Effective November 7, 2018. Document History
This Policy applies to all of Balsamiq websites, products and services, and any point of contact you might have with Balsamiq.
We define the following as our "Online Services":
We define the following as our "Licensed Products":
This document is a sister-document to our EULAs & Terms of Service documents. Please make sure you read both carefully before accessing or using a Balsamiq Online Service or Licensed Product.
We have made a commitment to be good citizens. We consider protecting and respecting your personal information as an essential part of that responsibility.
Our business model is a very traditional one: we provide products and services, and customers pay us for them. In other words, you are the customer, NOT the product.
Balsamiq is a small multi-national organization, based in Italy and the USA. We've been around since 2008 and are bootstrapped, profitable, and aim for longevity over growth. We believe in forming long-term relationships with our customers, our employees, and our communities. It all starts with trust.
Our Italian company (which does Research and Software Development) is Balsamiq SRL. Our tax identification number (P.IVA and C.F) is IT-02921031205.
Our American company (which primarily does Sales and Marketing) is Balsamiq Studios, LLC. Our Federal Tax Identification Number (EIN) is 26-2200095.
Balsamiq SRL fully owns Balsamiq Studios, LLC, and both are run by our founder and CEO Giacomo Guilizzoni (firstname.lastname@example.org).
In GDPR terminology, our two companies act as joint controllers, with main EU establishment in Italy.
Below is a complete description of data we collect, and what we do with the data. If it's not listed here or in our EULA or Terms of Service, we don't do it.
We call data that identifies — or that could reasonably be used to identify — you as an individual as "Personal Data."
This data includes:
You can find detailed information on how we keep your data safe in our Information Security page.
When purchasing directly from Balsamiq we collect data from you in order to complete the transaction and provide you access to our Online Service or Licensed Product. To make it as secure as possible, your credit card information (including number, expiration date and CVC security code) is sent securely to our payment processor directly from your browser. The processor validates it and sends us a validation code we can use to finish the purchase.
In the case of our Subscription Services (Balsamiq Cloud, Balsamiq Wireframes for Google Drive, and myBalsamiq) the processor stores your credit card information as well as your billing contact information in order to process your monthly or annual automatic renewals, or to allow you to upgrade or downgrade your subscription without re-entering a credit card number.
We never have access to, nor store your full credit card information.
The payment processor code we use also sets a cookie in your browser, to remember your info for future purchases. You can delete or block that cookie if you wish; our website will continue to work.
We require you to enter your billing information. This data, as well as the last four digits of your credit card which is sent to us by our payment processor, is stored in our transaction database (which we call "Olio") in order to maintain our financial records. This information appears on your invoice, which can be accessed by anyone who has been sent the url link to your invoice. We make the invoice links purposefully long and hard to guess for added security, and we prevent search engines from indexing them.
We automatically email the public invoice link following the purchase to the email address(es) you have provided.
The history of changes to the billing contact information on the invoice made by you or our team are logged and stored in Olio.
As part of purchasing a License Product directly from us (Balsamiq for Desktop or Atlassian Server Apps), you are requested to enter a License Name. This is usually a company name, but sometimes an individual's name is entered. This name is kept in Olio to maintain accurate purchase records.
If we have issued you a free license or a trial license extension via email, we will have saved your email address in Olio along with the License Name we issued, which may be in a company or individual's name, depending on the case. We keep this data to track the software we have given out.
Subscription Service records may include more than one billing contact. These email addresses and related billing contact information can be updated at any time and the history of changes are logged in Olio.
Lastly, if you have purchased one of our Atlassian Apps for Jira or Confluence directly from the Atlassian Marketplace, Atlassian has offered us access to the billing records for purchases of our app. We import this data into Olio which includes limited Personal Data such as the technical and billing contacts' email address and names. This information is used to offer better support to customers by having all purchase records together, as well as for our accounting purposes. Data from Atlassian includes purchase price, but not details on the payment method.
The data we collect in Olio, including Personal Data, is not shared with third parties, except for the purposes of determining the validity of a payment. In this case we may share the name and email address associated with the purchase with the credit card holder, your company’s accounting department, or with our payment processor when responding to a chargeback.
We only send emails to the email addresses we collect in Olio to communicate account activity such as purchase confirmation and subscription status (renewal, cancellation, etc.).
When we store passwords, we never store them in the clear. No-one can see them. We either save them in our database using best-practice cryptographic hashing, or go through a 3rd party authentication provider (see below).
It is your sole responsibility to keep your user name, password, and other sensitive information confidential. If you become aware of any unauthorized use of your account or any other breach of security, you must notify Balsamiq immediately.
If you forget your password, we send you a secure link via email that lets you reset it.
Balsamiq staff will never change a password for you, nor change the Owners (as defined in the Terms of Service) or Billing Administrators. Please refer to our documentation to learn how to assign or revoke these roles yourself.
For our Online Services that have the concept of a "User Account", we store your name, email address, and if you upload it, a photo to use as your avatar.
We use this information to identify you as a user of the Online Service.
Our Licensed Products do not "call home", nor transmit any data to our servers.
The only Personal Data we store for License Products is related to the purchase transaction as described above.
If you send us an email to an address that ends in '@balsamiq.com', or use one of the online forms on our website balsamiq.com, we collect your name and email address and any additional information and documents you send us in your correspondence.
We keep that data in our help desk software indefinitely. The customer interaction history helps us provide you with better customer service and helps us research how to improve our products and services.
We also use this information to proactively contact you if we see from our logs that you're having an issue with our Services, or if we resolved an issue you reported. If you had expressed interest in them, we also email you to notify you of beta programs or user research interviews.
If you chose to sign up for our newsletter we ask you to enter your email address, so that we can send you the newsletter. We keep your email address in our newsletter service provider until you unsubscribe via the link included in every newsletter.
If you have applied for a job or applied for one of our raffles for a free ticket to a conference, we ask you to enter your name and email address so that we can get back to you, as well as any application information you wish to provide in response to our questions.
We keep raffle data in our wiki until the end of each raffle, after which it is deleted.
In order to submit a comment to our blog, we ask you to enter your name and email address, so that we can attribute the comment to you and so that we can get in touch if needed to help you with your question or comment. We store your email address in our Wordpress hosting provider.
We use Google Analytics to help us in our marketing and product design efforts, but we only track aggregate data. The Google Analytics code we use saves two cookies on your computer: _ga and _gid. You can delete or block those any time you wish, our website will continue to work.
We collect the IP addresses of everyone who visits our site or uses our Services. This information is used for debugging and DDOS prevention, and kept in our logs for 2 weeks.
In order to keep your Personal Data as secure as possible, we don't own any servers of our own. Instead, we rely on best-in-class third party services to store your data more securely than what we would be able to do ourselves.
Here's the list of our vendors we use, and links to their privacy policies:
|Google Sheets||Store data from balsamiq.com online forms, as well a customer lists for beta program and similar||USA||G Suite Security and Trust|
|Help Scout||Support Help Desk||USA||
Help Scout Security
About the General Data Protection Regulation
|Postmark||Transactional application emails||USA||
Postmark EU Data Protection
WPEngine & GDPR Compliance
You have the right to request a copy of your information, to object to our use of your information, to request the deletion or restriction of your information, or to request your information in a structured, electronic format.
Balsamiq Cloud and myBalsamiq give you a way to access your personal information and correct it, via User Settings or a billing page.
Most of our Online Services give you a way to download or delete your data at any time. Once you delete your data, unless specified otherwise, we keep it in our backups for up to 60 days, then destroy it with no way to recover it.
If you have any questions or concerns about how your Personal Data is processed, or if you want a copy of your data, or want to rectify it or delete it, don't hesitate to email us at email@example.com.
To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections. We use this procedure to better safeguard your information. You can correct factual errors in your personally identifiable information by sending us a request that credibly shows error.
We will respond as quickly as possible, and certainly within 30 days.
In certain circumstances we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
If we become aware of a data breach that affects your Personal Data, we will notify you (and the appropriate national supervisory authorities) within 72 hours.
Our detailed Information Security information is here.
The people you share them with, as described in our Online Service or Licensed Product's documentation.
For the Balsamiq Services that have the concept of Owners (as defined in Terms of Service), they will be able to see your wireframes as well.
For Online Services some Balsamiq employees will also have access, according to the following guidelines:
Balsamiq Studios, LLC is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Balsamiq Studios, LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. Balsamiq is liable for any processing of personal information by such third parties that is inconsistent with the Privacy Shield Principles unless it is not responsible for the event giving rise to any alleged damage.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Balsamiq Studios, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, Balsamiq Studios, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Balsamiq Studios, LLC commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Balsamiq.
Balsamiq Studios, LLC has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
Under certain conditions, Privacy Shield provides the right to invoke binding arbitration when other dispute resolution procedures have not provided resolution. This is described in Annex I to the Privacy Shield.
*Only US-based entities are eligible to self-certify under Privacy Shield. Therefore, as an EU based entity, Balsamiq SRL does not need to self-certify under Privacy Shield in order to transfer data outside of the EU.
Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information on our Online Service or Licensed Product from those we actually know are under 16, and no part of our Online Service or Licensed Product are structured to attract anyone under 16. If we become aware that a child under 16 has provided us with Personal Data, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at firstname.lastname@example.org.
Balsamiq Studios, LLC
1517 24th Street
Sacramento, CA, 95816-6206
Viale Oriani 2
40137 Bologna (BO)