In addition to our Terms and Conditions this document describes how HOSTRY processes your personal data obtained due to your use of our website and/or services. We demand all our clients to be at least 18 years old. We do not deliberately search or gather any personal information or data about people who have not achieved this age. We recommend to read Privacy Policy in full to guarantee the knowledge of your rights. If you have any questions about Privacy Policy or personal data collection, please contact us via any convenient means.

What do we do with your data?

When you use us as your hosting provider please mind that any video, picture or content on your website that was published and available to you as a user or even not published and unavailable is not considered to be personal data and that’s why is not covered under our Privacy Policy.

The obtaining of data

General navigation on our website: You can get access to some components of our services even without account creation. In this case only your IP address, country of origin and other non-personal information about your computer or device (browser type, search engine, time and date of queries, url, operating system, history of access) may be registered with us among any other information. This is needed to prevent unauthorised use of information and/or content.

Cookie files, metadata and activity on our website

We use cookie files and other anchors and information for storage of your personal info in order for you not to need to provide it again when you access our website for the second and all future times, as well as to provide you with personal content and information, to track the effectiveness of the provision of service for us and to gather such statistics as the number of visitors or number of page views etc.

Cookie file is a small element of computer code that will remain on your computer and contain information that will help to identify your search engine. When you access the website as well as applications and program instruments, cookie files check your identity for your id to enter the system. We use the information that was gathered with cookie files to identify your search engine to ensure that the next time you access our website the procedure was faster and more smooth because the website has already stored information about you.

If you don’t want for us to use cookies you can prevent it by simply changing the preferences of your search engine. If you do not allow to use cookie files, some or all websites, or other instruments can be not accessible for you. Sometimes the information that you upload is provided with embedded metadata. If you don’t want us to use metadata you should remove it before you upload information to our website or to our other applications and programs. We can gather the data of your visits, including the access to pages, your actions on our websites, your preferences and program instruments, made purchases and polls/contests you took part in. We can also gather information about your PC, mobile phone and other device, including the type of the device, search engine, location, IP address and words that have been used to perform the search.

The use of the account

In order to use many of our services, you will need to create account with us. In order to registrate you with us we will need certain information from your side. We and you should abide by the Data Protection Regulations (i.e. all laws on data processing, including personal data, if they are still in effect and can be used to the information that is provided to us) and General Data Protection Regulations (Regulation EC 2016/679), including any other Regulations that is connected with the processing of the personal data. We guarantee you the integrity of personal data that you have disclosed to us according to this document.

What data do we collect?

If you allow, we will collect and process the following types of the personal data:

• Your personal name, address, and phone number;
• Your preferred payment method;
• Your e-mail address, Skype and other addresses, contact information, and web IDs that are used for online communication;
• Personal ID number / Tax Identification Number (TIN);
• The data that is used for your identification, such as your national passport or other means that can identify you;
• Information about our communication with you, such as requests that have been submitted to our support team to solve any technical or administrative issue, full logs of our conversations with you, information about your e-mail account and e-mails that have been sent to us;
• Account data. This is the data of your products, IPs, and services that you have purchased or plan to purchase with us, information about your domain name, assigned IP addresses by us, client identifier, or any other information that is relevant to your personal cabinet.

Lawful Basis for Processing

We process your personal data based on the following legal grounds:

• Performance of a Contract: To provide our hosting services, process orders, and manage your account.
• Legal Obligation: To comply with Know Your Business (KYB), Anti-Money Laundering (AML) directives, and tax laws, which require us to collect identification data (e.g., national passport, tax ID).
• Legitimate Interests: To prevent fraud, ensure network security, and conduct statistical analysis to improve our services.

Why do we process your data?

We process your data for the following purposes:

• to follow the laws, including our Agreement, Terms and Conditions and Privacy Policy as well as other natural rights or something that may be required due to existing regulations and legislation as a result of any trial or government institute, including the privacy laws;
• to provide the security of any individual, to prevent fraud and other malicious activities;
• to investigate and process any suspicious actions that may be performed by client;
• to improve any part of our website, to conduct statistical analysis related to the use of our website or applications and programs that can be accessed via this website, to make statistical analysis, to conduct the polls that will help us understand user satisfaction which is needed to keep our clients and to perform needed marketing events. This may include e-mail, mass media and other means of communication. Such info is also needed for sales purposes, including the analysis of data and use of our services to make improved marketing proposals to make the satisfaction rate higher;
• to perform any financial actions, including payments, receiving of payments, invoice generation and processing of financial transactions regarding the purchased products and services, as well as disclosing this information to collectors (third party) to collect debts if any;
• to make our website work better for you, to increase the quality of our services, and to develop additional products and services;
• to provide the opportunity to purchase our products and services via website or other mean of communications. You may also be forwarded to the secure gateway for payment. We will NOT gather any sensitive information about your credit/debit/payment card or any other mean of the payment. Such info will be passed to the third-party payment systems and is controlled by their own respective privacy policy;
• to contact you regarding our products and services, orders, statuses of orders and to answer your questions;
• to give our personnel the opportunity to help you in case needed and to manage our infrastructure, systems, databases and other applications and program instruments;
• to fulfill our contract as well to process orders and provide you with products and services from our side.

If you decide not to provide us with your information we may be unable to provide you with information, program products and services or give you support you may need. We will not disclose your personal information unless it will be demanded by law or trial orders as well as any other legislation in order for our systems to be functioning properly, to protect us and our other users and clients and unless it will be needed according to any other lawful grounds. In this case we will immediately notify you about such circumstances before we process your data according to the applicable laws, if those laws do not forbid such notification.

Minifying of data

We will use any reasonable means to minify the volume of your personal data that we process to the needed level. We will use all reasonable means to guarantee that your processed data is really needed to achieve goals that are specified by this Privacy Policy.

We can share the data about you with:

• our partners and agents that take part in providing services to you;
• anti-fraud agencies;
• collectors and other organizations collecting debts;
• security agencies, regulatory organisations, courts or other government institutes in the portion really needed by the law;
• competent authorities in the European Union and Member States, including Digital Services Coordinators and judicial authorities, upon receiving a legally binding Order to provide information in accordance with Article 10 of the EU Digital Services Act (DSA);
• we will also share your information if you register your domain name with us. In this case the disclosing of your personal information is determined by the registrator Privacy Policy.

We do not disclose your personal data to the third parties with exception to the cases when it goes along with this Privacy policy or is needed by the law. You agree to give us the right to use gathered personal information to achieve any goals stated in this Privacy Policy.

What methods do we use to collect personal data?

We use the following means to collect personal data:

• our own website;
• our conversations, including live chat logs, e-mails, regular mails and other chat sessions;
• the process of providing our products and services to you, including provision of support by our dedicated department when you use our/our partners network, infrastructure and/or other services;
• the process of performing actions regarding commercial activity.

Data Retention Periods

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Specifically:

• Operational and Security Logs (e.g., IP addresses, access history) are retained for up to 12 months to ensure network security and prevent fraud.
• Account and Billing Information is retained for the duration of our contract and for up to 10 years after account termination to comply with EU and Cyprus tax, accounting, and anti-money laundering (AML) legal obligations.
• Once the retention period expires, your data is securely deleted or anonymized.

What rights do you have?

European Privacy Rights The rights described in this section apply specifically to individuals located within the European Economic Area (EEA) and the United Kingdom, in accordance with the General Data Protection Regulation (GDPR). If you reside outside these territories, your personal data will be processed in accordance with our standard global privacy practices, and the specific rights listed below may not apply to you unless required by your local jurisdiction.

Regarding your personal data you have the following rights:

• to delete or take back all personal data after finishing using our services to the extent that is allowed by the applicable law;
• you can ask us to stop processing your data and do it at any time. It will not influence previous processing;
• you can demand us to explain what data was processed and for what purposes;
• if you find any inconsistencies in your personal data, you can change it yourself or ask us to do this for you. You will also have the right to provide any additional information that you may consider relevant;
• in certain circumstances you can immediately contact us and ask to permanently delete your personal information if you don’t want us to process it. This, however, may lead to inability of using our services until the permission will be granted again;
• if you want to change your personal data that you cannot change yourself, please contact us at dp@hostry.com;
• you have the right not to take part in our marketing activities. Just press unsubscribe link in any of our e-mails. If you cannot find this link or it is not available, please contact us at dp@hostry.com;
• if you are sure that the personal data is used without your consent you can let us know about that immediately and we will fix any arising issue. If we fail to do so, you have your lawful right to file a claim to the corresponding organization that is responsible for control of data protection.

Do we guarantee the security of received data?

We do guarantee the security of received data because:

• we possess the needed technical and organizational means needed to protect your personal data from unlawful processing, from loss and destruction of your personal data;
• we always search for the means of making our technical, physical and administrative means better in order to make your data even more secure. We use TLS certificates to encode the data. This is applicable to our web sites, where https is a must;
• all data is stored in private servers. Servers are located in private racks with several layers of protection;
• all our personnel has a point in NDA and will not disclose any of your private information.

Data Breach Notification

In the event of a personal data breach affecting users located in the European Economic Area (EEA), Hostry will notify the competent supervisory authority within 72 hours of becoming aware of it. If the breach poses a high risk to your personal data, we will communicate the breach to you without undue delay, providing information on the nature of the breach and the measures taken to mitigate it.
You should also guarantee that the access to your personal information will be limited to those persons from your personnel, who really need it to use our services.

Privacy policy of children

We do not deliberately collect information about users below the age of 18, as they are forbidden to use our services. If it became known to you that a child has shared personal information with us, please immediately inform us about that at dp@hostry.com.

Other

If you have received the login and password from your personal cabinet and for the service, it is your responsibility to keep them in safe place. Any person that gets access to those credentials will be able to use service and your personal cabinet from your behalf.

Changes to Privacy Policy

We can change Privacy Policy at any time, so make sure you check this page regularly to monitor the changes. If you have questions, please don’t hesitate to contact us at a href="mailto:dp@hostry.com">dp@hostry.com.