Privacy policy

Last updated: February 10, 2022

The privacy of your data is extremely important to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data.

This policy applies to all products built and maintained by Stirred AB including Metamorphous.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity & access

When you sign up for a Metamorphous product, we typically ask for identifying information such as your name and email address. That’s so you can personalize your new account, and we can send you updates or other essential information. We sometimes also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture.


Geolocation data

We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.

Web analytics data — described further in the Website Interactions section — are also tied temporarily to IP addresses to assist with troubleshooting cases.

Website interactions

When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services. Other web analytics we utilize are described further in the Cookies and Do Not Track section.


Cookies and Do Not Track

We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics.

A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org

At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.

Voluntary correspondence

When you write Metamorphous with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.

We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.

Information we do not collect

We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.

We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.


When we access or share your information

Our default practice is to not access your information. The only times we’ll ever access or share your info are:

**To provide products or services you’ve requested**. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. Having subprocessors means we are using technology to access your data. No Metamorphous human looks at your data for these purposes unless an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases and when they happen, we look for root cause solutions as much as possible to avoid them from reoccurring.

**To help you troubleshoot or squash a software bug, with your permission.** If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.

**To investigate, prevent, or take action regarding restricted uses.** Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.

Your rights with respect to your information

At Metamorphous, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Metamorphous recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:

* **Right to Know.** You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.

* **Right of Access.** This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.

* **Right to Correction.** You have the right to request correction of your personal information.

* **Right to Erasure / “To be Forgotten”.** This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Metamorphous services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.

* **Right to Complain.** You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en

* **Right to Restrict Processing.** This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information.

* **Right to Object.** You have the right, in certain situations, to object to how or why your personal information is processed.

* **Right to Portability.** You have the right to receive the personal information we have about you and the right to transmit it to another party.

* **Right to not be subject to Automated Decision-Making.** You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.

* **Right to Non-Discrimination.** This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and directly updating your account information.

If you have questions about exercising these rights or need assistance, please contact us. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.

If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.


What happens when you delete data in your product accounts

We delete your data after an account is cancelled. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts.

Location of site and data

Our products and other web properties are operated in Sweden and the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

When transferring personal data from the EU

The GDPR requires that any data transferred out of the EU must be treated with the same level of protection that the EU privacy laws grant. The privacy laws of the United States generally do not meet that requirement. That is why since GDPR went into effect, Metamorphous has offered a data processing addendum and voluntarily participated in the EU-US Privacy Shield Framework as well as the Swiss-US Privacy Shield Framework.

We have incorporated a Data Processing Addendum to our Terms of Use that is in effect when the GDPR applies to your use of Metamorphous Services to process Customer Data as defined in the DPA. You can find the DPA linked within clause 7 of the Uptime, Security and Privacy section. The DPA includes the European Commission’s Standard Contractual Clauses (both controller-processor and controller-controller) to extend GDPR privacy principles, rights, and obligations everywhere personal data is processed.

There are also a few ad-hoc cases where EU personal data may be transferred to the US related to Stirred AB operations. For instance, if someone in the US comments on our company blog or a customer participates in one of our infrequent surveys or someone applies to one of our open positions or buys swag on our company shop. Such transfers are only occasional and transferred under the [Article 49(1)(b) derogation](https://gdpr-info.eu/art-49-gdpr/) under GDPR.

EU-US and Swiss-US Privacy Shield policy

The EU-US Privacy Shield is an agreement between certain European jurisdictions and the United States that up until July 16, 2020, allowed for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary. The Swiss-US Privacy Shield is a similar program for data transferred to the US from Switzerland that was in effect until September 8, 2020.

We comply with the frameworks for EU, UK, and Swiss data that are transferred into the United States

Metamorphous complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States, respectively. We’ve certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles take precedent. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Metamorphous is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Privacy Shield Frameworks.

The Privacy Shield Frameworks uphold specific principles, many of which are already outlined in the section on Your Rights. For clarity, pursuant to the Privacy Shield Frameworks, the following principles apply to all EU, UK, and Swiss data that has been transferred into the United States:

- Individuals have the right to access their personal data and to update, correct, and/or amend information that is incomplete. Individuals also have the right to request erasure of personal information that has been processed in violation of the principles. Individuals wishing to exercise these rights may do so by by signing in and directly updating your account information.
- We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
- We may be required to release personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.

We commit to resolving all complaints

In compliance with the EU-US Privacy Shield Principles and the Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union, United Kingdom, or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact David Turnbull at Stirred AB at [email protected]

If your EU-US Privacy Shield complaint cannot be resolved through these described channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. To learn more, please view the Privacy Shield Annex 1 at [https://www.privacyshield.gov/article?id=ANNEX-I-introduction](https://www.privacyshield.gov/article?id=ANNEX-I-introduction).

Changes & questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our company blog.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch.

Adapted from the Basecamp open-source policies / CC BY 4.0