Privacy Policy

This Privacy Policy explains how Hostry Compute LLC, a Delaware limited liability company with its registered office at 2810 N Church St STE 89834, Wilmington, DE 19802, United States ("Hostry", "we", "us", "our"), processes personal data in connection with hostry.com, the customer Portal and all Hostry services.

Where Hostry processes personal data on behalf of a customer as a processor, the Data Processing Agreement applies. Cookies and similar technologies are described in the Cookie Policy. The Hostry mobile applications are covered by a separate Mobile Application Privacy Policy.

1. Age Requirement

Our services are intended for persons aged 18 or over. We do not knowingly collect personal data from anyone under 18. If you become aware that a minor has provided personal data to us, contact dp@hostry.com and we will delete it.

2. What This Policy Does Not Cover

Content that you host on our infrastructure — files, images, video, databases and applications, whether published or not — is your data, not personal data collected by us about you. It is not covered by this Privacy Policy. Our handling of that content is governed by the Master Service Agreement and, where applicable, the Data Processing Agreement.

3. Data We Collect

3.1 Account and Identity Data

• name, and company name where applicable;
• postal address;
• telephone number;
• email address and other contact identifiers used for online communication;
• personal identification number or Tax Identification Number, where required;
• identity documents such as passport or national ID, where required for verification;
• beneficial ownership and corporate registration records, for business customers.

3.2 Billing Data

• preferred payment method and the identifier of the transaction;
• invoices, payments, credits and balance history.

We do not collect or store full payment card numbers, CVV codes or bank credentials. Payment details are submitted directly to third-party payment providers and are governed by their own privacy policies.

3.3 Technical and Usage Data

• IP addresses and network metadata;
• authentication and access logs;
• country of origin, browser type, operating system, device type, referring URL, and date and time of requests;
• pages visited and actions taken on our websites;
• service account data — products, services and IP addresses assigned to you, domain names, client identifier and other Portal records.

3.4 Communications

• support tickets and their full contents;
• live chat logs, email correspondence and other communications with us;
• records of complaints and abuse reports concerning your services.

3.5 Browsing Without an Account

You can access parts of our website without creating an account. In that case we may still record your IP address, country of origin and non-personal device information, in order to prevent unauthorized use of our content and services.

4. Why We Process Data

We process personal data to:

• provide, operate and maintain the services, and fulfil our contract with you;
• create and authenticate your account;
• process orders, payments, invoices and refunds, and pursue unpaid debts;
• verify identity and comply with KYC/KYB, AML, CTF, sanctions and export control obligations;
• prevent fraud, secure our network, and investigate suspicious activity;
• respond to abuse reports, copyright claims and lawful requests from authorities;
• provide customer support and manage our infrastructure, systems and databases;
• conduct statistical analysis to improve the website and services, and to develop new ones;
• send service communications about orders, incidents and account status;
• send marketing communications, where you have not opted out;
• comply with legal obligations and defend legal claims.

If you choose not to provide the data we require, we may be unable to provide the services or support you request.

5. Legal Basis for Processing

Where the GDPR or UK GDPR applies, we rely on the following legal bases:

Where we rely on legitimate interests, we have assessed that those interests are not overridden by your rights and freedoms. You may object to such processing — see Section 10.

6. How We Collect Data

• directly from you, through our website, the Portal and order forms;
• through our communications with you, including tickets, live chat and email;
• automatically, through server and application logs when you use the services;
• from third parties, including identity verification providers, payment providers and fraud prevention agencies.

7. Who We Share Data With

We do not sell personal data. We share it only where necessary, with:

• payment providers and financial intermediaries, to process transactions;
• identity verification and fraud prevention providers, for KYC/KYB and anti-fraud checks;
• datacenter operators, connectivity carriers and infrastructure partners, to deliver the services;
• domain registries and registrars, where you register a domain through us. Disclosure of your data in that case is determined by the registry's and registrar's own rules, including WHOIS/RDAP publication requirements;
• debt collection agencies, to recover unpaid amounts;
• professional advisers, including lawyers and auditors, under confidentiality obligations;
• law enforcement, regulators, courts and other public authorities, where required by valid legal process — see Section 12;
• competent authorities in the European Union and its Member States, including Digital Services Coordinators and judicial authorities, upon receipt of a legally binding order under Article 10 of the EU Digital Services Act;
• an acquirer or successor entity, in the event of a merger, acquisition or sale of assets.

8. International Transfers

Hostry is established in the United States, and its infrastructure and personnel are distributed across multiple countries. Some services are delivered on infrastructure operated by third-party providers, so the countries in which data is processed depend in part on those providers and change when a provider changes. Personal data is therefore processed in the United States and in the countries where our datacenters, infrastructure providers and partners operate.

An up-to-date list of those countries is maintained together with the list of sub-processors and is available on request from dp@hostry.com.

Where we transfer personal data out of the European Economic Area or the United Kingdom, we rely on the European Commission's Standard Contractual Clauses, or the UK International Data Transfer Addendum, together with supplementary technical measures including encryption in transit and at rest.

9. Retention

We retain personal data only as long as necessary for the purposes described above:

Once the retention period expires, data is securely deleted or anonymized.

Retention of your hosted service data, as opposed to your personal data, is governed by the Service Suspension & Retention Policy.

10. Your Rights

10.1 European Economic Area and United Kingdom

If you are located in the EEA or the UK, you have the right to:

• access the personal data we hold about you and obtain a copy;
• rectify inaccurate or incomplete data;
• erase your data where the legal grounds for erasure apply;
• restrict processing in certain circumstances;
• object to processing based on legitimate interests, and to direct marketing at any time;
• data portability — receive data you provided in a structured, machine-readable format;
• withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of prior processing;
• lodge a complaint with your national data protection supervisory authority.

Note that erasure requests may be limited by our legal obligation to retain billing, tax and AML records for the periods stated in Section 9, and that deleting data necessary for the services may make it impossible to continue providing them.

10.2 California

If you are a California resident, under the CCPA as amended by the CPRA you have the right to know what personal information we collect and how it is used and shared; to request deletion; to request correction; to opt out of the sale or sharing of personal information; to limit the use of sensitive personal information; and not to be discriminated against for exercising these rights.

Hostry does not sell or share personal information as those terms are defined under the CCPA/CPRA, and does not use sensitive personal information for purposes requiring a right to limit.

10.3 Other Jurisdictions

Residents of other US states with comprehensive privacy laws, and of other countries granting equivalent rights, may exercise the rights available under their applicable law. Where local law does not grant specific rights, your data is processed in accordance with our standard global practices described in this policy.

10.4 How to Exercise Your Rights

Submit requests to dp@hostry.com or through the Portal ticket system. We may require verification of your identity before acting on a request, which is itself a safeguard for your data.

We respond within 30 days, or within one month where the GDPR applies, and may extend that period where the request is complex, notifying you of the extension.

You may also unsubscribe from marketing emails using the link in any such message.

11. Establishment and Representatives

Hostry does not maintain a legal entity or establishment within the European Union or the United Kingdom.

Data protection inquiries from individuals, and enquiries from supervisory authorities, should be directed to dp@hostry.com, and are handled directly by Hostry in the United States. Where an EU or UK authority submits a lawful, specific and proportionate request, Hostry will engage with it under the procedure set out in the Law Enforcement Requests policy.

12. Law Enforcement and Legal Requests

We disclose personal data to authorities only where compelled by a valid court order, subpoena, warrant or other legally binding request. We do not provide voluntary or informal access to customer data.

Where legally permitted, we notify the affected customer before disclosing their data, so that they may seek to challenge the request. We do not provide such notice where notification is prohibited by law, by judicial order, or where the request concerns an emergency involving risk to life.

The full procedure is set out in the Law Enforcement Requests policy.

13. Security

We implement technical and organizational measures appropriate to the risk, including:

• TLS encryption for all data in transit; HTTPS is enforced across our websites and Portal;
• access control, authentication and role separation for personnel;
• network-level security monitoring and segregation of customer environments;
• logging and audit trails;
• physical security — servers are held in private racks within controlled datacenter facilities;
• confidentiality obligations binding all personnel;
• secure deletion of data after the retention period.

No system can be guaranteed to be completely secure. You are responsible for keeping your own credentials confidential, and for limiting access to your account to those of your personnel who need it.

14. Data Breach Notification

If a personal data breach occurs, we will:

• notify the competent supervisory authority within 72 hours of becoming aware of it, where individuals in the EEA or UK are affected and the breach is likely to result in a risk to their rights and freedoms;
• notify affected individuals without undue delay where the breach is likely to result in a high risk, describing the nature of the breach, its likely consequences and the measures taken to mitigate it;
• notify affected residents of US states in accordance with applicable state breach notification laws;
• notify affected customers acting as controllers within the timeframe set out in the Data Processing Agreement.

15. Automated Decision-Making

We use automated checks for fraud prevention, sanctions screening and abuse detection. These may result in an order being declined or a service being suspended pending review. Such decisions are subject to human review on request — contact dp@hostry.com or open a ticket, and a member of our team will review the outcome.

16. Changes to This Policy

We may update this policy from time to time. Material changes will be notified through the Portal or by email. The effective date at the top of this page indicates the most recent revision. We encourage you to review this page periodically.

17. Contact

Hostry Compute LLC
2810 N Church St STE 89834
Wilmington, DE 19802
United States