PRIVACY POLICY

(hereinafter: “Privacy Policy”)

1. Introduction

1.1. Purpose and characteristics of Privacy Policy

Your privacy is important to Service Provider because Application connects two services in which people communicate and collaborate. This document explains what Personal Data is processed by the Firnity Discord for Confluence application ("Application" as defined in Terms of Use) and by Service Provider while providing Services ("Services" as defined in Terms of Use, especially support and feedback), how and why that data is used, how it is shared and protected, how long it is retained, and what rights are available.

1.2. Who is the Controller?

The controller of Personal Data that Service Provider collects for its own vendor administration, direct support, vulnerability handling, limited product analytics, legal compliance, and related business purposes is Łukasz Wiatrak, doing business as “Łukasz Wiatrak Firnity” (the “Service Provider” as defined in Terms of Use), with its registered seat in Kraków (address: ul. Zamknięta 10, lok. 1.5, 30-554 Kraków, Poland), having Tax Identification Number (NIP): 5130127144 and Statistical Number (REGON): 520124248 (hereinafter referred to as “Service Provider”). You can contact Service Provider by phone at +48 693 066 020 or by email at contact@firnity.com.

When the relationship between Service Provider and User makes User the Controller and Service Provider a Processor under the DPA, Service Provider Processes customer-directed Personal Data on User's behalf in accordance with the DPA, Terms of Use, this Privacy Policy, and User's documented instructions.

1.3. Who does Privacy Policy apply to?

Privacy Policy applies to Users, as defined in Terms of Use, including any business entity or organization that purchases, accesses, or uses Application for business purposes and individuals acting on its behalf. It also applies to people whose Personal Data is Processed through a User's configured Confluence and Discord workflows, and to people who contact Service Provider directly.

If a User grants access to Application and Services to related entities, Personnel, User's Clients, Confluence users, or Discord members, Service Provider Processes their Personal Data as a Processor on the basis of the DPA where applicable. User remains responsible for its own notices, lawful basis, instructions, permissions, and configured destinations.

Application is intended for organizational use and is not directed to children. By using Application and related Services, User acknowledges that it has read and understood this Privacy Policy. If User does not agree with its terms, User must refrain from using Application and Services.

1.4. Definitions

Capitalized terms in this Privacy Policy have the meanings given to them in this document or in Terms of Use. In case of inconsistency, the meaning given here prevails.


2. How and why Your Personal Data is processed?

2.1. Reasons for Personal Data Processing

When acting as Controller, Service Provider Processes Personal Data as necessary to enter into or perform the Agreement, operate vendor and license administration, answer support or security communications, protect Application and legal rights, and meet applicable legal, tax, and accounting obligations. Service Provider may rely on performance of a contract, compliance with a legal obligation, or a legitimate interest, as described in Section 6.

When acting as Processor, Service Provider Processes Personal Data only for User's documented purposes and instructions, including the instructions expressed through User's configuration and requested actions in Application. User determines the applicable lawful basis for that Processing.

Service Provider does not use Personal Data collected through Application or the Trust Center for direct marketing.

2.2. How does Service Provider use Personal Data?

Service Provider uses Personal Data to:

2.2.1. Facilitate integration: connect an authorized Confluence Cloud installation to selected Discord servers and destinations; authenticate requests; enforce Confluence and Discord permission boundaries; send configured notifications, summaries, cards, panels, previews, and linked discussions; and allow authorized users to find, share, create, comment on, or label Confluence content through supported workflows.

2.2.2. Create content in Confluence: transmit content and attachments submitted through an authorized Discord command or interaction to the connected Confluence site, using the linked Atlassian identity and applicable Confluence permission checks.

2.2.3. Provide support and improve services: respond to support and vulnerability reports, diagnose bounded failures, maintain Application, protect against misuse, and understand product use through limited usage events and masked session recordings.


3. Which Personal Data are processed?

Service Provider Processes the following categories of Personal Data to provide Application and related Services.

3.1. Data from Confluence Cloud

3.1.1. Confluence User and Installation Data: Atlassian account IDs, display names and avatars where a workflow requires them; Confluence cloud IDs and site URLs; Forge application, environment and installation IDs; licensing information; permission context; and short-lived, installation-scoped Forge system tokens. Application does not store Atlassian user access or refresh tokens.

3.1.2. Confluence Content and Configuration Data: space IDs, space keys and space names; page and comment IDs, parent page IDs, titles, URLs, labels, timestamps and author or actor account IDs; saved notification, summary, command, panel, action and discussion settings, including filters, schedules and destinations; and event and delivery records containing event IDs and types, page and space IDs, notification-rule IDs, Discord message IDs, status, timestamps and bounded failure details. Current Confluence content is retrieved when configured notifications are sent. Page bodies, comments, event content, search results, submitted creation content and attachments are Processed for the duration of the requested workflow.

3.2. Data from Discord users

When Discord users connect an account, connect or use a server, invoke a command, select a message, use a panel or action, create a Confluence page, or receive configured content, Service Provider Processes:

3.2.1. Discord User, Server, Destination and Content Data: Discord user IDs, usernames and display names; server IDs and names; role, channel, thread and message IDs; URLs; selected message content, command and form inputs, attachments, interaction context, permission results and delivery information needed for the requested workflow. Linked accounts include Discord user IDs, Atlassian account IDs, installation IDs, status and timestamps. Names are retrieved when needed to display accounts and recipients. Discord OAuth access and refresh tokens are discarded after identity or server connection is verified.

3.3. Support, communications, and website data

While providing support, handling security reports, maintaining legal records, and improving Services, Service Provider may collect Personal Data that User or another person voluntarily provides, such as:

3.3.1. Support Request Information: name, email address, organization name or Confluence site ID, relevant account or destination IDs, timestamps, diagnostic descriptions, and any other Personal Data included in communications. Do not send passwords, tokens, secret-bearing URLs, raw provider payloads, or unrelated customer content.

3.3.2. Feedback and Communications: information provided in feedback, complaints, contractual notices, data-subject requests, or vulnerability reports.

3.3.3. Website and Service Requests: request information, such as IP address, user agent, requested URL, and timestamp, may be Processed by the hosting service for operation and security. Trust Center search runs in your browser. Hosting providers and processing locations are identified on the Sub-Processors page.

3.4. Application diagnostics and product analytics

3.4.1. Application diagnostics: Sentry receives browser error information, including error descriptions, bounded stack traces, Application context, Atlassian account IDs, Confluence cloud IDs and Forge installation IDs. Reports exclude page content, form values and browser request payloads.

3.4.2. Application analytics: Service Provider uses PostHog's EU service for limited usage events and minimized recordings of Application's own interface to diagnose errors, maintain reliability and improve workflows. Information includes feature use, selected options and outcomes, browser/device and session information, and sanitized interface URLs, which may include resource IDs. Random browser and session IDs are held in memory without persistent analytics cookies or analytics IDs stored in localStorage. Recording is configured to mask input values, customer content and private or error text; block private media; and exclude console output, network request/response records (including headers and bodies), performance recordings, canvas content and embedded content from other origins. This analytics is not used for advertising.

Application analytics is controlled for the whole Confluence site in Settings by an authorized Confluence administrator. The choice applies to everyone using Application for that site. Application analytics is enabled by default. Missing or unavailable settings are treated as off. Normal updates and reinstall recovery preserve retained settings; a known returning customer is not automatically treated as a new customer.

Saving the setting as off stops further optional capture in that browser. Other open sessions apply the change through refreshed recording-permission checks. Inactive sessions check the setting before resuming capture. Older open versions must be reloaded to use this control. Switching off does not recall information already sent or in transit.

Turning analytics off does not restrict access to Services. Separate service, security and error records continue under their own purposes. Individuals may object to Processing based on legitimate interests by contacting contact@firnity.com, as described in Section 7.


4. To whom Your Personal Data is exposed?

4.1. Sub‑processors and entrusting Personal Data

Service Provider engages Sub-processors to provide Application and related Services, subject to the DPA. Their identities, services, processing locations, and applicable transfer safeguards are published on the Sub-Processors page.

Service Provider uses PostHog, Inc. for its own product analytics through PostHog's EU service. This Processing is separate from customer-directed Processing under the DPA.

4.2. Third‑party platforms

Application Processes and sends Personal Data through customer-selected third-party platforms. In particular, Confluence and Forge are provided by Atlassian, and Discord services are provided by Discord. User controls the connected tenants, servers, destinations, permissions, and configured workflows. Atlassian and Discord Process data under their respective agreements, policies, and roles after data reaches their services.

4.3. International Data transfers

Personal Data may be Processed outside Poland or the European Economic Area by the providers used to deliver Application and by User's selected Atlassian and Discord services. For transfers made by Service Provider, Service Provider uses safeguards required by applicable data-protection law, such as an adequacy decision or applicable standard contractual clauses. Provider locations and applicable safeguards are identified on the Sub-Processors page. User is responsible for the lawfulness of its instructions and customer-directed transfers to its own Atlassian and Discord environments.

4.4. Legal Obligations

Service Provider may disclose Personal Data when required by applicable law, a binding court order, legal process, or authorized governmental or Supervisory Authority request. Where legally permitted and appropriate, Service Provider will inform the affected Controller before disclosure.


5. Period of processing

The period of Processing depends on the purpose, User's instructions, the Agreement, and applicable law, as described below.

5.1. Basic period of processing

Service Provider retains installation, linked-account, configuration, and event-delivery records while needed to provide the requested integration. Content retrieved to perform a workflow is Processed for the duration of that workflow.

After we receive a verified Forge uninstall notice, access stops. We keep app-hosted settings and integration records for 30 days, then delete them at the next daily cleanup. Reinstalling on the same Confluence site during this period resumes retained settings after fresh authorization and cancels deletion.

Backups have a separate seven-day recovery window. Backup files can remain longer to support this recovery window. After reinstall, old installation details expire at the original 30-day deadline. After live deletion, a separate record used to reject old installation requests expires after one day and is removed at the next daily cleanup. Account links still used by another active installation remain for that installation. Content already sent to Confluence or Discord follows that platform’s retention.

Verified requests for return or erasure are handled separately under the DPA.

A minimal Application analytics setting remains after live deletion: the Confluence cloud ID and an off value. It contains no individual preferences, linked accounts, customer content or access tokens and does not restore the integration or grant access. We retain this record to prevent a known returning site from being automatically re-enabled, subject to the rights in Section 7.

Session recordings are available in PostHog for up to 30 days under the configured recording window. Usage events are retained for the period needed to diagnose errors, maintain reliability and improve Application workflows, subject to applicable data-protection rights. Turning analytics off or uninstalling Application does not automatically delete provider history. Contact contact@firnity.com to exercise rights concerning previously received records.

Support, security, and contractual correspondence is retained for as long as needed to handle the matter, meet legal obligations, or establish, exercise, or defend legal claims. User may request access, correction, return, or erasure at contact@firnity.com. Service Provider verifies identity and authority before acting on a request.

5.2. Period of processing for tax purposes

Service Provider Processes controller-side transaction, contract, tax, and accounting Personal Data for as long as required by applicable Polish law. The ordinary Polish tax record period may extend for five years from the end of the calendar year in which the relevant tax payment deadline occurred, subject to suspension, extension, or another legal requirement.


6. Legal basis of processing and security measures

6.1. Legal basis for processing (performance of the contract)

When Service Provider acts as Controller, Article 6(1)(b) GDPR may apply where Processing is necessary to enter into or perform an Agreement with the data subject. Article 6(1)(f) GDPR may apply to Service Provider's legitimate interests in operating support and security communications, understanding product use and improving Application, protecting Application and legal rights, preventing misuse, and establishing, exercising, or defending legal claims, balanced against the individual's rights and interests. For customer-directed integration data, User as Controller determines and documents the lawful basis and Service Provider acts on User's instructions under the DPA.

6.2. Legal basis for processing (legal obligations)

Processing may also be necessary for Service Provider to comply with a legal obligation under Article 6(1)(c) GDPR, including applicable tax, accounting, court, regulatory, and data-protection duties.

6.3. Service Provider as Processor

When acting under the DPA, Service Provider Processes Personal Data on behalf of User's organization, which is Controller. User remains responsible for the lawfulness of its data, instructions, permissions, selected recipients, and notices to affected people.

6.4. Security measures

Service Provider implements technical and organisational measures selected for the current Application architecture and risk. These include:

6.4.1. Encryption in transit: Application uses HTTPS for Forge, Confluence, Discord, and remote-service communication, and encrypted connections to its application database.

6.4.2. Access Controls: signed Forge invocation context, Discord interaction signatures, scoped Forge app or user authorization, Confluence access checks, Discord channel and thread permissions and protected secret configuration limit access at the relevant boundary.

6.4.3. Security Assessments: Firnity Discord for Confluence source and dependency changes are subject to development review and testing.

6.4.4. Hosting: hosting providers and processing locations are disclosed on the Sub-Processors page. The Security Overview describes the controls used to protect Application data.


7. How to exercise Your rights?

7.1. Range of rights

Depending on the circumstances and applicable law, a data subject may have rights concerning Personal Data for which Service Provider is Controller. Where User is Controller, requests should normally be directed to User, and Service Provider will provide assistance required under the DPA. These rights may include:

7.1.1. Right of Access: To request confirmation of whether Personal Data is being Processed and access to that data, under Article 15 GDPR.

7.1.2. Right to Rectification: To request correction of inaccurate or incomplete Personal Data, under Article 16 GDPR.

7.1.3. Right to Erasure: To request deletion of Personal Data in applicable circumstances, under Article 17 GDPR.

7.1.4. Right to Restrict Processing: To request limitation of Processing under applicable conditions, under Article 18 GDPR.

7.1.5. Right to Data Portability: To receive applicable Personal Data in a structured, commonly used, machine-readable format and transmit it to another controller, under Article 20 GDPR.

7.1.6. Right to Object: To object to Processing based on legitimate interests, under Article 21 GDPR.

To exercise a right for which Service Provider is Controller, or to ask Service Provider to assist User as Controller, contact Service Provider by email at contact@firnity.com or by phone at +48 693 066 020. For security and tenant isolation, Service Provider may need to verify identity, authority, account ownership, and the relevant Atlassian installation before acting.

7.2. Complaint to the supervisory authority

Under Article 77 GDPR, you may lodge a complaint with a competent supervisory authority. In Poland, this is the President of the Personal Data Protection Office (Prezes UODO), available at https://uodo.gov.pl/. A list of other European Economic Area authorities is available from the European Data Protection Board.


8. Final provisions

8.1. Is providing data necessary to enter into an Agreement?

Service Provider requires the account, site, installation and resource IDs, authorization context, configuration, and other data necessary to establish and operate Application and perform the Agreement. Some direct vendor data may also be required for legal, tax, accounting, support, or security purposes. Without required data or third-party accounts and permissions, some or all Services cannot be provided. Application is intended for organizational use and is not directed to children.

8.2. Where does Service Provider get your personal data from?

Service Provider obtains Personal Data from User and its authorized administrators, Personnel, User's Clients, Confluence users, Discord members, Atlassian Forge and Confluence APIs, Discord APIs and interactions, the Atlassian Marketplace where applicable, and people who contact Service Provider directly. Optional analytics on public marketing and documentation pages starts after Allow analytics and uses consent (GDPR Art. 6(1)(a)). PostHog, Inc.'s EU service receives public page paths, selected interactions, traffic-source and campaign information, event times, browser/device information and random browser and session IDs to understand visits and marketing effectiveness. Browser-linked website analytics is retained for up to 12 months. Use Analytics settings in the public-page footer to allow or reject it. Reject stops new public collection and clears this tracker's locally stored browser/session IDs and source information; it does not automatically delete records already received by the provider. Contact contact@firnity.com about those records or to exercise your rights. The Website analytics notice explains storage, retention and controls. Trust Center search remains local to the browser. Public website analytics is separate from the Application analytics described in Section 3.4.

8.3. Changes to Privacy Policy

Service Provider may update this Privacy Policy when Application, law, providers, or Processing changes. Material changes will be posted in the Trust Center and, where applicable, communicated through Marketplace or directly to customer contacts available to Service Provider. A change that requires consent or a new agreement will not take effect merely because a page was posted. User may discontinue use in accordance with Terms of Use if it does not accept an applicable contractual change.

Effective date: the date this version is published.