accordance with our Data Deletion and Retention Policy in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management, or otherwise as may be required by law.
Please note that we do not collect payment information from you. This will be collected directly from you by our third-party payment processor.
Information we collect about you. We may collect the following information about you:
your contact details (phone number, address, email address).
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); webpage identifier; what you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), metadata information about the payload and page; analytical data; information about the DOM and mutation events; comments you choose to publicly provide; and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources.
We may receive information from the third-party authentication provider about you, including your GitHub, Bitbucket, Google, or Docker username and your email address. We are also working closely with other third parties (including, for example, business partners, service providers, sub-contractors in technical and payment services, advertising networks, analytics providers, search information providers and recruitment agencies) and may receive information about you from them. If you use the Platform while working for one of our customers, we will receive information (such as your email address, to create an account for you) from that customer. If you work for an organization, we may receive your name and contact details from partners who identify for us potential customers for our services (including attendees at events we sponsor).
Uses made of the information
We use information held about you in the following ways:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to provide customer support;
to personalize your experience;
to contact you about your account;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
to provide you with our newsletter, security best practices and updates about our Platform;
to provide you with information about goods or services we feel may interest you;
to notify you about changes to our services;
to administer our Platform and our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our Platform and our services and to ensure that content is presented in the most effective manner for you and for your computer or mobile device; and
as part of our efforts to keep our Platform safe and secure.
If you no longer wish to receive our newsletters, product updates, or other marketing communications, you may unsubscribe from them at any time by going to: https://preferences.snyk.io/dont_sell
Legal Basis for our processing personal data
We rely upon the following legal grounds as a basis for processing your personal data.
Performing our obligations under a contract with you, or making pre-contract arrangements with you.
Legal and regulatory compliance.
Our legitimate business interests, and those of our customers. We rely on our legitimate business interests, and those of our customers, to process your personal data. For example, we have a legitimate interest in providing and improving the Snyk service; maintaining and improving the security and integrity of our Platform; minimizing claims and financial losses of us, and our customers; promoting the Platform and our services and brand; research and analytics; and sharing information with our service providers who help power our operations.
In some cases where we send you promotional material by email we obtain your consent as a legal basis to processing your personal data.
Disclosure of your information
We may share your information with the following, selected third parties:
business partners, service providers and sub-contractors for the performance of any contract we enter into with them or you;
service providers acting as processors who provide IT, customer management, recruitment administration and system administration services;
analytics and search engine providers that assist us in the improvement and optimization of our Platform.
We may disclose your personal data to certain third parties in the following circumstances:
if we have your permission to do so;
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may access and use your personal data;
other companies in our Snyk group of companies;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the terms applicable to the Snyk service and any other documents referred to in them; or to protect the rights, property, or safety of Snyk, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
To third parties to market their products or services to you if you have consented. We contractually require these third parties to keep personal data confidential and use it only for the purposes for which we disclose it to them.
Where we store your personal data
All information you provide to us is stored on our secure servers or those of our service providers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.
Snyk is an international business. Your personal data may be shared with our affiliated companies and certain third parties who are based outside the UK and the European Economic Area (“EEA”), including in the United States of America. Any processing of your personal data by these parties will involve an export of your personal data outside the UK and the EEA. These other countries may have data protection rules that are different from your own country. We endeavour to ensure that people to whom we provide your personal data hold it subject to appropriate safeguards and controls.
Whenever we transfer your personal data out of the UK and EEA, we will ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government from time to time. For further details, see here.
We may transfer your Personal Data to countries that have not been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government – provided that, in these cases:
we may use specific appropriate safeguards approved by the European Commission and the UK Government, which are designed to give personal data the same protection it has in the EEA/UK (for example, requiring the recipient of personal data to enter into the relevant form of the so-called ‘Standard Contractual Clauses’ issued or approved from time to time); or
in very limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
Please contact us at Privacy@snyk.io if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a dispute in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please contact us at email@example.com or https://preferences.snyk.io/privacy.
If you would like to exercise your data privacy rights as applicable to your location of residence, please follow this link https://preferences.snyk.io/privacy and for Do-Not-Sell requests, the following link https://preferences.snyk.io/dont_sell.
To remove your account from app.snyk.io please follow the steps in this guide, “How Can I Delete my Account?”
If you are needing to contact legal/DPO - email firstname.lastname@example.org.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at email@example.com.
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Snyk has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You may contact EDPO regarding matters pertaining to the GDPR:
by using EDPO’s online request form: https://edpo.com/gdpr-data-request/, or
by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
Stopping Use of the Platform
If you want to stop using the Platform and the Snyk services, you may do so. If you do, you may also want to remove any cookies that we have placed on any device used to access the Platform and the Snyk services.
Third Party Platforms
Our Platform may, from time to time, contain links to and from the websites operated by third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.