I. Name and Address of the Responsible Person

The responsible person within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is:

Thorsten Büring

Bommershöfer Weg 46

40670 Meerbusch

Germany

E-Mail: LinkMap@buering.net

II. Name and Address of the Data Protection Officer

The data protection officer is identical with the responsible person listed above.

III. General Information on Data Processing

1. Scope of the Processing of Personal Data

As a matter of principle, we process personal data of our users only to the extent that this is necessary to provide a functional add-on based on the Atlassian Connect Framework and Atlassian Forge platform. The processing of personal data of our users is regularly carried out only after the consent of the user. An exception applies in those cases where obtaining prior consent is not possible for factual reasons and the processing of the data is permitted by legal regulations.

2. Legal Basis for the Processing of Personal Data

In so far as we obtain the consent of the data subject for processing operations of personal data, Art. 6 (1) lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

To the extent that processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d GDPR serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) lit. f GDPR serves as the legal basis for the processing.

3. Data Deletion and Storage Duration

The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Blocking or deletion of the data will also take place if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

IV. Technology Architecture and Data Flow

1. Hybrid Architecture: Forge and Connect Remote

LinkMap operates as a hybrid application combining Atlassian Forge (frontend) and Atlassian Connect (backend remote):

• Forge Frontend: User interface components run on Atlassian's infrastructure using the Forge platform. Atlassian acts as a processor for any data handled by Forge components.
• Connect Remote Backend: Application logic and database operations run on our infrastructure hosted by Heroku (Europe region). We act as the controller for data processed by the backend.
• Data Flow: User interactions in the browser communicate with both Atlassian Cloud REST APIs (directly) and our backend services (via Forge remote invocations). This architecture ensures optimal performance while maintaining data security.

2. Infrastructure and Sub-Processors

Hosting Provider: Heroku (Salesforce), European region

• Heroku provides Platform-as-a-Service (PaaS) hosting for our backend application and managed PostgreSQL database
• Heroku/Salesforce complies with GDPR and has appropriate Data Processing Agreements (DPA) in place
• Data is stored exclusively in the European region
• Standard Contractual Clauses (SCCs) apply for any international data transfers
• For details, see: Heroku GDPR Compliance and Salesforce DPA

Atlassian as Sub-Processor: For Forge components, Atlassian acts as a sub-processor. Atlassian's data processing practices are governed by the Atlassian Forge Data Processing Addendum. See: Forge DPA

No Other Third Parties: We do not share collected data with any other third-party organizations, services, or processors beyond Heroku (hosting) and Atlassian (Forge platform).

V. Provision of the Add-on and Creation of Log Files

1. Description and Scope of Data Processing

Each time our add-on is called up, our system automatically collects data and information from the calling Atlassian Cloud instance and from the computer system of the calling computer.

The following data is collected and processed:

a) Installation and Authentication Data (stored until app uninstallation):

• The base URL of your Atlassian Cloud instance
• The description of your Atlassian Cloud instance
• The client key of your Atlassian Cloud instance
• The name of the instance such as 'Jira' or 'Confluence'
• The public key of your instance used for JWT authentication between the add-on and Atlassian Cloud

b) Personal Data - User Account Information (stored until app uninstallation or account closure):

• Atlassian Account ID: A unique identifier assigned by Atlassian to each user. This is the only personal data we store and is used to associate saved layouts and individual app settings with specific users.
• Data Category: Online identifier pursuant to Art. 4(1) GDPR
• Storage Format: Stored in plain text in our Heroku-hosted PostgreSQL database
• Purpose: Essential for providing personalized functionality (saved layouts and user-specific settings)
• Legal Basis: Art. 6(1)(b) GDPR (performance of contract) and Art. 6(1)(f) GDPR (legitimate interest in providing personalized service)

c) Application Configuration Data (stored until app uninstallation or user deletion):

• When the LinkMap save functionality is used: JQL query, IDs of expanded issues, X and Y positions of issues on the map, user-created labels, link direction, filter settings, and visualization preferences
• Individual LinkMap settings for the context widget embedded in the issue view: number of link levels to display, link direction, and display preferences
• Whether the latest release notes have been shown to the user
• Note: This configuration data is associated with the user's Account ID but does not itself constitute personal data under GDPR

d) Log Files (stored for 7 days maximum):

• Technical log data for system operation and error diagnosis
• No personal data is logged in application logs
• Logs may include: timestamps, request types, error messages, and system performance metrics
• IP addresses, if logged, are anonymized or deleted after 7 days maximum

Data Categories Summary:

Data Type	Personal Data?	Storage Location	Retention
Atlassian Account ID	Yes (online identifier)	Heroku PostgreSQL (EU)	Until uninstall or account closure
Instance authentication keys	No	Heroku PostgreSQL (EU)	Until uninstall
Saved layouts and settings	No (associated with Account ID)	Heroku PostgreSQL (EU)	Until uninstall or user deletion
Application logs	No (anonymized)	Heroku (EU)	7 days maximum

2. Legal Basis for the Data Processing

The legal basis for the storage and processing of authentication data and log files is Art. 6 para. 1 lit. f GDPR (legitimate interest in providing and securing the service).

The legal basis for storing the Account ID and associated configuration data is Art. 6 para. 1 lit. b GDPR (performance of contract to provide personalized app functionality).

3. Purpose of Data Processing

The storage of authentication data is necessary to enable delivery of the add-on functionality and to establish secure communication between your Atlassian instance and our service.

The storage of the Account ID is necessary to provide personalized features including saved layouts and individual settings that persist across sessions.

The storage in log files is done to ensure the functionality, security, and reliability of the add-on. We use the data to optimize the add-on and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place.

In these purposes also lies our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.

4. Duration of Storage

Account ID and User Settings: Your Account ID and associated configuration data (saved layouts, settings) are stored until:

• The app is uninstalled from your Atlassian instance (automatic deletion), or
• Your Atlassian account is closed or deactivated (deletion within 24-48 hours via automated check using Atlassian Personal Data Reporting API), or
• You request deletion of your data (manual deletion upon request)

Authentication Data: Instance authentication data is deleted when the app is uninstalled from your Atlassian instance.

Log Files: Application logs are automatically deleted after 7 days maximum. Anonymized logs may be retained longer for security analysis.

5. Automated Data Deletion via Privacy API

LinkMap uses the Atlassian Personal Data Reporting API to ensure GDPR compliance:

• We report all Account IDs for which we store personal data to Atlassian
• This information is made available to users on their Atlassian Account profile
• Approximately once per day, we query the API to identify closed or deactivated accounts
• When an account closure is detected, we automatically delete the Account ID and all associated data (saved layouts, settings) from our database within 24-48 hours
• This process ensures compliance with GDPR Art. 17 (Right to Erasure) for closed accounts

6. Data Residency

Current Implementation: All data collected by the Connect Remote backend is stored in the European region via Heroku's European data centers. However, LinkMap does not currently support Atlassian's Data Residency feature for automatic migration when customers move their Atlassian instance to different regions.

Forge Framework: For data processed by Forge components, Atlassian automatically handles data residency according to the customer's Atlassian instance location. See Forge Data Residency documentation for details.

7. Possibility of Objection and Removal

The collection of authentication data for the provision of the add-on is mandatory for the operation of the add-on.

The storage of Account ID is necessary to provide personalized functionality (saved layouts and settings). If you wish to use the app without storing personal data, you may choose not to use the save functionality. Alternatively, you may request deletion of your Account ID and associated data at any time by contacting us at LinkMap@buering.net, though this will result in loss of all saved layouts and settings.

VI. Permission Scopes and Data Access

1. Required Permission Scopes

LinkMap requests the following permission scopes from Atlassian. Each scope is necessary for specific functionality and follows the principle of least privilege:

Scope	Purpose and Justification
read:jira-work	Essential: Read issue and link data for visualization (core functionality)
read:connect-jira	Required: Validate JQL queries
read:jql:jira	Essential: Execute JQL searches to define issue scope for layouts
delete:issue-link:jira	Required: Allow users to delete links (user-initiated action only, respects permissions)
read:sprint:jira-software	Feature: Apply LinkMap to sprint issues in Jira Software
read:app-user-token	Architecture: Enable remote backend to invoke Atlassian APIs with user permissions (Forge remote requirement)
report:personal-data	GDPR Compliance: Use Personal Data Reporting API to identify closed accounts for data deletion

2. User Permission Context

All data access through LinkMap is performed in the context of the authenticated user. The app respects your Atlassian instance's permission configuration, meaning users can only access and visualize data they are already authorized to see in Jira or Confluence.

VII. Use of Cookies

Our add-on does not set or use cookies for tracking, analytics, or any other purpose.

The Atlassian Connect Framework and Forge platform may set cookies necessary for authentication and secure communication. For information about cookies set by Atlassian, please see:

• Atlassian Connect Security Overview
• Atlassian Privacy Policy

Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

VIII. No Tracking or Analytics

LinkMap does not use any tracking or analytics services such as Google Analytics. We do not track, monitor, or analyze user behavior within the application. We do not collect data about which features you use, how often you use them, or any usage patterns.

IX. No Automated Decision-Making or Profiling

LinkMap does not employ any automated decision-making processes or profiling as defined in Article 22 of the GDPR. No decisions with legal effects or similarly significant effects are made about users based solely on automated processing of personal data.

X. E-mail Contact

1. Description and Scope of Data Processing

If contact is made via the e-mail address provided on our website or documentation, the user's personal data transmitted with the e-mail will be stored.

In this context, the data is not passed on to third parties. The data is used exclusively for the processing of the conversation.

2. Legal Basis for Data Processing

The legal basis for the processing of the data, if the user has given his consent, is Art. 6 para. 1 lit. a GDPR.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

3. Purpose of Data Processing

In the case of contact by e-mail, the processing of the data serves solely to process the contact.

4. Duration of Storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data sent by e-mail, this is the case when the respective conversation with the user is ended. The conversation is ended when it can be inferred from the circumstances that the matter concerned has been conclusively clarified.

5. Possibility of Objection and Removal

The user has the option at any time to revoke his consent to the processing of personal data via email. If the user contacts us by email, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.

All personal data stored in the course of contacting us will be deleted in this case.

XI. Rights of the Data Subject

If personal data of yours is processed, you are a data subject within the meaning of the GDPR and you are entitled to the following rights against the controller:

1. Right of Access (Art. 15 GDPR)

You may request confirmation from the controller as to whether personal data concerning you are being processed by us.

If such processing is taking place, you may request information from the controller about:

• The purposes for which the personal data are processed
• The categories of personal data which are processed
• The recipients or categories of recipients to whom the personal data have been or will be disclosed (Heroku/Salesforce, Atlassian)
• The planned duration of the storage of the personal data concerning you (until app uninstallation or account closure)
• The existence of a right to rectify or erase the personal data concerning you, a right to obtain the restriction of processing by the controller, or a right to object to such processing
• The existence of a right of appeal to a supervisory authority
• Where personal data is transferred to a third country, information about the appropriate safeguards (Standard Contractual Clauses with Heroku/Atlassian)

2. Right to Rectification (Art. 16 GDPR)

You have a right of rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.

Note: The Account ID is assigned by Atlassian and cannot be modified. If you believe your Account ID is incorrect, please contact Atlassian support.

3. Right to Restriction of Processing (Art. 18 GDPR)

Under the following conditions, you may request the restriction of the processing of personal data concerning you:

• If you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data
• The processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data
• The controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims
• If you have objected to the processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override your grounds

If the processing of personal data concerning you has been restricted, such data may - apart from being stored - only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State.

4. Right to Erasure (Art. 17 GDPR)

a) Obligation to Delete

You may request the controller to erase the personal data concerning you without undue delay, and the controller shall be obliged to erase such data without undue delay, if one of the following reasons applies:

• The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed
• You revoke your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR and there is no other legal basis for the processing
• You object to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) GDPR
• The personal data concerning you have been processed unlawfully
• The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law

How to exercise this right: To delete your personal data (Account ID and associated configurations), please contact us at LinkMap@buering.net. We will process your request within 30 days. Alternatively, data is automatically deleted when the app is uninstalled or when your Atlassian account is closed.

b) Exceptions

The right to erasure does not exist to the extent that the processing is necessary:

• For compliance with a legal obligation which requires processing under Union or Member State law
• For the assertion, exercise or defense of legal claims

5. Right to Data Portability (Art. 20 GDPR)

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided:

• The processing is based on consent pursuant to Art. 6(1)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and
• The processing is carried out with the aid of automated procedures

How to exercise this right: Contact us at LinkMap@buering.net to request a copy of your Account ID and associated configuration data in JSON format.

6. Right to Object (Art. 21 GDPR)

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

7. Right to Withdraw Consent (Art. 7(3) GDPR)

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

8. Right to Lodge a Complaint with a Supervisory Authority (Art. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Competent Supervisory Authority (Germany):

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW)
Kavalleriestraße 2-4
40213 Düsseldorf
Germany
Website: https://www.ldi.nrw.de

XII. Data Security Measures

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

• Encryption in Transit: TLS 1.3 for all data transmission between components
• Encryption at Rest: Database encryption provided by Heroku PostgreSQL
• Access Control: Role-based access control (RBAC) and multi-factor authentication (MFA) for administrative access
• Authentication: JWT-based authentication via Atlassian Connect Framework
• Logging and Monitoring: Security event logging with 7-day retention
• Regular Updates: Timely application of security patches and updates
• Vulnerability Management: Participation in Atlassian Marketplace Security Bug Bounty program
• Backup: Daily automated backups with 7-day retention in European region

XIII. International Data Transfers

All personal data is stored and processed within the European Union (Heroku European region). However, as Heroku is operated by Salesforce (a U.S. company), the following safeguards apply to ensure GDPR compliance:

• Standard Contractual Clauses (SCCs): Salesforce/Heroku uses EU-approved SCCs for international data transfers
• EU-U.S. Data Privacy Framework: Salesforce participates in the EU-U.S. Data Privacy Framework
• Data Processing Agreement: Available at Salesforce DPA

For Forge components, Atlassian's data transfer safeguards apply. See Atlassian DPA for details.

XIV. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in our data processing practices or legal requirements. If we make material changes that reduce your rights, we will notify you by:

• Posting a notice in the app
• Updating the "Last Updated" date at the top of this policy

We encourage you to review this Privacy Policy periodically. Continued use of the app after changes constitutes acceptance of the updated policy.

XV. Contact for Privacy Matters

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact:

Thorsten Büring
LinkMap@buering.net
Bommershöfer Weg 46
40670 Meerbusch
Germany

XVI. Atlassian Resources

Atlassian, as provider of the Jira Cloud Service as well as the Connect Framework and Forge platform used, provides the following documentation on data privacy and cloud security:

• Atlassian Cloud Security Statement
• Atlassian Privacy Policy
• Atlassian Forge Data Processing Addendum
• Forge User Privacy Guidelines