We self-certify compliance with:

Apigee strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which we do business.  This Safe Harbor Privacy Policy sets forth the privacy principles that Apigee follows with respect to transfers of personal information between member states of the European Union, Iceland, Liechtenstein and Norway (the European Economic Area or EEA) and the United States.

Definitions

“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

Adherence to European Union and Swiss Privacy Principles

Apigee has installed policies and procedures to ensure that it adheres to the European Union and Swiss Privacy Principles.  This includes involving an independent third party to resolve privacy disputes when necessary.

Disclosure to Law Enforcement

Apigee may disclose Personal Data, including the data you submit to us, with or without notice (a) if required by a subpoena or other judicial or administrative order, (b) where required by law, or (c) at our sole discretion, where we deem it necessary to protect the safety of any individual, the general public, or to prevent violation of the rights of Apigee or any third party.

Apigee and Its Affiliates

Apigee is a United States based corporation, which also operates several international affiliates.  Apigee may share some or all of your Personal Data with these, or future, affiliates.  Apigee requires all affiliates to honor its Privacy Policies, including the Safe Harbor Privacy Policy.

Change of Ownership

In the event of change in ownership, or a direct merger or acquisition with another entity, we reserve the right to transfer all of Apigee User information, including Personal Data, to a separate entity.  We will use commercially reasonable efforts to notify you (by posting on our website or issuing an e-mail to the e-mail address you provided when you registered) of any change of ownership; merger or acquisition of Apigee by a third party, and you may choose to modify any of your registration information at that time.

Principles

  1. Notice

Apigee shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information.  Company shall provide the Individual with the choice and means for limiting the use and disclosure of their Personal Information.  Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which is was originally collected.

  1. Choice

The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a non-agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.  For Sensitive Personal Information, Apigee will give individuals the opportunity to affirmatively and explicitly (opt in) consent to the disclosure of their information to a non-agent third party or the use of their information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

  1. Onward Transfers to Agents

Apigee will obtain assurances from its agents that they will safeguard personal information consistent with this Policy.  Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding.  Where Apigee has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Apigee will take reasonable steps to prevent or stop the use or disclosure.

  1. Data Security

Apigee shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.  Apigee has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction.  Apigee cannot guarantee the security of Information on or transmitted via the Internet.

  1. Data Integrity

Apigee shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual.  To the extent necessary for those purposes, Apigee shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

  1. Access

Upon request, Apigee will grant individuals reasonable access to personal information that it holds about them.  In addition, Apigee will take reasonable steps to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

  1. Enforcement

Apigee uses a self-assessment approach to maintain compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with these Principles.  We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to Apigee at the address given below.  Apigee will investigate and attempt to resolve complaints and disputes regarding use and disclosure or personal information in accordance with the principles contained in this Policy.

Apigee has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism when necessary.  Apigee uses the Better Business Bureau EU Safe Harbor program (http://www.bbb.org/us/european-dispute-resolution/) to resolve such disputes.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor.  We will post any revised policy on this website.

Information Subject to Other Policies

The Company is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement.  However, certain Information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy.

Contact Information

Questions, comments, or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:

Apigee Corporation

Re: US/EU Safe Harbor
10 Almaden Boulevard, 16th Floor
San Jose, CA 95113

SafeHarbor@apigee.com