This Privacy Policy ("Policy") supplements the Terms of Service ("Terms") and describes how Firespring ("Firespring", "Company", "we", "us", or "our") collects, uses, and shares information provided to us through our website analytics.firespring.com (the "Site"), and the services available through our Site ("Firespring Analytics", "Service", or "Services").

We collect information about users of our Service (our "Customers"), as well as our Customers' end users ("End Users") (collectively, "you", "your", or "yourself"). Note that Customers are also End Users, as we use our own Service to track itself. Some of the information collected may be Personal Data (defined as personal data of End Users that is processed by Firespring on behalf of Customers). Your rights regarding Personal Data are described in this Policy.

By using the Service, you agree that your information will be handled as described by this Policy, and that your usage and any disputes over privacy are subject to the Agreement.


Information we collect

We collect information about you through your use of our Service and/or from the web sites and services provided by our Customers.

From Customers

When you create an account, you provide us with a username, password, real name, and email address, as well as one or more web sites that you own and want to monitor with the Service. If you make a purchase, you provide us with your billing information such as card number and address. This information is used for the purposes of having and maintaining your account. Your email is only used for important account notifications, such as a failed payment or expiring subscription.

From End Users

We collect information from End Users under the instruction of our Customers, under which circumstance we have no direct relationship with the End Users.
The following information is sent to our servers by default when an End User visits a Customer's web site.
  • URL & Title of pages viewed
  • URL & Title of any links that are clicked on pages viewed
  • Referrer
  • User agent
  • Browser language
  • Screen resolution
  • x/y coordinates of mouse events
  • Unique ID tracking cookie ("UID")
    Most privacy laws consider this to be Personal Data, even though it is randomly generated and does not identify who you are or reveal anything else about you. Its sole purpose is to more accurately track unique visitors.
  • IP address ("IP")
    IPs are anonymized by default, but Customers can disable this for security/fraud purposes, in which case they are considered Personal Data.
  • Custom data
    This feature can be used by a site to attach additional data to a visitor, potentially including Personal Data such as a name or email address, but it is against our Terms to log Personal Data using this feature without disclosure or (depending on "legitimate interest") consent. Customers are responsible for obtaining content from End Users, if necessary. This feature requires a small amount of configuration and coding by Customers, so only a small percentage of Customers use it.

Processing of UID and IP Personal Data is lawful and does not require your direct consent because it is "necessary for the purposes of the legitimate interests" (GDPR Article 6), and "necessary to fulfill the legitimate interests" (LGPD Article 7), of web sites using the service. These legitimate interests include but are not limited to:
  • Assembling statistics regarding the use of a web site. (Accurately counting unique visitors is a vital statistic for any web site).
  • Preventing fraud and abuse, and maintaining information security. (Full IP addresses are necessary for this type of usage). (Recital 47 of the GDPR states: "The processing of Personal Data strictly necessary for the purposes of preventing fraud also constitutes a legitimate interest".)

As End Users of our service, the types of information listed above are also collected about our Customers when they are using our Service. The Personal Data that we log is as follows:
  • Your UID and IP address, per the legitimate interests above.
  • Your account username, per the legitimate interests above, as well as to help with customer service needs.


How we use your information


Customers

  • To provide and maintain our Service to you.
  • To help understand how Customers use our Service on an individual and aggregate basis in order to improve it.
  • To help with customer service needs, such as troubleshooting issues that you report to us.
  • To contact you with important account notifications, such as a failed payment or expiring subscription.
  • Other research and analytical purposes such as Service performance, Customer behavior and retention, and common navigations through the Site.

End Users



How we share your information

We may share your information with service providers or contractors who perform actions or functions on our behalf, but only as necessary to provide and maintain the Service to you. For example, we must share your billing information with our merchant account provider in order to charge you for the Service.

We may also share your information for legal reasons, such as:
  • Meeting applicable laws, regulations, legal processes, or enforceable governmental requests.
  • In response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
  • Detecting, preventing, or otherwise addressing fraud, security, or technical issues.
  • Protecting against harm to the rights, property or safety of Firespring, our Customers, or the public as required or permitted by law.
  • Enforcing applicable Terms of Service.



Cookies

The following cookies are used with the Service. All cookies are first party unless otherwise noted. Temporary session cookies (that expire when you leave a web site) are not listed.

Customers:

login
If you check "remember me" on the login page, this cookie is set for 1 year to automatically log you in on future visits. Deleted if you manually "log out" of the Site.
osa
Third party cookie, for authenticating the on-site analytics widget when visiting your own web sites. Deleted if you manually "log out" of the Site.
ignore
Third party cookie, for ignoring your own visits to your own web sites.

End Users:

_referrer_og
Stores external referrer for 90 days, for better long term attribution of traffic sources.
_utm_og
Stores dynamic (UTM) campaign variables for 90 days, for better long term attribution of marketing efforts.
_custom_data_[key]
Only set when a site is using custom data tracking and the site has flagged an End User as having fully consented to tracking Personal Data. These cookies cache certain custom data keys for 30 days so that they're attached to sessions even when a visitor is not logged in.
_jsuid
Unique ID, a random 32 bit integer generated upon someone's first visit to a web site.
cluid
Third party Unique ID, attached to our tracking domains, for identifying the same visitor across multiple domains belonging to the same customer. The first and third party values are kept in sync. If both are set, we update the first party cookie to match the third party cookie. If only one of these cookies is set, we attempt to set the other one with the same value.

Customers can disable End User cookies by setting firespring_custom.cookies_disable.


Security

To the best of our ability, we protect all of our data from loss, misuse, and unauthorized access and destruction.

Secure (HTTPS) access is forced for our Site to help keep your information, including login credentials, secure in transit.

You are responsible for using a strong and unique password for the Site to help keep your account secure. We are not responsbile for any unauthorized activity on your account because of lost, weak, or compromised passwords.


EU & Swiss Privacy Shield

In July 2020, EU and Swiss courts declared their respective US Privacy Shield Frameworks to be inadequate for the transfer of Personal Data to the United States. Companies within these regions must now use the updated 2021 EU Standard Contractual Clauses ("SCCs") instead. The UK (after Brexit) has recognized the new EU SCCs as well, with a small addendum. Our Data Processing Agreement has been updated to include these SCCs for Customers in these regions.


Personal Data rights

EU, UK and Swiss residents have the legal right to access, correct, and delete their Personal Data, per the General Data Protection Regulation (GDPR), with some exceptions. Residents of California and Brazil have similar rights and exceptions, per the California Consumer Privacy Act (CCPA) and Lei Geral de Proteção de Dados Pessoais (LGPD), respectively.

Customers may contact us directly to access or delete their data. End Users, with whom we we have no direct relationship, should send their inquiries directly to the Customer in question, as we are considered simply a "Data Processor" per the GDPR and a "Service Provider" per the CCPA. End Users may opt out of tracking entirely if desired, also known as "Do not sell my personal information" in California.

If we receive a request from an End User in relation to Personal Data processed for a Customer, we will advise the End User to submit their request to Customer, and Customer will be responsible for responding to such request using the tools we have provided on our Site for handling Personal Data requests. Customer agrees to use all reasonable measures to verify the identity and location of an End User before sharing or modifying Personal Data.

Customers can export their data using the API or the export function, or delete their account using the link at the top of the user preferences page.

We retain Personal Data on behalf of our Customers for as long as needed to provide our Service to them, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. To protect against accidental or malicious deletion, there is a delay before data is removed from our active systems and data will remain in our backup systems for up to 1 year before it is fully deleted.

The CCPA requires us to disclose the information we have collected and "sold" over the last 12 months. This is covered in Information we collect.

Our Service is not designed for children under 13. If we discover that a child under 13 has provided us with Personal Data, the data will be deleted.


Contact us

If you need to contact us about privacy, Personal Data, or Data Protection, or would like to make a complaint, please contact us by email.


Changes to this Policy

This Policy may be updated from time to time, as documented below. We will notify you via your registered email address and/or a notice on this website prior to any significant changes becoming effective regarding Personal Data. You should periodically review this page for the latest information.

- Sep 27, 2021 - added clauses for Brazil's "Lei Geral de Proteção de Dados Pessoais" (LGPD)
- Aug 21, 2020 - added information about the EU Standard Contractual Clauses (SCCs) replacing the US Privacy Shield frameworks.
- Jul 1, 2020 - added clauses for the California Consumer Privacy Act (CCPA).
- May 25, 2018 - added clauses for the General Data Protection Regulation (GDPR).