Document Active
December 1, 2025

Privacy Policy

01

This Privacy Policy, including all schedules attached hereto, (the "Privacy Policy") is incorporated into and subject to the Terms of Service (the "Agreement") entered into by and between Customer and Arvion. All capitalized terms used, but not defined in this Privacy Policy shall have the meanings set forth in the Agreement. In the event of an express conflict between the Agreement and the Privacy Policy, the terms of the Privacy Policy shall prevail.

02

1. DEFINITIONS

Data Protection Laws means all national, federal, and state data protection laws and regulations, as may be amended or updated from time to time, applicable to Arvion's processing of Personal Data to provide the Services as described in the Agreement. Such Data Protection Laws shall include, as applicable:

  • The California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., and its implementing regulations ("CCPA"); and
  • The General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR") or the "UK GDPR" which means the UK General Data Protection Regulation, as it forms part of the law of the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018.

Personal Data means any information relating to an identified or identifiable natural person, which is processed by Arvion in its role as a data processor for the purposes of providing the Services under the Agreement.

03

2. RIGHTS AND OBLIGATIONS

The parties acknowledge and agree that with respect to the processing of Personal Data, Customer is the controller and Arvion is the processor. The parties agree that the Agreement and this Privacy Policy, as well as Customer's configuration of the Services, shall constitute the Customer's instructions for the processing of Personal Data. Each Party shall comply with its respective obligations under the Data Protection Laws. Customer will not instruct Arvion to process Personal Data in violation of applicable law. To the extent required by Data Protection Laws, Arvion shall assist Customer in complying with Customer's obligations under the Data Protection Laws.

04

3. SUBPROCESSORS

Customer grants Arvion general authorization to engage third parties to process the Personal Data ("Sub-processors"). Arvion shall maintain an up-to-date list of Sub-processors and Customer may request for a copy of such list.

05

4. DATA REQUESTS

Arvion shall, to the extent required by applicable Data Protection Law, notify Customer if Arvion receives any valid requests from a data subject identified in connection with Customer's Arvion subscription to exercise his or her individual rights under Data Protection Law.

06

5. GDPR

This Section shall apply only to the extent as Personal Data contains personal information subject to the GDPR, or UK GDPR, and shall apply in addition to the other requirements of the Agreement and the other provisions of this Privacy Policy. The parties agree that Arvion may process Personal Data as part of providing the Services pursuant to the Agreement.

07

6. INTERNATIONAL DATA TRANSFERS

Customer acknowledges and agrees that Arvion may transfer, access and process Personal Data on a global basis as necessary to provide the Services in accordance with the Agreement. Arvion will make any such transfers in compliance with the Data Protection Laws.

08

7. CCPA

This Section shall apply only to the extent that Personal Data contains personal information subject to the CCPA and shall apply in addition to the other requirements of the Agreement and the other provisions of this Privacy Policy.

09

8. GENERAL

8.1 Governing Law. Unless otherwise required, the parties agree that this Privacy Policy shall be governed by and construed in accordance with the laws of the jurisdiction set forth in the Agreement and the parties agree to submit to the jurisdiction of the courts specified in the Agreement.

10

Schedule 1: DATA PROCESSING DETAILS

Categories of data subjects: Developers and other employees of Customer who are users of Arvion's services or otherwise contribute to Customer's code base

Categories of personal data:

  • First and last name, employer, title, and position
  • Email addresses
  • User ID's or tags related to source code repositories or other services integrated with Arvion by the Customer's users
  • Connection and/or localization data
END OF DOCUMENT