Privacy Shield Notice


  1. Introduction

This Privacy Policy explains what information Combodo company and its related entities (hereafter "Combodo") collect about you and why, what we do with that information, how we share it, and how we handle the content you place in our products and services. It also explains the choices available to you regarding our use of your personal information and how you can access and update this information.

  1. Scope of Privacy Policy

This Privacy Policy applies to the information that we obtain through your use of "Combodo Services" via a "Device" or when you otherwise interact with Combodo.

"Combodo Services" include our Websites, Downloadable Products, Products installed automatically and SaaS Products but does not include Third Party Products. These are third party products or services that you may choose to integrate with Combodo product or services, such as third party extensions available in the iTop Hub. You should always review the policies of third party products and services to make sure you are comfortable with the ways in which they collect and use your information.
A "Device" is any computer used to access the Combodo Services, including without limitation a server, desktop, laptop, mobile phone, tablet, or other consumer electronic device. Unless otherwise stated, our SaaS Products and our Downloadable Products are treated the same for the purposes of this document.

By registering for or using Combodo Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

  1. Definitions

  • Extension:

A bundle of code, resources and configuration files that can be used with a Combodo Product to add new functionality or to change the behavior of that product's existing features.

  • Content:

Any information or data that you upload, submit, post, create, transmit, store or display in a Combodo Service.

  • Downloadable Products:

Combodo's downloadable software Products, including Extensions created by Combodo that are automatically installed or installed by customers on an infrastructure of their choice. Downloadable Products do not include Extensions created by third parties, even when they are accessed through, or available through the iTop Hub.

  • Information:

All of the different forms of data, content, and information collected by us as described in this Privacy Policy.

  • Personal Information:

Information that may be used to readily identify or contact you as an individual person, such as: name, address, email address, or phone number. Personal Information does not include information that has been anonymized such that it does not allow for the ready identification of specific individuals.

  • SaaS Products:

Combodo's "Cloud" hosted solutions, as well as other Combodo hosted solutions that display a link to this Privacy Policy. For the avoidance of doubt, if a Combodo hosted solution displays a link to a different privacy policy, then that other privacy policy shall apply.

  • Websites:

Combodo's websites, including but not limited to,,,, and any related websites, sub-domains and pages.

  1. Changes to our Privacy Policy

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Effective Starting" date at the top of this Privacy Policy. If we make any material changes, we will provide you with additional notice (such as by adding a notice on the Combodo Services homepages, login screens, or by sending you an email notification). We encourage you to review our Privacy Policy whenever you use Combodo Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you will need to stop using Combodo Services and deactivate your account(s), as outlined below.

  1. Information you provide to us

We collect the following information:

Account and Profile Information: We collect information about you and your company as you register for an account, create or modify your profile, use, access, or interact with the Combodo Services (including but not limited to when you upload, download, collaborate on or share Content). Information we collect includes: 

  • Contact information such as name, email address, mailing address, and phone number
  • Profile information such as a username, profile photo, and job title
  • Preferences information such as notification and marketing preferences

You may provide this information directly when you enter it in Combodo Services.

In some cases another user (such as a system administrator) may create an account on your behalf and may provide your information, including Personal Information (most commonly when your company requests that you use our products). We collect Information under the direction of our customers and often have no direct relationship with the individuals whose personal data we process. If you are an employee of one of our customers and would no longer like us to process your information, please contact your employer. If you are providing information (including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information as described in this Privacy Policy.

  • Content:

We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our Products or Websites. Such Content includes any Personal Information or other sensitive information that you choose to include ("incidentally-collected Personal Information").

  • Other submissions:

We collect other data that you submit to our Websites or as you participate in any interactive features of the Combodo Services, participate in a survey, contest, promotion, sweepstakes, activity or event, apply for a job, request customer support, communicate with us via third party social media sites or otherwise communicate with us. For example, information regarding a problem you are experiencing with a Combodo Product could be submitted to our Support Services or posted in our public forums.

  1. Information we collect from your use of Combodo Services

  • Web Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Products. This information includes internet protocol (IP) addresses as well as browser type, current page, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, local and language preferences, identification numbers associated with your Devices, your mobile carrier, and system configuration information. In the case of our SaaS Product, the URLs you accessed (and therefore included in our log files) include usernames as well as elements of Content (such as, PHP code and instances) as necessary for the SaaS Product to perform the requested operations. Occasionally, we connect Personal Information to information gathered in our log files as necessary to improve Combodo Services for individual customers. In such a case, we would treat the combined Information in accordance with this privacy policy.

  • Analytics Information from Website and Products:

We collect analytics information when you use our Websites and Products to help us improve our products and services. In the Products, this analytics information consists of the feature and function of the Combodo Service being used, domain name, the username and IP address of the individual who is using the feature or function (which will include Personal Information if the Personal Information was incorporated into the username), the sizes and original filenames of attachments, and additional information required to detail the operation of the function and which parts of the Combodo Services are being affected. 

The analytics information we collect includes elements of Content related to the function the user is performing. As such, the analytics information we collect may include Personal Information or sensitive business information that the user has included in Content that the user chose to upload, submit, post, create, transmit, store or display in an Combodo Service.

As of the date this policy went into effect, we use Google Analytics as an analytics provider. To learn more about the privacy policy of Google Analytics, refer to Google's Policies and Principles. Use the Google Analytics Opt-out Browser Add-on to prevent analytics information from being sent to Google Analytics.

  • Analytics Information Derived from Content: 

Analytics information also consists of data we collect as a result of running queries against Content across our user base for the purposes of generating Usage Data. "Usage Data" is aggregated data about a group or category of services, features or users that does not contain Personal Information. For example, we may query Content to determine the most common types of workflows that users use (e.g. what percentage of all instances use ITIL style workflows?) by searching for the most common workflow names, or we may query Content to determine the most popular job titles for iTop Hub users in order to better understand the composition of our user base.

Though we may happen upon sensitive or Personal Information as we compile Usage Data from Content across user instances, this is a byproduct of our efforts to understand broader patterns and trends. It is not a concerted effort by us to examine the Content of any particular customer.

  • Cookies and Other Tracking Technologies:

Combodo and our third party partners, such as our analytics partners, use various technologies to collect information, such as cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory. We use cookies to improve and customize Combodo Services and your experience; to allow you to access and use the Websites or SaaS Products without re-entering your username or password; and to count visits and understand which areas and features of the Websites and SaaS Products are most popular. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Websites or Products. Combodo and our third party partners also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Websites or Products or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Combodo and our third party partners also use javascript, e-tagsand HTML5 local storage to collect information about your online activities over time and across different websites or online services. Many browsers include their own management tools for removing HTML5 local storage objects.

You may be able to opt out of receiving personalized advertisements as described below under "Your Choices."

  1. How we use Information we collect

General Uses: We use the Information we collect about you (including Personal Information to the extent applicable) for a variety of purposes, including to:

  • Provide, operate, maintain, improve, and promote Combodo Services;
  • Enable you to access and use Combodo Services, including uploading, downloading, collaborating on and sharing Content;
  • Process and complete transactions, and send you related information, including purchase confirmations and invoices;
  • Send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;
  • Send promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, promotions, contests, events and sending updates about your team and chat rooms; and providing other news or information about us and our select partners. You have the ability to opt out of receiving any of these communications;
  • Monitor and analyze trends, usage, and activities in connection with Combodo Services and for marketing or advertising purposes;
  • Investigate and prevent fraudulent transactions, unauthorized access to Combodo Services, and other illegal activities;
  • Personalize Combodo Services, including by providing content, features, or advertisements that match your interests and preferences;
  • Enable you to communicate, collaborate, and share Content with users you designate; and
  • For other purposes about which we obtain your consent.

Notwithstanding the foregoing, we will not use Personal Information appearing in our Analytics Logs or Web Logs for any purpose. The use of Information collected through our Combodo Services shall be limited to the purposes disclosed in this policy.

  1. Information sharing and disclosure

We will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not sell your Personal Information or Content.

  • Your Use:

When you use Combodo Services, Content you provide will be displayed back to you. Certain features of Combodo Services allow you or your administrator to make some of your Content public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you input into Combodo Services.

  • Collaboration:

As a natural result of using Combodo Services, you may create Content and grant permission to other Combodo users to access it for the purposes of collaboration. Some of the collaboration features of Combodo Services display your profile information, including Personal Information included in your profile, to users with whom you have shared your Content. Your sharing settings may make any Information, including some Personal Information that you submit to the Combodo Services visible to the public, unless submitted to a restricted area.

  • Combodo Community:

Our Websites offer publicly accessible community services such as blogs, forums, bug trackers, and wikis. You should be aware that any Content you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account. To request removal of your Personal Information from the Combodo Community, please contact us using the information listed below. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to and why.

  • Links to Third Party Sites:

The Combodo Services may include links to other websites whose privacy practices may differ from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

  • Social Media Widgets:

The Combodo Services may contain social media features, such as the Twitter "tweet" button. These features may collect your IP address, which page you are visiting on the Combodo Services, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Combodo Services. Your interactions with these features are governed by the privacy policy of the company providing it.

  • Testimonials:

We may display personal testimonials of satisfied customers on the Combodo Services. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us using the information below.

  • Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

We may disclose your Information (including your Personal Information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of Combodo's products and services, (d) to protect Combodo, our customers or the public from harm or illegal activities, or (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

  • Business Transfers:

We may share or transfer your Information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Combodo Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

  • Aggregated or Anonymized Data:

We may also share aggregated or anonymized information that does not directly identify you with the third parties described above.

With Your Consent. We will share your Personal Information with third parties when we have your consent to do so.

  1. Information we do not share

We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes) without your permission.

  1. Data storage, transfer and security

Combodo hosts data with hosting service providers in numerous countries. The servers on which Personal Information is stored are kept in a controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any incidentally-collected Personal Information you choose to store in Websites or Products are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

Where data is transferred over the Internet as part of a Website or Product, the data is encrypted using industry standard SSL (HTTPS).

Where Downloadable Products are used, responsibility of securing access to the data you store in the Downloadable Products rests with you and not Combodo. We strongly recommend that administrators of Downloadable Products configure SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage used to hold data.

  1. Your Choices

You may opt out of receiving promotional communications from Combodo by using the unsubscribe link within each email or within your Combodo Service account settings menu, or emailing us (privacy(at) to have your contact information removed from our promotional email list or registration database. Although opt-out requests are usually processed immediately, please allow ten (10) business days for a removal request to be processed. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding Combodo's Services. You can opt-out of some notification messages in your account settings. 

  1. Accessing and updating your information

You may often correct, update, amend, or remove your Personal Information in your account settings or by directing your query to your account administrator. You may also contact Support Services, or contact us by postal mail using the address listed below. We will respond to your request for access within 30 days.

You can often remove Content using editing tools associated with that Content. In some cases, you may need to contact your administrator to request they remove the Content. You can contact us to request removal of Personal Information from Combodo Community services.

You may want to deactivate your Combodo Services account. To deactivate an account, please contact us at the contact information below. 

We will retain your account information for as long as your account is active, or as reasonably useful for commercial purposes or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If your account is managed by an administrator, that account administrator may have control with regards to how your account information is retained and deleted.

  1. Our policy towards children

Combodo Services are not directed to individuals under 13. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information. If you become aware that a child has provided us with Personal Information, please contact our Support Services.

  1. International users; Privacy Shield Related Complaints

If you are visiting from the United States of America or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your Personal Information to France to us. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.

We encourage you to contact us if you have any question or concerns about this Policy using the contact information below. 

5, Rue de l’Octant
38130 Echirolles, France

E-Mail: privacy(at) (please change (at) by @ sign before email sending)


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