# Privacy Policy

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Table of Contents

### Product Terms

Terms of Service

Standard Service Level Agreement

Product-Specific Terms

### Partner Terms

One-Time Reseller Agreement

### Policies & Other Terms

Privacy Policy

Acceptable Use Policy

Community Policy

Champions Terms

DMCA Takedown Notice

Subprocessors

Support Policy

CSE Usage Policy

Jeli Legacy Support Policy

Process Automation

Data Processing Addendum

Information Security Practices

Modern Slavery Act

Safe Harbor

Cigna Machine Readable Files

Event Terms

Trial Terms

### Security

Overview

Security Disclosure

Safe and Secure Generative AI

In Scope Services

### Privacy

Privacy FAQs

Privacy Shield and Schrems II

PagerDuty's GDPR Approach

Region-Specific Data Privacy Laws

**Effective Date: September 1, 2025**

**California Residents**: Click
here to see our additional privacy information for
California residents.

Your privacy is of the utmost importance to PagerDuty, Inc.
(“**PagerDuty**” or “**we**”) and we take our
obligations regarding your privacy seriously.

We have developed this Privacy Policy to describe how we collect, use and
disclose your personally identifiable information (“**PII**”
or “**personal data**“) when:

you access or use our websites such as those found at
pagerduty.com,
rundeck.com,
and catalytic.com
(“**Website**” or “**Websites**”);

we collect information about your access or use any of the
Software-as-a-Service hosted services, software, web applications, and
mobile applications (“**Online Services**”) that we operate and
which link to this policy (“**Service Usage Data**“);

PagerDuty conducts its business operations activities such as sales
activities, marketing activities, user experience activities, event
activities, support services, consulting services, training services, or
when you otherwise interact with PagerDuty, including both online and
offline interactions (“**Business Operations**”); and

when PagerDuty recruits potential candidates for employment, such as
when you apply for a position with us
(“**Recruitment Opportunities**”).

Our Websites, Online Services, Business Operations, and Recruitment
Opportunities are collectively referred to in this Privacy Policy as our
“**Services**”.

This Privacy Policy does not apply to personal data that is processed as
part of a data processing agreement with you or your employer.

## Consent

This section does not apply if you are based in the European Economic Area
(“**EEA**”) or Switzerland. By using our Services, you agree
to the terms and conditions contained in this Privacy Policy and you
expressly consent to the processing of your data in accordance with this
Privacy Policy. If you do not agree to any of these terms and conditions,
or approve of PagerDuty’s data practices as explained herein, then you
should immediately cease all use of our Services. To the fullest extent
permitted by applicable law, you agree that any dispute over privacy or
the terms contained in this Privacy Policy and Terms of Use, or any other
agreement we have with you, will be governed by the laws of the state of
California.

## What Data We Collect

PagerDuty collects the following types of PII:

### PII You Provide

If you interact with our Services, PagerDuty may collect the following
categories of PII from you: (1) identifiers and customer records
(e.g., name, email address, phone number), (2) employment and
professional information, (3) Internet activity information (e.g.,
online identifiers), (4) geolocation information (including
state/province and country), (5) where applicable, authentication
credentials for your account, and (6) audio, electronic, or visual
information (such as recorded customer service interactions, and
photos or videos that you might submit). Additionally, when you
interact with our Services you may submit content, feedback, and other
communications that may contain other categories of PII that you
choose to include. If you purchase services or products from us, we
will also collect commercial information, payment account, and other
financial information. If you apply for a job, we may also collect
information that may be considered sensitive, depending on your
jurisdiction. For example, you may provide us demographic information
(such as your racial or ethnic origin, religious or philosophical
beliefs, or union membership), and we may require your application to
include government identifiers, such as your social security, driver’s
license, state identification card, or passport number.

We may combine the information we collect directly from you with
information we obtain from public sources, partners, and other third
parties and use such combined information in accordance with this Privacy
Policy. We may also make inferences about you drawn from the information
described above.

### PII We May Receive From Your Use of the Services.

When you interact with our Services, we may collect Service Usage Data
and receive the following categories of PII, including through
cookies, web beacons and other tracking technologies: (1) identifiers
and customer records (e.g., name, email address, phone number, mailing
address including state/province, country, and other information you
fill out in webforms), (2) commercial information (such as products or
services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies), (3) internet activity information
(e.g., IP address, cookie information (such as cookie ID), ad IDs,
device information (such as device ID), user agent information (such
as browser type and operating system), browsing history, and other
information about how you interact with our Services), (4) geolocation
data (e.g., country of residence and approximate location, such as
inferred from your IP address), (5) login information (e.g., your
account name and password), and (6) inferences drawn from any of the
above information categories.

### PII We May Receive From Other Sources

We may also collect any of the following types of information about
you from other sources, including from your organization, from third
parties (such as PagerDuty’s partners, event co-sponsors, or parties
from whom we have purchased information), or from other publicly
available sources (such as your company’s website, social networking
services, or press materials):

identifiers and customer records ( such as name, email address, phone
number, mailing address including state/province, country);

professional or employment-related information ( such as current and
historical company information, industry, and title);

- commercial information (such as purchase history);

Internet activity information (such as browser activity and social
networking activity );

- geolocation information (including state/province and country).

The way in which these third parties collect PII is detailed in their own
privacy policies, available on their websites. We may combine this
information with PII provided by you and draw inferences from any of the
above categories.

## How We Use the Data We Collect

PagerDuty uses the data we collect, including data collected using
cookies, web beacons and other tracking technologies, for the following
purposes:

Facilitate the creation of and secure your account on the Services;

- Identify you as a user of the Services;

- Provide, administer, and support your use of the Services;

- Train our personnel;

- Analyze and improve our Services;

Personalize and improve the quality of your experience when you interact
with our Services;

Send you administrative notifications, such as security or support and
maintenance messages;

Respond to your inquiries and requests, including through chat features;

Provide you with marketing communications (such hardcopy or electronic
newsletters and information about upgrades and special offers) or user
surveys;

- Market and sell our products to our customers and prospects;

Determine which of our Services may be of interest to you or your
business and personalize the Services;

- Send you information about jobs of interest to you;

Facilitate and process job applications and determine eligibility for
career opportunities;

- Comply with applicable laws and regulatory requirements;

- Respond to lawful requests, court orders and legal process; and

- Protect our legal interests or those with whom we do business.

## Information Disclosure

To the extent permitted by applicable law, PagerDuty may disclose your PII
for the purposes described in Section III, in the following circumstances:

### Service Providers.

We may engage our affiliates or third-party companies or individuals
to support us in connection with the purposes listed above, such as to
provide IT services, process payments or contact users where an alert
is triggered.

### Analytics and Advertising Providers.

We may engage certain third party companies who are not service providers
to provide analytics and/or to advertise our services. These third party
companies, include, but are not limited:

Google: For more information on how Google uses data, visit:

google.com/policies/privacy/partners. To opt out of Google cookies,
visit:
www.google.com/settings/ads and

tools.google.com/dlpage/gaoptout.

Meta: Meta may use cookies, web beacons, and other storage technologies
to collect or receive information from our Websites and elsewhere on the
Internet and use that information to provide measurement services,
target and deliver ads, including on Meta’s platforms. For more
information, refer to Meta’s disclosures regarding adjusting the ads you
see on Meta’s platforms.

Microsoft Advertising: For information on how Microsoft collects or
receives PII to provide service through Bing Ads, see the Microsoft
Privacy Statement.

YouTube: Our Websites may allow you to access content using the YouTube
API. YouTube may collect certain PII, such as the types of data
described above in this section, about you through the YouTube API.
YouTube’s collection of PII is subject to the Google privacy policy,
available at

https://www.google.com/policies/privacy.

We are not responsible for the effectiveness of, or compliance with,
external-parties’ opt-out options or programs or the accuracy of their
statements regarding their programs.

### Legal Process.

It may be necessary — by law, legal process, litigation, and/or requests
from public and governmental authorities within or outside your country of
residence — for PagerDuty to disclose your PII. We may also disclose your
PII if we determine disclosure is reasonably necessary to enforce our
terms and conditions or protect our operations or users.

### Business Transfer.

We may share your PII if PagerDuty engages in a merger, acquisition,
bankruptcy, dissolution, reorganization, sale of some or all of
PagerDuty’s assets, financing acquisition of all or a portion of our
business, a similar transaction or proceeding, or steps in contemplation
of such activities (e.g. due diligence).

We may also disclose your PII with your prior informed consent. Service
providers acting on our behalf are obliged to adhere to confidentiality
requirements no less protective than those set forth herein and will only
receive access to your PII as necessary to perform their functions.

We may transfer PII (including personal data about residents of the EEA
and Switzerland) to our vendors, consultants and other service providers
who need access to such PII to carry out work on our behalf. PagerDuty
will be liable for the processing of such PII by a third party service
provider unless we can prove that we are not responsible for the event
giving rise to the damages. We may also be required to disclose such PII
in response to lawful requests by public authorities, including to meet
national security or law enforcement requirements.

## How We Protect Your Data — Security

We are committed to protecting the security of information received via
the Online Services, including PII. We provide reasonable and appropriate
administrative, technical, and physical security controls to protect your
PII from unauthorized access, use, or disclosure. For example, we use
secure socket layer technology (SSL) in connection with our Online
Services. We also require you to enter a password to access your account
information. Please do not disclose your account password to anyone else.
Despite our efforts, no security controls are 100% risk-free, and
PagerDuty does not warrant or guarantee that your PII will be secure in
all circumstances. To learn more about our current security practices and
policies, please view our
Information Security Practices; we keep this document updated as these
practices evolve over time.

## Your Data, Your Choice

Please note if you are a California resident, please see the
“Additional Information for California Residents”
section below for information about your privacy rights under California
law.

### Opt-Out.

Marketing communications: We offer you choices regarding the
collection, use, and sharing of your PII. Where permitted by
applicable law, we will periodically send you communications that
directly promote our Services. When you receive such communications
from us, you may indicate a preference to stop receiving further
communications from us and you will have the opportunity to “opt-out”
by following the unsubscribe instructions provided in the
communications you receive, managing your preferences (e.g.

marketing email notification preferences) or by contacting us
directly. Despite your indicated marketing communication preferences,
we may continue to send you operational messages, including notices of
any updates to our Terms of Use or Privacy Policy.

Cookies: You may adjust your preferences in relation to cookies and
similar technologies on the Websites that use cookies by clicking on the
“Cookie Settings” link at the bottom of those Websites. For browsers, you
may also be able to adjust your browser settings to remove or reject
cookies. Some browsers may have a “Do Not Track” setting. Please note that
the Websites are not designed to respond to “Do Not Track” settings. For
mobile devices, you may also be able to use mobile device settings to
limit mobile tracking technologies and associated activities. For
instance, you can adjust or reset the advertising identifiers on your
mobile device in the device settings. iOS users can visit Settings >
Privacy > Advertising > Reset Advertising Identifier. Android users
can visit Google settings > Ads > Reset advertising ID. Finally,
certain advertising vendors may participate in the Digital Advertising
Alliance AdChoices Program for websites (www.youradchoices.com) and mobile
applications (www.aboutads.info/appchoices), or in the Network Advertising
Initiative’s opt out program for certain targeted advertising for websites
(www.networkadvertising.org/choices) and mobile applications
(www.networkadvertising.org/mobile-choice). Please be aware that, even if
you are able to opt out of certain kinds of interest-based ads, you will
continue to receive non-targeted ads.

### Ability to Edit or Delete Your PII.

You may edit certain PII in your account on the Online Services,
including contact information and/or notification settings, by editing
your account profile. You may also request that we delete your account
information by sending an email to support@pagerduty.com, but
please note that we may be required (by law or otherwise) to keep this
information and not delete it (or to keep this information for a
certain time, in which case we will comply with your deletion request
only after we have fulfilled such requirements). PagerDuty will
respond to such requests within thirty (30) days or sooner if required
by applicable law. When we delete account information, it will be
deleted from the active database, but may remain in our archives for a
limited amount of time. We will otherwise retain your information for
as long as your account is active, as needed to provide you with the
Online Services you have requested, or as necessary to comply with our
legal obligations, resolve disputes, and enforce our agreements.

### Information Processed Under the Direction of Customers.

If an organization has registered for the Online Services (a
“**Customer**“) and your PII has been collected by
PagerDuty as a result of such organization’s use of the Online
Services, PagerDuty collects and processes any such PII of yours under
the directions of the relevant Customer. If these circumstances apply
to you and you wish to access, edit, delete or exercise any rights you
may have under applicable data protection laws with respect to any PII
that we have collected about you, please direct your query to the
relevant Customer as this may expedite the completion of your request.
We nevertheless provide reasonable assistance to our Customers to give
effect to data subject rights as appropriate and required by
applicable laws.

## Third-Party Links or Functionalities

Our provision of a link to any website or location outside of the Services
is for your convenience and does not signify our endorsement of such other
website or location or its contents. When you click on such a link, you
will leave our site and go to another site. During this process, a third
party may collect data, including PII, from you. Please be aware that the
terms of this Privacy Policy do not apply to these outside websites or
content, or to any collection of data after you click on a link to a third
party. We encourage you to carefully read the privacy statement of any
other website you visit.

Certain of our Services may contain functionality provided by third
parties. Your use of these functionalities is voluntary, and we may retain
the information that you submit through these features. For example, we
may use a third party to provide an interactive job application process.
This Privacy Policy does not apply to the practices of those companies
that we do not own or control. We provide these functionalities for your
convenience, and we have no control over, do not review, and are not
responsible for external online services.

## Additional Information for California Residents

The disclosures in this section apply only to California residents and are
intended to supplement this Privacy Policy with information regarding how
we collect, use, and share your “personal information” (as defined in the
California Consumer Privacy Act (“CCPA”)), as required by California law.

### Collection, Use, and Disclosure of Personal Information for Business
Purposes

California law requires that we detail the categories of Personal Data
that we collect, use, and disclose for certain “business purposes”.
These practices are described in Sections II (“What Data We Collect”),
III (“How We Use the Data We Collect”), and IV (“Information Sharing
and Disclosure”) of this Privacy Statement.

### Your California Privacy Rights.

If you are a California resident, the CCPA allows you to make certain
requests about your personal information. Specifically, the CCPA
allows you to request us to:

Inform you about the categories of personal information we collect or
disclose about you; the categories of sources of such information; the
business or commercial purpose for collecting your personal information;
and the categories of third parties with whom we share/disclose personal
information.

Provide access to and/or a copy of certain personal information we hold
about you.

- Correct personal information we hold about you, if inaccurate.

- Delete certain personal information we have about you.

Provide you with information about the financial incentives that we
offer to you, if any.

The CCPA further provides you with the right not to be discriminated
against (as provided for in applicable law) for exercising your rights.
Please note that certain information may be exempt from such requests
under California law. For example, we need certain information in order to
provide our services to you. We also will take reasonable steps to verify
your identity before responding to a request. In doing so, we may ask you
for verification information so that we can match at least two
verification points with information we maintain in our files about you.
If we are unable to verify you through this method, we shall have the
right, but not the obligation, to request additional information from you.

Please also note that if your personal information has been collected by
PagerDuty as a result of a Customer’s (as defined above) use of our
services, PagerDuty collects and maintains your personal information under
the directions of the relevant Customer. If these circumstances apply to
you and you wish to access or delete any personal information that we have
collected about you, please direct your query to the relevant Customer as
this may expedite the completion of your request. We nevertheless provide
reasonable assistance to our Customers to give effect to consumer choices
as appropriate and required by applicable laws.

If you would like further information regarding your legal rights under
California law or would like to exercise any of them, or if you are an
authorized agent making a request on a California consumer’s behalf,
please contact us at
privacy@pagerduty.com.

If you are a California resident, you have the privacy right to opt
out of your personal information from being sold or shared for
cross-context behavioral advertising purposes. To opt out of these
purposes, go to the form at this link and follow
the instructions.

Shine the Light Disclosure: The California "Shine the Light"
law gives residents of California the right under certain
circumstances to request information from us regarding the manner in
which we share certain categories of personal information (as defined
in the Shine the Light law) with third parties for their direct
marketing purposes. We do not share your personal information with
third parties for their own direct marketing purposes.

## Additional information for Nevada residents

Under Nevada law, certain Nevada consumers may opt out of the sale of
“personally identifiable information” for monetary consideration (as such
terms are defined under Nevada law) to a person or that person to license
or sell such information to additional persons. We do not engage in such
activity; however, if you are a Nevada resident and you have purchased
products or services from us, you may submit a request to opt out of any
potential future sales under Nevada law by emailing us at privacy@pagerduty.com. Please note
we may take reasonable steps to verify your identity and the authenticity
of the request. Once verified, we will maintain your request in the event
our practices change.

## Information about Children

Our Online Services are not intended for use or access by children or
minors. PagerDuty does not knowingly collect or solicit information from
anyone under the age of thirteen (13). If you believe PagerDuty has
inadvertently collected information about a child under the age of
thirteen (13), please contact us at privacy@pagerduty.com immediately
using the contact information below.

## Changes to Our Privacy Policy

PagerDuty reserves the right to change this Privacy Policy. PagerDuty will
provide notification of the material changes to this Privacy Statement
through our pagerduty.com Website and, where appropriate, by email to any
email address of yours we may have on file, at least thirty (30) days
prior to the change taking effect.

## Contact Us

Thanks for reading our Privacy Policy. PagerDuty welcomes your comments,
questions, and concerns regarding our Privacy Policy. Please contact us at
privacy@pagerduty.com or at our
mailing address below:

PagerDuty, Inc.

Attn: Legal Department

600 Townsend St. #200

San Francisco, CA 94103 USA

## Supplemental GDPR Privacy Statement

**Scope:** This Supplemental GDPR Privacy Statement is relevant
to any individual located in the European Economic Area who uses or visits
PagerDuty’s Online Services where these services directly link to this
Supplemental GDPR Privacy Statement.

This Supplemental GDPR Privacy Statement does not cover any other data
collection or processing, including, without limitation, through other
PagerDuty Websites or online services that do not display a direct link to
this Supplemental GDPR Privacy Statement, or through third-party websites.

European Union Regulation 2016/679 of 27 April 2016 on the protection of
natural persons with regard to the processing of personal data and on the free
movement of such data (“**EU GDPR**“), requires PagerDuty to
provide additional and different information about its data processing
practices to data subjects in the European Economic Area
(“**EEA**“). If you are accessing the Online Services from a
member state of the EEA, this Supplemental GDPR Privacy Statement applies to
you.

PagerDuty, Inc., 600 Townsend St., #200, San Francisco, CA 94103, is the data
controller, and can be contacted at privacy@pagerduty.com. Its
representative in the EU is Adam Brogden and can be contacted at contact@gdprlocal.com.

**Legal Basis of Processing**. In general, the legal basis for
PagerDuty’s processing of your personal data in connection with the Online
Services is Article 6(1)(b) of the EU GDPR, which allows processing of
personal data as necessary for the performance of a contract. When you access,
use or register for our Online Services, you form a contract with us based on
the applicable terms of use or terms of service, and PagerDuty needs to
process your personal data to provide the requested Online Services.

As exceptions, PagerDuty relies on your consent with respect to cookies that
are not strictly necessary and direct marketing emails per Article 6(1)(a) of
the EU GDPR; and pursues legitimate interests under Article 6(1)(f) of the EU
GDPR with respect to situations where PagerDuty needs to process your personal
data for other purposes listed in Section 3.

**Personal Data Transfers outside of the EEA**. PagerDuty may
transmit some of your personal data to a country where the data protection
laws may not provide a level of protection equivalent to the laws in your
jurisdiction, including the United States. As required by applicable law,
PagerDuty, Inc. will provide an adequate level of protection for your personal
data using various means, including, where appropriate:

relying on a formal decision by the European Commission that a certain
country ensures an adequate level of protection for personal data (a full
list of such decisions may be accessed online here:

https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
);

entering into appropriate data transfer agreements based on language
approved by the European Commission, such as the Standard Contractual
Clauses (2010/87/EC and/or 2004/915/EC), which are available upon request at
privacy@pagerduty.com;

implementing appropriate physical, technical and organizational security
measures to protect Personal Data against accidental or unlawful
destruction, accidental loss or alteration, unauthorized disclosure or
access, and against all other unlawful forms of processing; and

taking other measures to provide an adequate level of data protection in
accordance with applicable law.

Any onward transfer is subject to appropriate onward transfer requirements as
required by applicable law.

**Data Retention**. PagerDuty keeps personal data as long as
required to provide the Services you have requested or registered for and
comply with applicable laws.

**Data Subject Rights**. You have a right to request from
PagerDuty access to and rectification or erasure of your personal data or
restriction of processing concerning you, as well as the right to data
portability under the EU GDPR. You also have the right to object, on grounds
relating to your particular situation, at any time to the processing of your
personal data by us and we can be required to no longer process your personal
data. In general, you have the right to object to our processing of your
personal data for direct marketing purposes. If you have a right to object and
you exercise this right, your personal data will no longer be processed for
such purposes by us. You can exercise such rights by accessing the information
in your account, submitting a request
here,
and/or by emailing
privacy@pagerduty.com.

If you have provided consent for cookies that are not strictly necessary,
direct marketing emails or other data processing based on your consent, you
have the right to withdraw your consent at any time, without affecting the
lawfulness of processing based on consent before its withdrawal. You have the
right to lodge a complaint with a supervisory authority.

**Profiling**. PagerDuty does not use in connection with the
Online Services automated decision-making, including profiling, in a way that
produces legal effects concerning you or which significantly affects you.

## The E.U.-U.S. Data Privacy Framework

PagerDuty complies with the E.U.-U.S. Data Privacy Framework (“E.U.-U.S. DPF”), the U.K. Extension to the E.U.-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) (together, the “DPF”). PagerDuty has certified to the U.S. Department of Commerce that it adheres to each of the respective DPF Principles with regard to the processing of personal data. To learn more about the DPF programs, and to view our certification, please visit https://www.dataprivacyframework.gov/.

If you are located in the E.U., U.K., or Switzerland, PagerDuty has committed to resolving complaints you may have about the collection and processing of your personal data or our participation in the DPF programs. If you have a question or complaint, you should first reach out to PagerDuty directly at privacy@pagerduty.com. If we do not respond, or if you are unhappy with our response, we have partnered with JAMS, an alternative dispute resolution provider based in the United States, to process further complaints at no cost to you. You can file a complaint with JAMS here: https://www.jamsadr.com/DPF-Dispute-Resolution. If you feel that neither PagerDuty nor JAMS has resolved your complaint, you may request that your complaint be submitted to the Data Privacy Framework Panel for binding arbitration.

As further described above in our Privacy Policy, PagerDuty may sometimes share personal data with third parties, who perform services on our behalf. If we transfer personal data received under the Data Privacy Framework to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our Data Privacy Framework obligations, and we will remain liable under the Data Privacy Framework if the third party fails to comply with these obligations unless we prove we are not responsible for the event giving rise to the damage.

The U.S. Federal Trade Commission has jurisdiction over PagerDuty’s compliance with the DPF. PagerDuty may be required to disclose personal information to public authorities who issue lawful and binding legal requests, including to meet national security or law enforcement requirements. To learn more about the Data Privacy Framework Panel, please visit https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf.