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PRIVACY POLICY

Last updated: March 10, 2023


OVERVIEW

This Privacy Policy (“Privacy Policy”, “Policy”) describes how HashiCorp, Inc.
(“HashiCorp”, “we”, “us” or “our”) collects, uses, shares, processes and
protects personal information (“Personal Information”) relating to individuals
(“you”, or “your”), who may use or interact with our websites or services,
communicate with us, contact us, or attend our events. “You” may be a visitor to
one of our websites, a user of one or more of our Services (“User”), a
collaborator, or a customer (“Customer”).

HashiCorp respects your privacy and is committed to protecting your Personal
Information (any information that relates to an identified or identifiable
individual).

Note: We do not rent, sell, or trade your Personal Information without your
prior consent.


SCOPE

This Policy applies to all visitors of our websites, and users of our products,
websites, features or services, or any other HashiCorp websites that link to
this Policy (collectively, the “Websites”), unless covered by a separate privacy
policy, and explains how we collect, use, disclose, and safeguard your
information. Please note that HashiCorp's Data Protection Addendum (DPA) is the
governing document that applies to the extent that we process Personal
Information in the role of a processor (or a comparable role such as “service
provider” in certain jurisdictions) on behalf of our customers, including where
we offer to our customers various cloud products and services, through which our
customers (and/or their affiliates) connect their own applications to our hosted
platform, sell or offer their own products and services, send electronic
communications to other individuals, or otherwise collect, use, share or process
Personal Information via our cloud products and services.

Please read this Privacy Policy carefully.


DATA COLLECTIONS AND USES


OVERVIEW

This Policy describes how we collect and use your Personal Information, whether
it is shared and/or disclosed, and how we address privacy matters, such as
deletion of your Personal Information upon request, and opting-out of marketing
communications. Lastly, we describe methods for contacting us if you have
privacy questions, comments or feedback.


PERSONAL INFORMATION WE COLLECT AND RECEIVE

Transparency is one of the best ways to earn your trust. Below are the types of
personal data elements we may receive and process about you through: the use of
our website, products, or support services; attendance of our virtual and
in-person events; third party advertising and marketing partners; and
applications to our open roles. The summary sections and tables below explain in
further detail the specific personal data elements information we collect from
you or receive from third parties and why, based upon your relationship with us
and as your relationship evolves with HashiCorp

VISITORS

When you visit our public websites, without logging into an account or using our
products and/or services, we consider you a Visitor. As a Visitor, the
information we collect from you is listed below. You’re not obligated to provide
us with such Personal Information, and you are free to change or completely
opt-out of information being shared with us; however refusing to provide
requested Personal Information might prevent you from using certain features of
the Websites.

What do we collect? Why do we collect it? Can you limit collection? HashiCorp
Cookies To recognize you when you make a return visit and deliver overall a
consistent experience Most modern browsers allow you to delete or limit cookies

You can manage your cookie preferences and settings by making choices in our
cookie banner or through our cookie preference center

Third-Party Tags and Cookies To deliver an overall consistent experience, and
measure our marketing effectiveness Most modern browsers allow you to delete or
limit cookies, including third-party cookies; however, you may not be able to
limit marketing tags entirely unless you do not visit our sites

You can manage your cookie preferences and settings by making choices in our
cookie banner or through our cookie preference center

Internet Protocol (IP) Address
 * Part of the basic function of the internet
 * To measure who is visiting us and from where

The only way to avoid this is to not visit our sites Browser Metadata

(i.e. browser type, version, operating system)

 * Part of the basic function of the internet
 * To ensure we maintain a positive website experience for most used browsers

Browsers communicate this automatically; however, some third-party extensions
may allow you to limit this Log data
 * To maintain website functionality

Log data is collected automatically and may include: Internet Protocol (IP)
addresses; browser types, product versions, and operating systems, date and time
stamp, language preferences, etc. Contact Data

(i.e., Names, emails, phone numbers, etc.)

 * To respond to your inquiry via our “contact us” methods

 * This information is voluntarily shared
 * This may be required to respond to administrative or account issues or
   inquiries.

CUSTOMERS/PROSPECTIVE CUSTOMERS (MARKETING)

In addition to the data above, you may also voluntarily share Personal
Information with us, as customers or prospective customers, in order to receive
information about products and services, or to register for an upcoming event.

We may also receive information about you, such as your name, employer, title,
country, state and contact information, from third parties, such as marketing
partners, and combine it with other information we have about you. If we already
have information about you in our database in accordance with applicable data
retention periods, we would update this information. We also use data enrichment
agencies to add information, if you did not provide certain data. These data
enrichment agencies can also be located in third countries outside the European
Union, European Economic Area, or UK, in particular in the U.S. We will then use
adequate safeguards such as Standard Contractual Clauses, as updated from time
to time, and supplementary measures, where required. In addition, HashiCorp may
engage third parties to deliver advertising about our Products or Services. This
advertising helps us personalize the advertising content that is relevant to
you. The collection and use of your data by third parties is subject to the
applicable third party’s privacy policy, but the use of your data by HashiCorp
is subject to HashiCorp’s Privacy Policy.

What do we collect? Why do we collect it? Can you limit collection? Name + Email
 * To respond to your inquiry
 * Email you about product offerings, updates and other marketing promotions

 * This information is voluntarily shared, to provide individuals with relevant
   marketing materials
 * This may be required to respond to administrative or account issues or
   inquiries.
 * You can opt out of marketing emails, see the “Contact Us” section

Company Name
 * To further develop our understanding of you

 * This information is voluntarily shared; however, for marketing purposes, this
   is required

Job Title
 * To further develop our understanding of you

 * Yes, this is voluntary

Phone Number
 * To contact you

 * Yes, this is voluntary

Analytics information
 * To measure the effectiveness of our marketing activities

You can manage your preferences and settings by making choices in our cookie
banner or through our preference center


USERS/CUSTOMERS

If you choose to register for an account with HashiCorp or on our Websites, you
will share Personal Information with us.

When you register, create a User Account on our Website and begin using our
products, we consider you a User. This section describes our privacy practices
related to Users. Keep in mind Users are also considered Visitors so we collect
this data in addition to what was described for Visitors.

What do we collect? Why do we collect it? Can you limit collection? Email,
Username, and Password
 * In order to establish your account and allow you to securely access it
 * Email you about service updates, maintenance activities, security
   notifications, weekly summaries, and other account related information

 * No, these are required for us to facilitate your account lifecycle or to
   contact you
 * You can; however, opt out of marketing emails, see the “Contact Us” section

Phone Number
 * For 2-factor authentication to increase security

 * No, this is required to enable 2-factor authentication

Payment Data (credit card data, address, etc.)
 * In order to process you payment, we require the minimum amount of data NOTE:
   We do not store any financial data, as we use Stripe and/or Shopify to
   process the payments.

 * No, this is required to process your payment

Audio and video recording data
 * For sales team’s training and awareness activities.
 * At the request of a customer.

 * We only enable these functions with your consent to do so. At any time you
   may withdraw consent verbally during the call or via writing prior to or
   following the call.

Other personal data Including but not limited to:
 * To facilitate use of our website contact forms.
 * To fulfill support tickets
 * To facilitate events and attendance
 * For interactions of social media
 * Participation in surveys

 * Each of these activities are optional and personal data is provided
   voluntarily.


JOB CANDIDATES

We provide the ability to submit job applications to our open job listings and
we receive candidate information from recruitment agencies for recruitment
purposes. To appropriately respond to your application, we need to collect and
process your provided Personal Information, which may also be carried out
electronically. If we begin an employment contract with you, your submitted
application data will be stored for the purpose of processing the employment
relationship in compliance with legal requirements. We maintain your Personal
Information for the period of time necessary to carry out our legitimate
business interests and according to applicable laws. For information about
specific retention periods, please contact us at privacy@hashicorp.com

What do we collect? Why do we collect it? Can you limit collection? Contact data

(i.e., name, email, phone number, etc.)

 * In order to contact you regarding next steps for interviews, etc.

 * No, these are required for us to process applications

Resume data

(i.e., education experience, work experience, etc.)

 * To process your application and determine whether you are a fit for the
   organization.

 * No, these are required for us to process applications

Background check data

(i.e., name, email, phone number, criminal history, employment verification,
etc.)

 * To confirm your identity and eligibility for employment with HashiCorp.

 * No, these are required for us to move forward with employment.


HOW WE USE PERSONAL INFORMATION

PURPOSES OF PROCESSING

In addition to those detailed above, we will not use or share your Personal
Information in ways unrelated to those described below. We do not use automatic
decision-making or profiling, and will not sell your Personal Information for
any purpose without your prior consent.

 * Customer’s instructions. HashiCorp will only share and disclose Personal
   Information in accordance with a Customer’s instructions, including any
   applicable terms in the Customer’s agreement(s) with us, and in compliance
   with applicable laws and regulations.
 * Customer access. Owners, administrators and other Customer representatives
   and personnel, as defined in the Customer agreement(s) with us, may be able
   to access, modify, or restrict access to Personal Information.
 * To provide and maintain our products. To respond to support requests, prevent
   or address any issues, monitor usage, and improve our products.
 * Administer events. We will use personal data provided to facilitate an event
   which may include providing information to third party vendors, partners, and
   sponsors. To opt-out of this data sharing with third parties and/or request
   deletion please refer to the “Your Rights” section below.
 * To recruit candidates. We may use personal information candidates provide to
   fulfill our legitimate interest to recruit for open positions at HashiCorp.
 * Training and awareness. We may utilize different tools, such as call
   recording, which contain personal information, to help with the training and
   awareness of our employee-base. We only record calls with your explicit
   approval (which may be terminated or withdrawn at any time).
 * During a change to HashiCorp’s business. If HashiCorp is involved in a
   merger, acquisition, sale of all or a portion of our assets, or bankruptcy,
   your Personal Information would be an asset transferred to or acquired by the
   successor entity or third party. You acknowledge that such transfers may
   occur and that the transferee may process Personal Information in a manner
   different to that set out in this Privacy Policy. You will be notified by
   email and/or a prominent notice on our Websites 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 de-identified information. We may disclose or use aggregated or
   de-identified Personal Information for any purpose. For example, we may share
   aggregated or de-identified information with prospects or partners for
   business or research purposes, such as showing a total count of active users
   accessing our products. We may use aggregated and de-identified Personal
   Information to further develop our own products and services as well.
 * To enforce our rights, prevent fraud, and for safety. HashiCorp may process
   your Personal Information to protect and defend the rights, property, or
   safety of HashiCorp or third parties, including enforcing contracts or
   policies, or in connection with investigating and preventing fraud or
   security issues. In all such instances, use and disclosure will be limited as
   much as reasonably possible.

LEGAL BASIS FOR PROCESSING

Our legal basis for collecting and using the personal information described in
the above sections will depend on the personal information concerned and the
specific context in which we collect it. However, in most cases we collect the
personal information to facilitate the business relationships we have with our
Users where we have consent to do so, to fulfill contractual agreements, or to
pursue our legitimate interests where these are not overridden by the interests,
rights, or freedoms of Users. In some cases we may be required legally to
collect or disclose personal information; in which case we will make this clear.
In other cases, where we rely on an alternative legal basis, we will do so only
with the appropriate legal requirements in place. A copy of our DPA with further
details is available here. For any questions on our legal basis for processing ,
please contact us at privacy@hashicorp.com.

THIRD PARTY SHARING

We may engage third party companies or individuals as service providers or
business partners to process Personal Information and support our business. We
may share Personal Information with third parties for a variety of reasons,
including but not limited to:

 * Service providers, business partners, and subprocessors. Service providers,
   business partners, and subprocessors all help to support HashiCorp’s products
   and operations. For a full list of HashiCorp’s subprocessors that process
   Personal Information on our behalf, please refer to
   hashicorp.com/subprocessors.
 * To comply with laws. If we receive a valid request for information, we may
   disclose Personal Information if we reasonably believe disclosure is in
   accordance with or required to comply with the legal process, a government
   request, or any applicable law or regulation.


HOW LONG DO WE KEEP YOUR DATA?

We only process and keep any Personal Information for as long as necessary to
achieve the purpose for which the information was originally collected. The
exact length of time we keep Personal Information depends on our processing
purposes and the statutory retention period for that type of information. After
the statutory period of time passes, or if storage of Personal Information is
not needed, Personal Information is deleted or anonymized.


SECURITY

HashiCorp takes appropriate administrative, technical, physical, and
organizational security measures to protect your Personal Information from loss,
theft, misuse and unauthorized access, disclosure, alteration, and destruction.
We follow industry standards to protect the Personal Information submitted to
us, both during transmission and once it is received, taking into account the
nature of such information and the risks involved in processing, and comply with
applicable laws and regulations. While we have taken reasonable steps to secure
the Personal Information you provide to us, please be aware that despite our
best efforts, no security measures are perfect or impenetrable, and no method of
data transmission can be guaranteed against any interception or other type of
misuse. For more information on our practices with regards to security and
confidentiality please visit hashicorp.com/security.

If you have any questions about our security, or have reason to believe that
your interaction with us is no longer secure, please contact us at
security@hashicorp.com.


POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age
of thirteen (13). If you are under age 13, please do not give us any Personal
Information. We encourage parents and legal guardians to monitor their
children’s Internet usage and to help us enforce our Privacy Policy by
instructing them to never share Personal Information through our Websites
without their permission. If you suspect or become aware of any data we have
collected from children under age 13, please contact us immediately by emailing
privacy@hashicorp.com or by using the contact information provided below.


NOTICE TO ALL NON-U.S. RESIDENTS

Our servers are located in the U.S. If you are located outside of the U.S.,
please be aware that any information provided to us, including Personal
Information, will be transferred from your country of origin to the U.S.
HashiCorp transfers and processes data, including the data transfers under the
EU-U.S. Privacy Shield, the Swiss-U.S. Privacy Shield, the UK and EU GDPR, and
in accordance with additional applicable laws and regulations.


NOTICE FOR RESIDENTS OF THE EUROPEAN AND SWISS ECONOMIC AREAS

In order to comply with European Union and Swiss data protection laws,
HashiCorp, Inc. utilizes a comprehensive data protection addendum (DPA) that
includes compliant Standard Contractual Clauses (SCCs) for all third parties
collecting, storing, or processing personal information and is self-certified
under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield. A copy of
our DPA can be found here. These frameworks were developed to enable companies
to comply with data protection requirements when transferring Personal
Information from the European Union and Switzerland to the United States. You
can view our self-certification here.

HashiCorp is responsible for the processing of Personal Information we receive,
under Privacy Shield, and the subsequent transfers to a third-party acting as an
agent on our behalf. With respect to Personal Information received or
transferred pursuant to the Privacy Shield Framework, HashiCorp is subject to
the regulatory enforcement powers of the U.S. Federal Trade Commission. In
certain situations, HashiCorp may be required to disclose Personal Information
in response to lawful requests by public authorities, including to meet national
security or law enforcement requirements.


NOTICE FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) is a new data privacy law that
applies to certain businesses which collect Personal Information from California
residents. The law went into effect on January 1, 2020. HashiCorp now offers
data protection terms pursuant to the EU GDPR and UK GDPR in Europe and the same
terms under the CCPA. Your rights under the CCPA are described below.

Please note that HashiCorp does not rent or sell any Personal Information.

In addition, California Civil Code Section 1798.83, also known as the “Shine The
Light” law, permits California residents to request and obtain from us, once a
year and free of charge, 1) information about categories of Personal Information
(if any) we disclosed to third parties for direct marketing purposes, and 2) the
names and addresses of the third parties with which we shared Personal
Information in the preceding calendar year.

If you are under 18 years of age, reside in California, and have a registered
account with our Websites, you have the right to request removal of unwanted
data that you publicly post on our Websites. To request removal of such data,
please visit privacy.hashicorp.com to initiate the deletion directly, or contact
us using the contact information provided below, and include the email address
associated with your account and a statement that you reside in California. We
will make sure the data is not publicly displayed on our Websites, but please be
aware that the data may not be completely or comprehensively removed from our
systems due to legal and regulatory requirements.

If you are a California resident and would like to make a request, please visit
privacy.hashicorp.com to initiate the request directly or submit your request in
writing to us using the contact information provided below.


INTERNATIONAL TRANSFERS

HashiCorp is headquartered in the United States and much of the data we process
will be transferred or processed in the United States. We also store and process
personal data in: (i) any country where we have active employees, and (ii) any
country in which we engage service providers. As a result, we may transfer,
access, or store personal data outside of the European Economic Area (“EEA”),
Switzerland, the United Kingdom, or other countries that require legal
protections for international data transfer. For international transfers of
personal data, we implement measures as necessary to ensure we provide
appropriate safeguards for the transferred personal data by using one of the
following approaches:

 * We may enter into agreements with Standard Contractual Clauses or another
   lawful transfer mechanism approved by the European Commission, and as agreed
   with customers.
 * We may transfer personal data to countries with privacy laws that have been
   recognized by the country from which the data was transferred as providing
   similar data protections (“adequacy”).
 * We may rely on other transfer mechanisms approved by regulatory authorities
   in the country from which the data are transferred.

This applies only to HashiCorp practices, technologies, and services. This does
not include links to websites and online services that are operated by other
companies not under the control or direction of HashiCorp. If you provide or
submit personal information to those websites or online services, the privacy
policies on those websites or online services apply to your personal
information. We encourage you to carefully read the privacy policies of any
website you visit.

YOUR RIGHTS

We recognize, under the EU-U.S. Privacy Shield, the Swiss-U.S. Privacy Shield,
CCPA, the EU GDPR, the UK GDPR, the Brazilian General Data Protection Law
(LGPD), and other applicable privacy laws, that you may have certain rights in
regards to your Personal Information. We feel that your privacy and ability to
preserve and exercise your rights is very important. You are encouraged to
review and understand these rights as they pertain to you and your Personal
Information. In certain circumstances, these rights include, but are not limited
to:

 * Right to be Informed: This means we have to tell you why we process your
   Personal Information, our retention periods, and who it will be shared with.
 * Right of Access: This means we have to provide you with a copy of your
   Personal Information we process upon your request.
 * Right to Rectification: This allows you to have inaccurate Personal
   Information rectified, or completed if it is incomplete.
 * Right to Erasure: This allows you to have your Personal Information erased.
 * Right to Restrict Processing: This means you can limit the way we use their
   data.
 * Right to Data Portability: This allows you to receive a copy of your Personal
   Information in a structured, commonly used and machine-readable format and
   gives you the right to transmit the data to another controller without
   hindrance.
 * Right to Object: This allows you to object to the processing of your Personal
   Information at any time.
 * Right to Non-Discrimination: The CCPA prohibits covered businesses from
   discriminating against consumers for exercising their CCPA rights. This means
   we cannot charge a different price, deny access to our products, or impose
   penalties for exercising your rights under the CCPA.
 * Right to Withdraw Consent: This means you can withdraw your consent at any
   time.

In support of these rights, you may exercise any of the above rights, with
respect to your Personal Information. You may update, correct, or delete your
Personal Information; if you wish to delete or suspend your account, please note
that we may retain certain information as required by law or for legitimate
business purposes. If you have become aware that an account has been created
about you without your knowledge or consent, you may contact us to request
deletion of that said account. You may visit privacy.hashicorp.com to initiate
the deletion or contact us by emailing privacy@hashicorp.com

For your protection, we may only respond with the Personal Information
associated with the particular email address that you use to send us your
request, and we may need to verify your identity before implementing your
request. We will respond to your request within 30 days.


CHANGES TO THIS POLICY

If we make material changes to this Policy, we will revise the “Last Updated”
date at the top of this Policy, and in some cases, where required by law, we may
provide you with more prominent notice (such as adding a statement to our
homepage or sending you an email notification). Any changes or modifications
will be effective immediately upon posting of the updated Privacy Policy.

We encourage you to review the Policy whenever you access the Websites to stay
informed about our information practices and the ways you can help protect your
privacy.


CONTACT US

For any and all privacy-related matters, questions or comments, or to exercise a
right under the EU’s GDPR, the UK’s GDPR or the CCPA, you may contact us in
writing or by email. Our contact information is as follow:

HashiCorp, Inc.

℅ Security and Privacy Office

101 Second Street, Suite 700

San Francisco, CA 94105

United States

Phone: +1 (415) 301-3250

Email: privacy@hashicorp.com

Website: privacy.hashicorp.com

EU or Swiss residents with inquiries or complaints regarding this Privacy Policy
should first contact HashiCorp at privacy@hashicorp.com. Please allow a
reasonable amount of time to respond to your request. If you have an unresolved
privacy or data use concern that we have not addressed satisfactorily, please
contact our U.S.-based third party dispute resolution provider (free of charge)
at https://feedback-form.truste.com/watchdog/request.

If these processes do not result in a resolution, you may then contact your
local data protection authority, the U.S. Department of Commerce, and/or the
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