Privacy notice for Impediment Ledger for Jira

1. Scope

This notice describes how the Atlassian Forge app Impediment Ledger for Jira (the “App”) handles data. It does not cover the prflow.app website or the PR Flow desktop application, which are described in the PR Flow privacy policy.

The App is published by PR Flow, a trading name of Árpád Kozma, sole proprietor (egyéni vállalkozó), registered address Szabadság tér 6., 2337 Délegyháza, Hungary, sole proprietor registration number 62570660, tax number (EU VAT) HU92217287, email [email protected] (the “Publisher”, “we”, “us”).

The terms “personal data”, “controller”, “processor” and “processing” have the meaning given in Regulation (EU) 2016/679 (the “GDPR”).

2. Where the data is stored and who can access it

The App runs on Atlassian Forge and is hosted by Atlassian. The App's records are kept in the Forge hosted storage of the customer's Atlassian site, on Atlassian's infrastructure; the few values described in section 5 are kept in Jira itself. Forge hosted storage follows the data residency location of the customer's Jira site and is migrated with it. Atlassian aims, but does not guarantee, to run the App's processing in the same location.

The App does not send data outside Atlassian. It makes no network calls outside Atlassian and uses no external analytics, no large language model of its own and no external logging service. The App is built and checked so that it has no external egress, which Atlassian's Runs on Atlassian programme requires.

The Publisher does not access the data the App stores and cannot read, export, correct or delete it on the customer's behalf. The only action the Publisher can take on it is the one described in section 8: at the customer's request, asking Atlassian to reattach the data after a reinstall.

Actions a user takes in the App run with that user's Jira permissions. Background processing reads Jira as the App, and every result shown to a user, including reports, CSV exports and the answers of the App's Rovo agent, is filtered to the issues that user may browse.

3. Roles

The customer (the owner of the Jira site on which the App is installed) is the controller of the personal data the App stores. The Publisher processes that data on the customer's behalf as its processor, under the Data Processing Terms in section 7 of the End User License Agreement. The Publisher is responsible for this processing; Atlassian is not.

The App's code runs, and its data is stored, on Atlassian's Forge platform. Atlassian hosts that data as the Publisher's sub-processor, under the Forge Terms and the Forge Data Processing Addendum agreed between Atlassian and the Publisher, which include the EU Standard Contractual Clauses. Atlassian's own sub-processors are listed at atlassian.com/legal/sub-processors. The Publisher uses no other sub-processor for this data.

The App is built so that the data stays in the customer's site and the Publisher does not see it: the Publisher has no means, in the App or in the Forge tools it uses, to read, export, correct or delete that data, and does not do so.

The Publisher acts as controller only for the data described in section 9.

4. Data the App stores

5. Data the App does not store, and limits on what it takes from Jira

• The App does not store names, email addresses, avatars, issue summaries or issue descriptions.
• Notes and resolutions are free text. Users should not enter personal data in them. The customer is responsible for their content.
• From the comment written in Jira's flag dialog, the App only takes comments without a visibility restriction (not restricted to a group or role, and not internal). A mention is kept as “@…” without the name.
• The data the App writes to Jira's search index (JQL entity properties) contains no personal data.
• The project a user last selected on the App's page is kept in a property of that user's own Jira account (user property impediment-ledger.page), not in the App's storage. It is deleted together with the account.

6. Rovo

If Rovo is enabled on the customer's site, the App's Rovo agent answers a user's question with data filtered to the issues that user may browse, and passes Rovo structured data that is also visible in the App's interface: issue key and summary, reason, duration, expected date and the owner's account ID. It does not pass notes, resolutions or resolution drafts.

Rovo is an Atlassian service governed by the terms between the customer and Atlassian. The App itself does not call a large language model and stores nothing from the conversation.

7. Logs

The App writes technical logs to the Atlassian Forge developer console. They contain the name of the operation, its outcome, an error code, a random correlation identifier, Jira's numeric issue and project identifiers, the App version and timings. They contain no notes, no issue content and no Atlassian account IDs. Atlassian adds technical context, such as the site, the installation and the invocation.

The Publisher can see these logs unless a site admin has turned off log sharing for the App, and uses them only to operate, support and secure the App. Atlassian keeps them for its standard log retention period (currently 30 to 60 days according to Atlassian's documentation); the Publisher does not copy them elsewhere.

8. Retention and deletion

• Closed blockers and their history are deleted automatically once they are older than the project's retention period (at most 365 days; 365 days unless a project sets less). The open blocker of an issue the App has been unable to read for longer than the retention period (for example a deleted or moved issue, or one hidden by an access rule) is deleted as well.
• About once a week, the App reports the Atlassian account IDs it stores to Atlassian's personal data reporting API. When Atlassian reports an account as closed, the App removes or replaces every stored reference to that account ID, normally within the next processing runs. Notes and resolutions are kept, but no longer linked to the account ID; personal data that users typed into their text is not removed automatically and can be edited in the App or deleted through the retention period.
• When the App is uninstalled, Atlassian keeps the App's data for the period set by its Forge data lifecycle (currently 28 days) and then deletes it. Reinstalling does not restore the data automatically. If the customer asks within 21 days of uninstalling, the Publisher will ask Atlassian to reattach the data to the reinstalled App; data written by the reinstalled App before the reattachment may be overwritten.
• Uninstalling the App does not remove any flag from Jira issues.

9. Data the Publisher processes as controller

Support and other contacts

When you contact the Publisher (for example at [email protected]), we process your name, email address and the content of your message to answer you and to resolve your request, based on our legitimate interest in providing support (Article 6(1)(f) GDPR) or, where you contact us as a customer, to perform our agreement (Article 6(1)(b) GDPR). We keep this correspondence for two (2) years after the request is closed, or longer where needed to establish, exercise or defend legal claims, at most until the end of the five-year general limitation period under Hungarian law.

Marketplace partner data

Atlassian makes licence and sales information available to the Publisher as a Marketplace partner: the customer's organisation name, country and site, the licence details (identifier, tier, start and end dates), the transaction details (amounts and dates) and, where provided, the name and email address of the technical and billing contacts. The Forge developer console also shows the Publisher which sites have the App installed.

The Publisher uses this data to administer licences, provide support and send the notices described in the End User License Agreement, based on its legitimate interest in running and supporting the App (Article 6(1)(f) GDPR), and to keep its accounting records (Article 6(1)(c) GDPR, Act C of 2000 on Accounting). It is not used for marketing without consent. The Publisher keeps it for the duration of the licence and five (5) years after it ends (the general limitation period under Hungarian law); records that form part of the Publisher's accounting records are kept for eight (8) years, as section 169 of Act C of 2000 on Accounting requires.

Recipients and transfers

The Publisher shares this data only with the service providers that need it: its email provider, Google Cloud EMEA Limited (Ireland), which provides Google Workspace, and Atlassian when a support request requires it. Google LLC and its affiliates process the data as Google's sub-processors; transfers to the United States are covered by the EU–U.S. Data Privacy Framework and the European Commission's Standard Contractual Clauses. The Publisher does not sell personal data and does not make decisions based solely on automated processing.

10. Your rights

For the data the App stores, the customer is the controller, so requests to access, correct, delete or restrict that data should go to the customer (usually your employer or the administrator of your Jira site). The App supports these requests as follows:

• A Jira admin can export every record the App stores, as JSON Lines, from the App's Data tab.
• Reasons, notes, owners, dates and resolutions can be corrected in the App's interface.
• Data is deleted through the project's retention period, or when the Atlassian account is closed.
• An inactive licence does not prevent the export or the deletion of closed accounts.

For the data described in section 9 you have the rights of access, rectification, erasure, restriction, data portability and objection under the GDPR. Write to [email protected]. You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement. In Hungary this is the Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH), 1055 Budapest, Falk Miksa utca 9–11; postal address 1363 Budapest, Pf. 9; naih.hu; [email protected]. You may also go to court.

11. Security

Actions a user takes in the App run with that user's Jira permissions, and every result shown to a user is filtered by what that user may browse. To report a security issue, write to [email protected].

12. Changes to this notice

We may update this notice, for example when the App changes. The date at the top shows the latest version. Material changes will be announced in the App's release notes or on its Marketplace listing, and notified to Atlassian as the Marketplace Partner Agreement requires.

13. Language

This notice is written in English, and the English version is binding. Translations are provided for convenience only; in case of any discrepancy, the English version prevails. See also the End User License Agreement and the support page.