Categories of personal information

"User Personal Information" is any personal information about one of our users which could, alone or together with other information, personally identify them. Information such as a user name and password, an email address, a real name, and a photograph are examples of "User Personal Information." User Personal Information includes Personal Data as defined in the General Data Protection Regulation.

"Technical Information" may include information we collect from website browsers, such as web server logs, or other log information, such as User session or activity logs. Technical Information may be connected to User Personal Information such as a username or an email address, or to other potentially personally-identifying information like Internet Protocol (IP) addresses.

User Personal Information does not include aggregated, non-personally identifying information. We may use aggregated, non-personally identifying information to operate, analyze, improve, and optimize our website and service.

Information from users with accounts

If you create an account, we require some basic information at the time of account creation. We will ask you for a valid email address, name and password . You also have the option to give us more information if you want to, and this may include "User Personal Information."

Information from website browsers

If you're just browsing the website, we collect the same basic information that most websites collect. We use common internet technologies, such as cookies and web server logs, to collect Technical Information. This is stuff we collect from everybody, whether they have an account or not.

The information we collect about all visitors to our website includes the visitor's browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request. We also collect potentially personally-identifying information like Internet Protocol (IP) addresses.

Information we collect from third parties

From time to time, Lana receives personal information about individuals from third parties. This may happen if you sign up for a to receive information about Lana from one of our vendors.

Why we collect this information

• We need your User Personal Information to create your account, and to provide the services you request, including to provide the Lana service or to respond to support requests.
• We use your User Personal Information, specifically your email address, to identify you on Lana.
• We will use your email address to communicate with you, if you've said that's okay, and only for the reasons you've said that's okay.
• We collect Technical Information to better understand how our website visitors use Lana, and to monitor and protect the security of the website.
• We collect personal information from third parties for the purposes for which it was authorized to be collected. For example, you may authorize Lana to contact you for marketing purposes via a third party's platform. If we need to use your personal information for other purposes, we will ask your permission first.
• We use your User Personal Information and Technical Information for internal purposes, such as to maintain logs for security reasons, for training purposes, and for legal documentation and compliance.
• We limit our use of your User Personal Information to the purposes listed in this Privacy Statement. If we need to use your User Personal Information for other purposes, we will ask your permission first.

Our legal basis for processing information

Under certain international laws (including GDPR), Lana is required to notify you about the legal basis on which we process User Personal Information. Lana processes User Personal Information on the following legal bases:

• When you create a Lana account, you provide your name and email address. We require those data elements for you to enter into the Terms of Service agreement with us, and we process those elements on the basis of performing that contract. We also process your user name and email address on other bases. If you have a Lana Payments, or other paid account with us, there will be other data elements we must collect and process on the basis of performing that contract. Lana does not collect or process a credit card number, but our third-party payment processor does.
• As a user, you can fill out the information in your user profile, and you have the option to provide User Personal Information such as your full name, an avatar which may include a photograph, your biography, your location, your company, and a URL to a third party website. If you decide to participate in a Lana research project or survey, you may choose to provide User Personal Information or other personal information to us for limited purposes. We process this information on the basis of consent. All of this information is entirely optional, and you have the ability to access, modify, and delete it at any time.
• Generally, the remainder of the processing of personal information we perform is necessary for the purposes of our legitimate interests. For example, for legal compliance purposes or to maintain ongoing confidentiality, integrity, availability and resilience of Lana systems, website, and service, we must keep logs of Technical Information; and, in order to respond to legal process, we are required to keep records of users who have sent and received DMCA takedown notices.
• If you would like to request erasure of data we process on the basis of consent or object to our processing of personal information, please contact our support team.

What information Lana does not collect

We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information. Although Lana does not request or intentionally collect any sensitive personal information, we realize that you might store this kind of information in your account. If you store any sensitive personal information on our servers, you are responsible for complying with any regulatory controls regarding that data.

If you're a child under the age of 18, you may not have an account on Lana. Lana does not knowingly collect information from or direct any of our content specifically to children under 18. If we learn or have reason to suspect that you are a user who is under the age of 18, we will unfortunately have to close your account. Please see our Terms of Service for information about account termination. Other countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not use Lana without obtaining your parents' or legal guardians' consent.

Shop contents

Lana employees do not access private repositories unless required to for security reasons, to assist the shop owner with a support matter, or to maintain the integrity of the service. Our Terms of Service provides more details.

If your shop is public, anyone (including us and unaffiliated third parties) may view its contents. If you have included private or sensitive information in your public shop, such as email addresses, that information may be indexed by search engines or used by third parties. In addition, while we do not generally search for content in your repositories, we may scan our servers for certain tokens, usage policy violations or security signatures, or for known active malware.

How we share the information we collect

We do share User Personal Information with your permission, so we can perform services you have requested or communicate on your behalf. You may indicate, through your actions on Lana, that you are willing to share your User Personal Information. For example, if you join an shop as a user, the owner of the shop will have the ability to view your activity in the shop's access log. We will respect your choices.

We do not share, sell, rent, or trade User Personal Information with third parties for their commercial purposes, except where you have specifically told us to (such as by buying a theme or domain name).

We do not host advertising on Lana. We may occasionally embed content from third party sites, such as YouTube, and that content may include ads. While we try to minimize the amount of ads our embedded content contains, we can't always control what third parties show.

We do not disclose User Personal Information outside Lana, except in the situations where we are required to do so in accordance with our Law Enforcement Policy.

We do share certain aggregated, non-personally identifying information with others about how our users, collectively, use Lana, or how our users respond to our other offerings, such as our conferences or events.

We do share User Personal Information with a limited number of third party vendors who process it on our behalf to provide or improve our service, and who have agreed to privacy restrictions similar to our own Privacy Statement by signing data protection agreements. Our vendors perform services such as payment processing, customer support ticketing, network data transmission, and other similar services. When we transfer your data to our vendors under EU-US Privacy Shield Framework, we remain responsible for it. While Lana processes all User Personal Information in the United States, our third party vendors may process data outside of the United States or the European Union. If you would like to know who our third party vendors are, please see our page on Subprocessors.

We may share User Personal Information if we are involved in a merger, sale, or acquisition. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our website or by email before any transfer of your User Personal Information. The organization receiving any User Personal Information will have to honor any promises we have made in our Privacy Statement or in our Terms of Service.

Public information on Lana

Much of Lana is public-facing. If your content is public-facing, third parties may access and use it in compliance with our Terms of Service, such as by viewing your shop. We do not sell that content; it is yours. However, third parties may scrape Lana and compile data for various purposes.

Organizations

You may indicate, through your actions on Lana, that you are willing to share your User Personal Information. If you collaborate on or become a member of a shop, then the Account owners may receive your User Personal Information. When you accept an invitation to a shop, you will be notified of the types of information owners may be able to see.

Please contact the Account owners for more information about how they process your User Personal Information and the ways for you to access, update, alter, or delete the User Personal Information stored in that account.

Third party applications

You have the option of enabling or adding third party applications. These third party applications are not necessary for your use of Lana. We will share your User Personal Information to third parties when you ask us to, such connecting to an accounting system.

Privacy Statement

It is your responsibility to post a privacy statement that accurately describes how you collect, use, and share personal information and other visitor information, and how you comply with applicable data privacy laws, rules, and regulations. Please note that Lana may collect Technical Information from visitors to your shop, including logs of visitor IP addresses, to maintain the security and integrity of the website and service.

How you can access and control the information we collect

If you're already a Lana user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting support.

You can control the information we collect about you by limiting what information is in your profile, by updating out of date information, or by contacting support.

If Lana processes information about you and you do not have an account, such as information Lana receives from third parties, then you may access, update, alter, delete, or object to the processing of your personal information by contacting support.

Data portability

As a Lana User, you can always take your data with you. You can  download all of the data we have about you using our API or through easy to use export functionality.

Data retention and deletion of data

Generally, Lana will retain User Personal Information for as long as your account is active or as needed to provide you services.

We may retain certain User Personal Information indefinitely, unless you delete it or request its deletion. For example, we don't automatically delete inactive user accounts, so unless you choose to delete your account, we will retain your account information indefinitely.

If you would like to cancel your account or delete your User Personal Information, you may do so by contacting support. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete your full profile (within reason) within 90 days. You may contact support to request the erasure of the data we process on the basis of consent within 30 days.

After an account has been deleted, certain data, such comments, will remain. However, we will delete or deidentify your personal information, including your email address and comments by associating them with a ghost user.

Our use of cookies and tracking

Cookies

Lana uses cookies to make interactions with our service easy and meaningful. We use cookies (and similar technologies, like HTML5 localStorage) to keep you logged in, remember your preferences, and provide information for future development of Lana. For security reasons, we use cookies to identify a device. By using our website, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device's ability to accept these cookies, you will not be able to log in or use Lana services. On certain areas of the website, we may also use cookies to identify you and/or your device to advertise Lana products and services to you on third party sites.

We provide a web page on cookies that describes the cookies we set, the needs we have for those cookies, and the types of cookies they are (temporary or permanent). It also lists our third party analytics providers and subprocessors, and details exactly which parts of our website we permit them to track.

Tracking and analytics

We use a number of third party analytics and service providers to help us evaluate our users' use of Lana; compile statistical reports on activity; and improve our content and website performance. We only use these third party analytics providers on certain areas of our website, and all of them have signed data protection agreements with us that limit the type of personal information they can collect and the purpose for which they can process the information. In addition, we use our own internal analytics software to provide features and improve our content and performance.

Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Lana responds to browser DNT signals and follows the W3C standard for responding to DNT signals. If you have not enabled DNT on a browser that supports it, cookies on some parts of our website will track your online browsing activity on other online services over time, though we do not permit third parties other than our analytics and service providers to track Lana users' activity over time on Lana.

Lana global privacy practices

We store and process the information that we collect in the United States in accordance with this Privacy Statement (our subprocessors may store and process data outside the United States). However, we understand that we have users from different countries and regions with different privacy expectations, and we try to meet those needs even when the United States does not have the same privacy framework as other countries'.

We provide a high standard of privacy protection --- as described in this Privacy Statement --- to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business, working with our Data Protection Officer as part of a cross-functional team that oversees our privacy compliance efforts. Additionally, if our vendors or affiliates have access to User Personal Information, they must sign agreements that require them to comply with our privacy policies and with applicable data privacy laws.

In particular:

• Lana provides clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal information using consent as a basis.
• We collect only the minimum amount of personal information necessary for our purposes, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.
• We offer you simple methods of accessing, correcting, or deleting the User Personal Information we have collected.
• We provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement. These are the Privacy Shield Principles, but they are also just good practices.

How we respond to compelled disclosure

Lana may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.

In complying with court orders and similar legal processes, Lana strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.

How we, and others, communicate with you

We will use your email address to communicate with you, if you've said that's okay, and only for the reasons you've said that's okay. For example, if you contact our Support team with a request, we will respond to you via email. You have a lot of control over how your email address is used and shared on and through Lana. You may manage your communication preferences in your user profile.

Lana may occasionally send notification emails new features, requests for feedback, important policy changes, or offer customer support. We also send marketing emails, based on your choices and in accordance with applicable laws and regulations. There's an unsubscribe link located at the bottom of each of the marketing emails we send you. Please note that you can not opt out of receiving important communications from us, such as emails from our Support team or system emails, but you can configure your notifications settings in your profile.

Our emails might contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we're not sending you unwanted email.

Resolving complaints

If you have concerns about the way Lana is handling your User Personal Information, please let us know immediately. We want to help. You may contact us by filling out the support request form. We will respond promptly --- within 45 days at the latest.

You may also contact our Data Protection Officer directly.

DPO Contact
Att: Lana Data Protection Officer
548 Market Street
San Francisco, CA 94104
hello@lana.dev

Dispute resolution process

In the unlikely event that a dispute arises between you and Lana regarding our handling of your User Personal Information, we will do our best to resolve it. If we cannot, we have selected JAMS, an independent dispute resolution provider, to handle unresolved Privacy Shield complaints. If we are unable to resolve your concerns after a good faith effort to address them, you may contact JAMS and submit a Privacy Shield claim. JAMS is a US-based private alternate dispute resolution provider, and we have contracted with JAMS to provide an independent recourse mechanism for any of our users for privacy concerns at no cost to you. You do not need to appear in court; you may conduct this dispute resolution process via telephone or video conference. If you are not based in the EU, EEA, Switzerland, or the UK, but you would still like to use the JAMS arbitration process to resolve your dispute, please let us know and we will provide access to you.

Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority.

Independent arbitration

Under certain limited circumstances, EU, EEA, Swiss, and UK individuals may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please read more about Privacy Shield. Arbitration is not mandatory; it is a tool you can use if you choose to. We are subject to the jurisdiction of the Federal Trade Commission.

Changes to our Privacy Statement

Although most changes are likely to be minor, Lana may change our Privacy Statement from time to time. We will provide notification to Users of material changes to this Privacy Statement through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the primary email address specified in your Lana account. For changes to this Privacy Statement that do not affect your rights, we encourage visitors to check our Site Policy repository frequently.

Contacting Lana

Questions regarding Lana Privacy Statement or information practices should be directed to our support team.