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ServiceNow® Privacy Statement

Effective as of 24 November 2025

ServiceNow, Inc., including its subsidiaries and affiliates (collectively, "ServiceNow," "we," or "us") respects the privacy of its customers, business partners, event attendees, job applicants and Website (as defined below) visitors.

The following Privacy Statement explains who we are and the different ways in which we collect, use, and disclose personal data about you, and how you can exercise your privacy rights. Please take the time to read this Privacy Statement and the related statements in their entirety to ensure you are fully informed. To access a specific policy, you may click on the relevant link below. Note that we may provide additional information about our privacy practices that are specific to one of our websites, events, products, or services or apply to residents of a certain jurisdiction.

If you have any questions or concerns about our use of your personal data, please contact us using the contact details provided at the bottom of this Privacy Statement.

PRIVACY STATEMENT. Our Privacy Statement covers our privacy practices as a controller with respect to the collection, use, and disclosure of information obtained: (i) through the ServiceNow websites that link to this Privacy Statement (our "Website"), (ii) events hosted by ServiceNow or our business partners and sponsors where we collect information from attendees (“Events”), and (iii) any marketing related activities which we are involved in.

ADDITIONAL INFORMATION FOR INDIVIDUALS RESIDING IN CALIFORNIA AND CERTAIN OTHER U.S. STATES. If you are a resident of California or another US State where ServiceNow is subject to a comprehensive state privacy law, please see below for additional information about how we process your personal data.

COOKIES POLICY. Our Cookies Policy addresses how we use cookies and other similar tracking technologies when you visit our websites or use our products, services, and mobile applications.  Our Cookies Policy addresses how we use cookies and other similar tracking technologies when you visit our websites or use our products, services, and mobile applications.

SERVICES PRIVACY STATEMENT. Our Services Privacy Statement covers our privacy practices as a controller in connection with the use of our hosted software applications and related support services, as well as expert services, including professional services, trainings and certifications that we provide to customers. The Services Privacy Statement also describes our privacy practices with respect to customer and partner contact and account management information we process in connection with the purchase and use of our products and services or technology provided by our partners to our customers.

APPLICANT PRIVACY STATEMENT. Our Applicant Privacy Statement covers our privacy practices as a controller in connection with an individual’s application for employment at ServiceNow.

 

Purpose and Scope

ServiceNow, Inc., including its subsidiaries and affiliates (collectively, "ServiceNow," "we," or "us") respects the privacy of users of its Website (as defined below) and registrants and attendees at its Events (as defined below), and of individuals with whom we may otherwise interact with for marketing purposes (collectively, Data  Subjects”).

This Privacy Statement (the "Privacy Statement") applies to our collection, use, and disclosure as controller of: (i) information obtained through the ServiceNow websites that link to this Privacy Statement ("Website"); (ii) information collected at event registration or attendance information for events hosted by us or our business partners where we collect information from registrants and attendees (“Events”), or (iii) marketing communications that we issue to you where we have obtained your contact details in some other manner.

About Us

ServiceNow makes work, work better for people. Our cloud‑based platform and products streamline and simplify how work gets done. Our solutions, and the custom solutions built by our customers and partners, help people do their best work. We are headquartered in Santa Clara, California but have subsidiaries and affiliates around the world.

For more information about ServiceNow, please see the About Us section of our Website. 

 

How We Obtain Information

We collect several types of information from and about Data Subjects that broadly fall into the following categories:

  1. 1.Information we collect from you:
    • When filling out forms on our Website (including without limitation, name, mailing address, email address, and telephone number).
    • When you post material to our Website, participate in bulletin boards, chat rooms, blogs, comment threads, forums, or other interactive features of our Website, register, or request further information or services from us. 
    • When you register to use a demo or developer instance of our cloud service.
    • When you enter a contest or promotion we sponsor.
    • When you contact us (including where you interact with chatbots on our Website).
    • When you complete our surveys.
    • When you register for or attend an Event (which may include photographs, audio, and video recordings of Event attendees)
    • Other information you may submit to us, including information related to your use of our Website or attendance to an Event (including without limitation, billing information).
  2. Additionally, if you contact us through our chat feature, we may monitor and retain the chat conversation, including for training purposes. We may use the contact details and information you provided in the chat to reach out to provide you with information you have requested about our products and services. Please do not use the chat feature if you do not wish to have your chat conversations monitored and retained.

  1. 2.Information from third parties or information which is publicly available.

    From time to time, we may collect and use information we receive about you from third parties in connection with your use of the Website or attendance to an Event or other marketing related activities. For instance, we may receive information about you from our business partners related to your registration information for Events or from other vendors where you have expressed an interest in ServiceNow products (including by downloading a ServiceNow digital asset or giving consent to receiving marketing materials). We also use third parties for reporting and analytics to measure the effectiveness of our Website and marketing efforts, and to identify areas for improvement.

  2. We may combine information we collect from third parties with information you provide us to update, expand, or provide you with tailored information regarding our products, services, and Events.  We may also collect information about you where you have made it publicly available. 

  1. 3.Information we collect as you navigate through the Website.

    As you navigate through the Website, we may also automatically collect details about your visits to the Website, including your IP address, usage patterns, traffic data, location data, logs, other communication data, and the resources that you access, as well as information about your device and internet connection, including your operating system and browser type.

    We also collect some of this information using cookies and similar tracking technologies through others that we engage to provide analytics services, serve advertisements, and perform related services across the web and in mobile apps. You can turn off cookies used for ad targeting purposes by accessing the “Cookies Preferences” link in the footer of the site or the “Your Privacy Choices” link. For detailed information on our cookies, please see our Cookies Policy.

    Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain state privacy laws. See “Additional Disclosures for Individuals Residing in Certain U.S. States" for more information and the privacy rights available to residents of these states, with respect to these practices.

     

    How We Use Information Collected

    We may process personal data that we collect about you for the following purposes:

    • To operate, maintain, and improve our Website.
    • To register you for Events you sign up for with us and populate profiles for you in our records.  
    • To provide you with information about products or services that you request from us.
    • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including without limitation, our Website Terms of Use, or to take action regarding violations of our policies.
    • To notify you about changes to our Website or obtain any required consent.
    • To allow you to participate in interactive features of our Website, when you choose to do so.
    • For industry analysis, benchmarking, analytics, marketing, and other business purposes. 
    • To track your browsing behaviour, such as the pages you visited over time, for analytics and advertising purposes.
    • To communicate with you about Events.
    • To contact you for marketing purposes, in accordance with your marketing preferences (for example, we may use your information to contact you to further discuss your interests in our services and products or other Events). Where one of our team speak to you over the phone, calls may be monitored or recorded for training and customer service purposes.
    • To promote our products, services, or Events on our social media accounts (for example, by using photographs, audio, and video recordings of Events which you may have attended).
    • To protect the rights, property, or safety of ServiceNow, its affiliates, employees, agents, or others.
    • To defend against a legal claim.

    If you ask us to contact you about goods and services, we may use your personal data or permit selected third parties to use your personal data, to contact you about such goods and services. You can withdraw consent at a later time by clicking on the “unsubscribe” link located in the emails we send you. For more information, see the section on “Your Privacy Rights” below. 

    Additional information about our privacy practices with respect to our collection and use of information from Events may be found in additional privacy statements on the registration sites for Events hosted by us, where relevant.

    Legal Basis for Processing

    Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. 

    To the extent that we process personal data as data controller, we normally do so on the basis of our legitimate business interest to do so (taking into account the fundamental privacy rights of any relevant individuals), and / or in performance of a contract, and / or on the basis of compliance with a legal obligation, and / or on the basis of consent, depending on the specific activity involved. 

     

    How We Disclose Information Collected

    We may disclose personal data about you to the following categories of recipients:

    • To our global subsidiaries and affiliates who will use it only for the purposes described in this Privacy Statement.
    • To our contractors, business partners and service providers we use to support our business or who provide services on our behalf. If you choose to or direct us to disclose your information to business partners or sponsors, your information will be subject to the respective business partner or sponsor’s privacy statement.
    • To a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganisation, dissolution or liquidation), in which case personal data held by us about you will be amongst the assets transferred to the buyer or acquirer.
    • To any competent law enforcement body, regulatory, government agency, court or other third party  to: (i) comply with relevant laws and regulations, including court order, a request from any competent law enforcement agency, or any other legal obligation; (ii) enforce or apply our Website Terms of Use, or terms of any other agreement, or to take action regarding violations of our policies; (iii) protect the rights, property, or safety of ServiceNow, its affiliates, employees, agents, or others, (iv) defend against a legal claim.
    • To any other user of the site or any other sites in the ServiceNow ecosystem, where you choose to make that information public. 
    • To any other person at your direction or with your consent to the disclosure.

    We may also disclose aggregated or de‑identified information that cannot reasonably be used to identify you. ServiceNow processes, maintains, and uses this information only in a de‑identified fashion and will not attempt to re‑identify such information, except as permitted by law.

     

    International Transfer of Data

    ServiceNow stores and processes any personal data collected in connection with Data Subjects in: (i) any country where we have facilities, (ii) any country in which we engage service providers; or (iii) any country where Events are held. A list of ServiceNow’s global offices is available here.

    For international transfers of personal data from the European Economic Area ("EEA"), the UK or Switzerland, we implement such measures as are necessary to ensure we provide appropriate safeguards for the transferred data, including through the use of Standard Contractual Clauses or another lawful transfer data transfer mechanism. 

     

    Security and Confidentiality

    ServiceNow maintains appropriate technical and organisational measures designed to protect the personal data of Data Subjects from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, and access. ServiceNow personnel and service providers with access to personal data of Data Subjects are required to keep such information confidential and secure.

     

    Retention

    We will retain your personal data if we have a business need to do so or for as long as is needed to fulfil the purposes outlined in this Privacy Statement, unless a longer retention period is required by law (for example, to comply with applicable legal, tax, or accounting requirements).

    When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

     

    Your Privacy Choices

    In accordance with applicable laws, we provide you with certain choices regarding the information you provide to us.  Depending on where you reside, you may have the following rights:

    • If you wish to access, correct, update, or request deletion of your personal data, you can contact us. Event registrants and attendees may update their user profiles for Events we host by logging into the applicable event website or registration page.
    • Depending on where you live, you may have specific privacy rights under applicable law, including the right to object to processing of your personal data, or to request that we restrict processing of your personal data, or to request a portable copy of your personal data, or to lodge a complaint with us in relation to our processing of your personal data. We will process your requests to exercise such rights in accordance with applicable data protection laws.
    • If you do not wish to receive our email marketing communication for promotional purposes, you may opt out by clicking on the “unsubscribe” or “opt out” link in the marketing emails we send you. To opt out of other forms of marketing (such as telemarketing), please contact us. In addition, if we process your personal data in reliance upon your consent, you can contact us at any time to withdraw your consent.
    • You have the right to complain to a data protection authority if you are unhappy about our collection and use of your personal data.
    • We use cookies and similar tracking technologies to analyze use of our Website and interactions with our marketing communications. As described in the “How We Obtain Information” section above, we also use these technologies for cross‑context behavioral or targeted advertising. You may opt out at any time by managing your cookies preference through clicking on the “Cookie Preferences” link in the footer of the site or the “Your Privacy Choices” link.  Alternatively, Website Users may opt out by broadcasting a legally recognized opt‑out preference signal, such as the Global Privacy Control (on the browsers and/or browser extensions that support such a signal).  Please note that, depending on which legally recognized opt‑out preference signal you use, our processing of the signal may be limited to the specific browser or device that you are using. You may need to renew your opt‑out choice if you use a different browser or device to access our Website.

    We will respond to such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfil your request, we may need you to provide certain information to verify your identity.  Additionally, depending on where you reside, you may be able to use an authorized agent to exercise your rights. We may request evidence that you have provided such agent with authority to submit requests on your behalf, and / or ask that you verify your identity directly with us.  If you are an authorized agent seeking to make a request, please contact us at privacy@servicenow.com.

    To exercise certain of your rights under applicable laws, you may submit a form here. Alternatively, you may contact us using the details in the “Contact Information

     

    Additional Information for Individuals Residing in California or Certain Other U.S. States

    If you are a resident of the State of California, which has enacted the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (as amended, the CCPA), or if you are a resident of another U.S. state where ServiceNow is subject to similar requirements (the “Other States”), this section applies to you.

     

    How We Collect or Generate, Use, and Disclose Personal Information

    In addition to the chart below:

    For information on the categories of personal information that we collect or generate, and the sources of such personal information, please see the “How We Obtain Information” section above.

    For information on how and for what purposes we use personal information, please see the “How We Use Information Collected” section above. 

    For information on how we disclose personal information, please see the “How We Disclose Information Collected” section above.

    What Personal Information We Collect or Generate

    Where We Get It

    Why We Collect or Generate It

    To Whom We Disclose It

    Identifiers (like your name, email, telephone number, etc.)

    From you

    From our partners or sponsors

    From others, including data brokers, as permitted by law

    To provide products and services that you request

    To create a profile for you in our records

    To notify you about changes to our Website, our Terms or policies, or enable you to provide consent

    To communicate with you about Events that you have registered for

    To contact you for marketing purposes, unless you have opted out

    To promote our products, services, and Events to you, including on social media

    Perform our obligations and enforce our rights under our Terms of Service, this Privacy Statements, or any other contract with you

    As otherwise required to comply with applicable law or valid legal process

    Our subsidiaries and affiliates

    Our business partners with whom we partner to jointly market or sell our products (“Business Partners”)

    Our Event sponsors (“Sponsors”)

    Our technology service providers (including cloud service providers, security providers, and data storage providers, together “Platform Service Providers”)

    Our marketing and advertising service providers

    Our Event service providers

    Our data analytics service providers

    Other users of our Website if you post content to interactive or public areas of the Website

    Any other person at your direction or with your consent

    Law enforcement, government, or other competent agencies when validly required by law

    Commercial information (such as Events attended, products or services purchased, your Website preferences)

    From you or your activity or transactions with us, including with our Website

    From our Business Partners or Sponsors

    To provide products and services that you request

    To create a profile for you in our records

    To communicate with you about Events that you have registered for

    To contact you for marketing purposes, unless you have opted out

    To promote our products, services, and Events to you, including on social media

    Perform our obligations and enforce our rights under our Terms of Service, this Privacy Statements, or any other contract with you

    As otherwise required to comply with applicable law or valid legal process

    Our subsidiaries and affiliates

    Our Business Partners

    Our Sponsors

    Our Platform Service Providers

    Our marketing and advertising service providers

    Our Event service providers

    Our data analytics service providers

    Any other person at your direction or with your consent

    Law enforcement, government, or other competent agencies when validly required by law

     

    Device, internet, and electronic network activity information (such as IP address, information about your browser or your device, location data, internet traffic data, etc.)

    From you or your activity or transactions with us, including with our Website

    From cookies or other tracking technologies, unless you opt out

     

    To operate, maintain, and improve our Website

    To keep our Website safe and secure

    To provide products and services that you request

    To promote our products, services, and Events to you, including on social media

    Perform our obligations and enforce our rights under our Terms of Service, this Privacy Statements, or any other contract with you

    As otherwise required to comply with applicable law or valid legal process

    Our subsidiaries and affiliates

    Our Platform Service Providers

    Our marketing and advertising service providers

    Our data analytics service providers

    Any other person at your direction or with your consent

    Law enforcement, government, or other competent agencies when validly required by law

     

    Approximate geolocation data (such as your country or city of residence)

    From you or your activity or transactions with us, including with our Website

    From cookies or other tracking technologies, unless you opt out

     

    To operate, maintain, and improve our Website

    To provide products and services that you request

    To promote our products, services, and Events to you, including on social media

    Perform our obligations and enforce our rights under our Terms of Service, this Privacy Statements, or any other contract with you

    As otherwise required to comply with applicable law or valid legal process

    Our subsidiaries and affiliates

    Our Platform Service Providers

    Our marketing and advertising service providers

    Our data analytics service providers

    Any other person at your direction or with your consent

    Law enforcement, government, or other competent agencies when validly required by law

     

    Audio recordings, photographs, video recordings, and other similar digital assets (including from our Events or conferences)

    From our photos or audio or video recordings of Events

    From others who attend Events that you attend

    To promote our products, services, and Events to you, including on social media

    Perform our obligations and enforce our rights under our Terms of Service, this Privacy Statements, or any other contract with you

    For safety and security at Events and on ServiceNow premises

    As otherwise required to comply with applicable law or valid legal process

    Our subsidiaries and affiliates

    Our Business Partners

    Our Sponsors

    Our Platform Service Providers

    Our marketing and advertising service providers

    Audiences on social media networks

    Our data analytics service providers

    Any other person at your direction or with your consent

    Law enforcement, government, or other competent agencies when validly required by law

    Professional or employment‑related information (like your job title or employment history)

    From you

    From websites or other digital properties where you have made such information public

    From others, including our Business Partners or Sponsors, as directed by you or permitted by law

    To provide products and services that you request

    To create a profile for you in our records

    To contact you for marketing purposes, unless you have opted out

    To promote our products, services, and Events to you, including on social media

    Perform our obligations and enforce our rights under our Terms of Service, this Privacy Statements, or any other contract with you

    As otherwise required to comply with applicable law or valid legal process

    Our subsidiaries and affiliates

    Our Business Partners

    Our Sponsors

    Our Platform Service Providers

    Our marketing and advertising service providers

    Audiences on social media networks

    Our data analytics service providers

    Any other person at your direction or with your consent

    Law enforcement, government, or other competent agencies when validly required by law

     

    User Content (such as content you create or post on our Website)

    From you or your activity with us, including with our Website

     

    To provide products and services that you request

    To create a profile for you in our records

    To contact you for marketing purposes, unless you have opted out

    To promote our products, services, and Events to you, including on social media

    Perform our obligations and enforce our rights under our Terms of Service, this Privacy Statements, or any other contract with you

    As otherwise required to comply with applicable law or valid legal process

    Our subsidiaries and affiliates

    Our Platform Service Providers

    Audiences on social media networks

    Other users of our Website if you post content to interactive or public areas of the Website

    Any other person at your direction or with your consent

    Law enforcement, government, or other competent agencies when validly required by law

     

     

     

    Additional Personal Information May Be Collected at Events. At certain Events, we may collect and use for these or other purposes additional personal information about you. Notice of what personal information we collect, how we use it, and how we disclose it may be found in privacy disclosures provided to you on‑site at such Events.

    Sensitive Personal Information. We do not collect, generate, or use sensitive personal information for the purpose of inferring characteristics about you in connection with our Website or Events.

    Personal Information that We May ‘Share’, ‘Sell’, or Use for Targeted Advertising. We may disclose your personal information to certain third parties, including our marketing and advertising providers, in ways that could be considered a ‘sale’ or ‘share’ (for purposes of cross‑context behavioral advertising) of your personal information or the use of your personal information for targeted advertising. ServiceNow does not ‘sell’, or ‘share’ personal information collected from individuals that we know to be under the age of 18.  

    Personal Information that We May Sell or Share

    Where We Collect that Personal Information

    Third Parties to Whom We May Sell, Share, or Disclose for Targeted Advertising Personal Information

    Identifiers

    From you

    From our Business Partners or Sponsors

    From others, including data brokers, as permitted by law

     

    Our Business Partners

     

    Our Sponsors

     

    Our marketing and advertising service providers

     

     

    Commercial information

    From you or your activity or transactions with us, including with our Website

    Our Business Partners

     

    Our Sponsors

     

    Our marketing and advertising service providers

     

    Device, internet, and electronic network activity information

    From you or your activity or transactions with us, including with our Website

    From cookies or other tracking technologies, unless you opt out

    Our marketing and advertising service providers

     

     

    Your Privacy Rights

    If you are a resident of California or one of the Other States, you have the following rights:

    • You have the right to opt out having your personal information sold, shared, or used for targeted advertising. You can exercise this right by managing your cookie preferences using the ‘Cookie Preferences’ link in the footer of our Website, by visiting our “Your Privacy Choices” link, or by contacting us at privacy@servicenow.com.
    • If you are a resident of California, you can also opt out by visiting our website with a legally recognized opt‑out preference signal enabled on your browser, such as the Global Privacy Control. Please note that our processing of the signal may be limited to the specific browser or device that you are using. You may need to renew your opt‑out choice if you use a different browser or device to access our website, or if you clear your cookies.
    • You have the right to know what personal information we have collected about you and to get access to that personal information. You can exercise that right by visiting our “Your Privacy Choices” link, calling our toll‑free number at 1 858 345 1444, or by contacting us at privacy@servicenow.com.
    • You have the right to correct inaccurate personal information that we have collected about you. You can exercise that right by visiting our “Your Privacy Choices” link, calling our toll‑free number at 1 858 345 1444, or by contacting us at privacy@servicenow.com.
    • You have the right to request that we delete the personal information that we have collected about you. You can exercise that right by visiting our “Your Privacy Choices” link, calling our toll‑free number at 1 858 345 1444, or by contacting us at privacy@servicenow.com.
    • You have the right to request the portability of your personal information. You can exercise that right by visiting our “Your Privacy Choices” link, calling our toll‑free number at 1 858 345 1444, or by contacting us at privacy@servicenow.com.
    • You have the right to appeal if we deny your request to exercise your rights of access, correction, deletion, or portability. You can exercise that right by contacting us at privacy@servicenow.com.
    • California residents: If you have concerns about the outcome of an appeal, you have the right to contact the Office of the Attorney General for the State of California.
    • You have the right not to be discriminated against for exercising your rights under the CCPA or applicable laws with similar requirements. We will not discriminate against you for exercising your rights under the CCPA or laws with similar requirements.

    When you exercise these rights, we may ask for additional information (such as an email address) that is reasonably necessary to complete your request or verify your identity, as required or permitted by applicable law. Depending on where you live, you may be able to use an authorized agent to exercise these rights. We may request evidence that have provided such agent with authority to submit requests on your behalf and ask that you verify the agent’s identity directly with us.  If you are an authorized agent seeking to make a request, please contact us at privacy@servicenow.com.

    Data Retention

    For information on our data retention practices, please see the section “Retention” above.

     

    General

    Third Party Websites and Applications

    This Website may link to websites that are not owned or controlled by ServiceNow. As such, this Privacy Statement does not apply to information collected on any third‑party site or by any third‑party application that may link to or be accessible from the Website. This Privacy Statement does not apply to information collected by customers, our business partners, and other third parties, or third‑party applications or services, even if this information is collected using our Website or at Events.

    Public Forums and Blogs

    Please note that any information you post or disclose in public forums will become public information and may be available to users and the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information in our public forums. Proper access and use of information provided on the Website, including contributions to our public forums, is governed by our Website Terms of Use and known or suspected violations should be reported to us.

    Children
    We do not knowingly collect personal data from anyone under the age of 16. If you are under 16, please do not attempt to fill out our forms or send any personal data about yourself to us. If we learn that we have collected personal data from a child under age 16, we will delete that information promptly.

    Changes To Our Privacy Statement

    ServiceNow reserves the right to update or change this Privacy Statement from time to time. If we make material changes to this Privacy Statement, we will notify you through an appropriate online notice or other means (which may include, if we have your contact details, notification by email). We ask that you review the Privacy Statement periodically to stay informed about any updates or changes that we may have made.

    You can see when this Privacy Statement was last updated by checking the “effective as of” date displayed at the top of this Privacy Statement.

     

    Contact Information

    To ask questions or comment about this Privacy Statement and our privacy practices or if you need to update, change or remove your information or exercise any other rights, contact us at: privacy@servicenow.com or call +1 858 345 1444

    Or by mail at:

    ServiceNow, Inc.
    Attn: Privacy
    2225 Lawson Lane
    Santa Clara, CA 95054

    All other feedback, comments, requests for technical support, and other communications relating to the Website should be directed to:  web_support@servicenow.com.

    This website is operated by ServiceNow, Inc. (the data controller), which is a Delaware corporation located at 2225 Lawson Lane, Santa Clara, CA 95054.

    Our main establishment in the European Union for GDPR purposes in Ireland (controller: ServiceNow Ireland Limited), and our lead supervisory authority is the Irish Data Protection Commission (“DPC”).