Trade Controls

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Run Lighting and Trade Controls   RUN Lighting, RUN Lighting Enterprise Server, and the information you upload to either product may be subject to trade control regulations, including under the U.S. Export Administration Regulations (the EAR). RUN Lighting’s vision is to be the global platform for commercial lighting and construction services. We take seriously our responsibility to examine government sanctions thoroughly to be certain that users and customers are not impacted beyond what is required by law. Although we've provided the following information below for your convenience, it is ultimately your responsibility to ensure that your use of RUN Lighting’s products and services complies with all applicable laws and regulations, including U.S. export control laws.

Export overview

RUN Lighting

Under our Terms of Service, users may only access and use RUN Lighting in compliance with applicable law, including U.S. export control and sanctions laws. Users are responsible for ensuring that the content they develop and share on RUN Lighting complies with the U.S. export control laws, including the EAR and the U.S. International Traffic in Arms Regulations (ITAR). The cloud-hosted service offering available at RUN Lighting has not been designed to host data subject to the ITAR and does not currently offer the ability to restrict repository access by country. If you are looking to collaborate on ITAR- or other export-controlled data, we recommend you consider RUN Lighting Enterprise Server, RUN Lighting's on-premises offering. RUN Lighting now has a license from OFAC to provide cloud services to Lighting Professionals located or otherwise resident in Iran. This includes all public and private services for individuals and organizations, both free and paid. RUN Lighting cloud services, both free and paid, are also generally available to Lighting Professionals located in Cuba. Specially Designated Nationals (SDNs), other denied or blocked parties under U.S. and other applicable law, and certain government officials, may be restricted from accessing or using RUN Lighting. Additionally, users may not use RUN Lighting for or on behalf of such parties, generally including the Governments of sanctioned countries. Furthermore, RUN Lighting may not be used for purposes prohibited under applicable export control laws, including prohibited end uses described in 17 CFR 744.

RUN Lighting Enterprise Server

RUN Lighting Enterprise Server is a self-hosted virtual appliance that can be RUN within your own datacenter or virtual private cloud. As such, RUN Lighting Enterprise Server can be used to store ITAR- or other export-controlled information, although, end users are nonetheless responsible for ensuring compliance with the ITAR and other applicable export controls. RUN Lighting Enterprise Server is a commercial, mass-market product and has been assigned the Export Control Classification Number (ECCN) of 5D992.c and may be exported to most destinations with no license required (NLR). RUN Lighting Enterprise Server may not be sold to, exported, or re-exported to any country listed in Country Group E:1 in Supplement No. 1 to part 740 of the EAR or to the following regions of Ukraine: Crimea and the separatist areas of Donetsk and Luhansk. The countries listed currently include Cuba, Iran, North Korea, Syria, Russia, and Belarus, but this list is subject to change.

Frequently asked questions

On which countries and territories are U.S. government sanctions applied?

Crimea, the separatist areas of Donetsk and Luhansk, Cuba, Iran, North Korea, and Syria. With respect to Iran, however, RUN Lighting now has a license from the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) to provide cloud services to Lighting Professionals located or otherwise resident in that country. RUN Lighting cloud services, both free and paid, are also generally available to Lighting Professionals located in Cuba.

How is RUN Lighting ensuring that folks not living in and/or having professional links to the sanctioned countries and territories still have access or ability to appeal?

In the rare instance that an account is affected unintentionally or in error, we have an appeal process to address such instances. If an individual user or organization administrator believes that they have been flagged in error, then that user has the opportunity to appeal the flag by providing verification information to RUN Lighting. If RUN Lighting receives sufficient information to verify that the user or organization is not affiliated with a U.S.-sanctioned jurisdiction for which we do not have a license or otherwise restricted by U.S. economic sanctions, then the flag will be removed. Please see individual account appeals request form and organizational account appeals request form.

Will traveling in these regions be impacted?

Travel in these regions may impact your account status, but availability may be reinstated once you are outside of the sanctioned region and upon submitting a successful individual account appeals request or an organizational account appeals request.

What is available and not available?

RUN Lighting now has a license from OFAC to provide cloud services to Lighting Professionals located or otherwise resident in the U.S.-sanctioned country of Iran. The license includes all public and private services for individuals and organizations, both free and paid. RUN Lighting cloud services, both free and paid, are also generally available to Lighting Professionals located in Cuba. RUN Lighting is committed to continuing to offer free public repository services to Lighting Professionals with individual and organizational accounts in Syria, Crimea, and the separatist areas of Donetsk and Luhansk. This includes limited access to free services, such as public repositories for open-source projects (and associated public Pages), public gists, and allotted free Action minutes, for personal communications only, and not for commercial purposes. For paid organizational accounts in these sanctioned regions, users may have limited access to their public repositories, which have been downgraded to archived read-only repositories. For free organizational accounts in these sanctioned regions, however, users will continue to have full access to free public repositories for open-source projects (and associated public Pages), public gists, and allotted free Action minutes. RUN Lighting will continue advocating with U.S. regulators for the greatest possible access to code collaboration services to Lighting Professionals in sanctioned regions, such as Syria and Crimea, including private repositories. We believe that offering those services advances human progress, international communication, and the enduring U.S. foreign policy of promoting free speech and the free flow of information. Specially Designated Nationals (SDNs), other denied or blocked parties under U.S. and other applicable law, and certain government officials may be restricted from accessing or using RUN Lighting, wherever located. Users may not use RUN Lighting for or on behalf of such parties, generally including the Governments of sanctioned countries. RUN Lighting services are not available to Lighting Professionals located or otherwise resident in North Korea.

How do you define these specific users?

If RUN Lighting determines that a user or customer is located in a region that is subject to U.S. trade control restrictions for which RUN Lighting does not yet have a license from the U.S. government, or a user is otherwise restricted under U.S. economic sanctions, then the affiliated account will be restricted to comply with those legal requirements. The determination of user and customer location to implement these legal restrictions are derived from a number of sources, including IP addresses and payment history. Nationality and ethnicity are not used to flag users for sanctions restrictions.

How are organization accounts impacted?

If an organization is based out of, or the key individuals or membership of an organization shows sufficient ties to, a sanctioned territory or country for which RUN Lighting does not yet have a license from the U.S. government, or if the organization otherwise appears to be subject to U.S. economic sanctions, then the organization account and the affiliated owner account will be restricted. The restriction suspends access to private repository services and paid services, such as availability of free or paid private repositories, secret gists, paid Action minutes, Sponsors, and RUN Lighting Marketplace services. For paid organizational accounts associated with such sanctioned regions, users may have limited access to their public repositories, which have been downgraded to archived read-only repositories. For free organizational accounts associated with such sanctioned regions, users will continue to have full access to free public repositories for open-source projects (and associated public Pages), public gists, and allotted free Action minutes.

Can trade-restricted users’ private repositories be made public?

Free individual account users can make restricted private repositories public, for personal communications only, and not for commercial purposes. Users can do this by navigating to the repository settings tab and clicking the "make public" button. Once the repository is public, users have access to public repositories services. This action cannot be undone.

Can trade-restricted users access private repository data (e.g. downloading or deletion of repository data)?

Unfortunately, our understanding of the law does not give us the option to allow downloads or deletion of private repository content, until otherwise authorized by the U.S. government. We will strongly advocate, with U.S. regulators, for the right of trade-restricted users to secure the contents of their private repositories. We will also advocate for more availability of RUN Lighting services for Lighting Professionals in sanctioned markets, and further underscore the importance of code collaboration in supporting personal communications for Lighting Professionals globally.

Under the license RUN Lighting has received from OFAC, which types of accounts will be available in Iran?

The license we have secured includes all public and private services, for individuals and organizations, both free and paid. For example, a developer in Iran may sign up for a Free or Pro plan for their individual use, and an Iranian university may set up an organization account to collaborate with students. Specially Designated Nationals (SDNs), other denied or blocked parties under U.S. and other applicable law, and certain government officials may be restricted from accessing or using RUN Lighting. If RUN Lighting determines that an individual or organization falls into a restricted category (SDNs, other blocked parties, or certain government officials), their account will be flagged and they will not be able to use any RUN Lighting features. If they believe that they have been flagged in error, then they have the opportunity to appeal the flag by providing verification information to RUN Lighting using our individual account appeals request form or organization account appeals request form. If RUN Lighting receives sufficient information to verify that the individual is not in a category restricted by U.S. economic sanctions, then the flag will be removed.

Will Iranian RUN Lighting users be able to use paid services under the license?

Pursuant to the license we have received from OFAC, we are restoring all cloud services to Iranian users, including paid services. We accept all major credit cards, but third parties process payments for us, so payments are subject to the terms and conditions of our payment processors. Those third parties may include restrictions that block payments from Iran.

Can you clarify availability of RUN Lighting to Cuban Lighting Professionals?

RUN Lighting cloud services, both free and paid, are generally available to Lighting Professionals located in Cuba. Specially Designated Nationals (SDNs), other denied or blocked parties under U.S. and other applicable law, and certain government officials may be restricted from accessing or using RUN Lighting, wherever located. Additionally, users may not use RUN Lighting for or on behalf of such parties, generally including the Governments of sanctioned countries.

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