Privacy and cookie policy

The short version

We collect minimal personal information from you, and only require an email address and password from you in order to provide our services. We do not sell your data to third parties. We use cookies to optimise website performance.

The long version

  1. General
    1. sdbx.moe (hereinafter, referred to as "we" or "us"), collects from the individual user (hereinafter, referred to as "you" and "your") certain personal data through the website https://sdbx.moe (hereinafter, referred to as the "Website"). We act as a data controller, i.e., the entity that determines the purposes and means of processing of your personal data.
    2. The Website provides users with the means to order hosting services (hereinafter, referred to as the "Services") for digital files by using a remote server.
    3. This Privacy and Cookie Policy (hereinafter, referred to as the "Privacy Policy") contains our policies and procedures governing the processing (i.e., collecting, storing, deleting, using, and disclosing) of personal data (i.e., any information relating to a natural person who can be identified, directly or indirectly, by using such information) through the Website.
    4. This Privacy Policy enters into force on the effective date indicated on the bottom of the Privacy Policy and remains valid until terminated or updated by us or until you stop using the Services.
    5. By using the Website, you acknowledge that you have read this Privacy Policy and you agree to be bound by it. If you do not agree with one or more provisions of this Privacy Policy, please do not use the Website.
    6. Your use of the Website is subject to this Privacy Policy. By using the Website or creating your user account on the Website and accepting this Privacy Policy, you are consenting to our processing of your personal and non-personal data as set forth in this Privacy Policy. Should we intend to collect any sensitive data from you, provide you with marketing communication, use your personal and non-personal data for the purposes not indicated in this Privacy Policy, transfer your personal data to third parties not indicated in this Privacy Policy, or significantly amend this Privacy Policy, we will seek your express consent in advance.
  2. Data collected by us
    1. Personal data. We adhere to data minimisation principles and collect only a minimal amount of personal data that are necessary for your usage of the Website and the Services.
      1. When you visit the Website, we collect your IP address.
      2. When you create an account on the Website, we collect your email address and password.
      3. When you make a payment through PayPal, PayPal's privacy policy will apply to the information you provide on the PayPal Web site.
      4. When you fill out the contact form available on the Website, we collect your e-mail address and any other information you decide to provide us in your message.
    2. Non-personal data. When you visit the Website, we may collect technical non-personal data, such as your browser types, operating systems, and the URL addresses of websites clicked to and from the Website, and your other online behavior. We collect the non-personal data in order to analyze what kind of users visit the Website, how they find it, how long they stay, from which other websites they come to the Website, what pages they look at, and to which other websites they go from the Website. The non-personal data collected by us are used only for the purposes of improving the Website and your user experience.
    3. In case your non-personal data are aggregated with certain elements of your personal data in the way that we may become able to identify you, such non-personal data will be treated as personal data.
  3. The purpose of collection of personal data
    1. We respect data protection principles and processes personal data only for specified, explicit, and legitimate purposes.
    2. The personal data collected during the registration of your user account on the Website or when you log in to the Website are used only for allowing you to create an account on the Website, providing you with the requested Services, contacting you with regard to the Services and the Website, and sending you information about Services that are similar to the Services used by you. Lawful basis: performance of a contract with you (i.e., maintaining your user account and providing the Services).
    3. The personal data submitted by you through the contact form available on the Website are used only for performing the tasks requested by you, answering your questions and providing you with the requested information, improving our business activities, and optimising the Website and the Services. Lawful basis: pursuing our legitimate interest (i.e., growing our business).
    4. Your IP address will be used only for providing you with the Services, improving our business activities and optimising and personalising the Website. Lawful basis: performing a contract with you (i.e., providing you with the Services) and pursuing our legitimate interest (i.e., analysing and improving our business activities).
    5. Your full name and credit card information will be used for processing your payments only. Lawful basis: performance of a contract with you (i.e., processing payments for the Services).
    6. We shall seek your prior express consent for using your personal data for any purposes that are not indicated in this Privacy Policy.
  4. Marketing communication
    1. From time to time, we may send you informational communications related to the Website and the Services, such as administrative information about the Services, information about updates of the Website and the Services, information about security breaches, or other related matters. Please note that such communications do not fall within the scope of direct marketing communication.
    2. We will send you direct marketing communications, including newsletters, offers of our new Services, recommendations, and promotions, only after you provide us with your prior explicit opt-in consent to receive such marketing communication.
    3. You have the right to opt-out from receiving direct marketing communication at any time by clicking on the "unsubscribe" link contained in each such marketing email sent to you or by contacting us directly. Our contact details are indicated in Section 12 "Contact information" of this Privacy Policy.
  5. Protection of personal data
    1. We employ information security tools to protect personal data collected through the Website. Such information security tools include, but are not limited to, secured networks, encryption, anonymization, and limited access to personal data. However, due to the inherent risks of using the Internet, we cannot be liable for any destruction, loss, use, copying, modification, leakage, and falsification of personal data caused by circumstances beyond our reasonable control.
    2. Breach notification. Should a personal data breach occur, we will inform the relevant authorities without undue delay and immediately take reasonable measures to mitigate the breach. We will notify you about such a breach as soon as possible through a notification on the Website and by sending you an e-mail.
  6. Retention period
    1. Your personal data will be kept for as long as it is necessary to provide you with the requested Services or until you request us to delete your personal data. When your personal data are no longer necessary to deliver the requested Services or upon your explicit request, we will delete your personal data immediately, unless we are obliged by law to retain such personal data for a specific period of time (e.g., for keeping accountancy records) or you provide us with your explicit consent to retain the personal data for a specified period of time.
    2. Please note that we may retain your communications submitted though the contact form for our legitimate interests (e.g., tracking our business activities) if such communications contain information relevant to our business. Where possible, we will anonymise your personal data.
  7. Third party access to personal data
    1. In certain situations, we may disclose your personal data to third parties. Such a disclosure is limited to the situations when the personal data are required for the purposes of provision of the Services or any information requested by you, pursuing our legitimate interests, law enforcement purposes, or if you provide your prior explicit consent. Please note that some third parties may be located outside of the jurisdiction in which you reside.
    2. Third-Party Service Providers. Your personal data may be legitimately disclosed to third parties that provide services on behalf of us or provide technical support to us, and assist us in providing the Services (hereinafter, referred to as the "Third-Party Service Providers"). Such Third-Party Service Providers may include newsletter providers and other parties who assist us in operating the Website and providing the Services. The Third-Party Service Providers act as data processors with regard to your personal data. Therefore, they will access your personal data as a part of their partnerships with us and only if such Third-Party Service Providers agree to assure an adequate level of protection of personal data that is consistent with this Privacy Policy. The Third-Party Service Providers include the following entities:
      1. Our business analytics providers Google Analytics.
    3. We do not sell, trade, or transfer to third parties not indicated in this Privacy Policy your personal data, unless we obtain your prior explicit consent to do so.
    4. Please note that we allow third-party behavioral tracking, which may include personal and non-personal data.
    5. If requested by public authorities exercising their official mission, we will disclose your personal data for law enforcement purposes.
    6. We are not responsible for actions of other third parties that are not mentioned in Section 7 of this Privacy Policy and with whom you share your personal data, and we have no authority to manage or control third party solicitations.
    7. Transfer outside the EEA. Some of the Third-Party Service Providers are located outside the European Economic Area (EEA) and, if you a resident of the EEA, we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection of your personal data or we conclude an agreement with the respective third party that ensures such protection.
  8. Your rights regarding your personal data
    1. We strive to assure that your personal data are true, accurate, up-to-date, and complete. If you would like modify or delete your personal data that are processed through the Website, you can do so by updating your personal data in your user account through the "Client Area" available on the Website.
    2. You have the right to manage the personal data that we collect from you. More particularly, we provide you with a possibility to request us to:
      1. Get a copy of your personal data that we store;
      2. Rectify inaccurate personal data;
      3. Move your personal data to another processor;
      4. Delete your personal data from our systems;
      5. Object and restrict processing of your personal data;
      6. Withdraw your consent; or
      7. Process your complaint.
    3. If you would like to exercise your rights listed above, please contact us by email at [email protected] and explain in detail your request. In order verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we would be able to identify you in our system. We will answer your request within a reasonable timeframe but no later than 2 weeks.
  9. Links
    1. Please note that the Website may contain links to third party websites. We hereby disclaim any liability in relation to the privacy practices of other websites. Before visiting any websites owned and operated by third parties and providing any information or personal data to the owners or operators of such websites, you should familiarise with the applicable privacy practices and take reasonable steps that are necessary to protect your personal data.
  10. Complaints about handling of personal data
    1. You have the right to submit a complaint to us about the way in which your personal data have been handled by using the contact details indicated in Section 12 "Contact information" of this Privacy Policy.
    2. After you submit such a complaint, we will send you an email within 5 business days confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe but no later than 2 weeks.
    3. If you are a resident of the European Union and you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
  11. Cookies
    1. The Website uses cookies. A cookie is a small computer file. It typically consists of letters and numbers. When you visit a website, the website may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer system. The main purpose of cookies is to allow a website to recognise user's device.
    2. There are two types of cookies, namely, persistent cookies and session cookies. Persistent cookies remain valid until their expiration date, unless deleted by the user before that date. Session cookies will be stored on a web browser and will remain valid until the moment when the browser is closed.
    3. Cookies do not typically contain personal data. However, personal data stored by us may be linked to the information stored in and obtained from cookies. Web servers can use cookies to: identify and track users while they navigate through different pages on a website; and identify users returning to a website.
    4. We use both session and persistent cookies. We use session cookies in order to verify your details until you are navigating from page to page on the Website. The session cookies enable you to avoid re-entering your details each time you enter a new page on the Website. We use persistent cookies in order to recognize you as a unique user when you return to the Website. As a result, you do not have to enter your login details multiple times as you move from other websites to the Website. We may also use cookies to place interest-based advertisements on the Website. We will not use cookies for purposes which are not mentioned in this Privacy Policy.
    5. We use Google Analytics to analyze your use of the Website. Google Analytics generates statistical and other information about the Website by means of cookies. The information generated by Google Analytics in relation to the Website is used to create reports about the use of the Website. For information on the privacy aspects of Google Analytics, please visit https://support.google.com/analytics/answer/6004245?hl=en .
    6. By using the Website, you agree to our use of non-privacy intrusive cookies as described in this Privacy Policy. For other types of cookies, we will seek your consent. If you do not agree to our use of cookies, you need to either refuse our use of cookies, discontinue your use of the Website or set your browser to refuse cookies. Please be aware that some parts of the Website may not function properly without cookies. If you would like to set your browser to refuse cookies, check your browser's help information or visit http://www.whatarecookies.com for further information.
    7. On occasions, we may offer third-party content on the Website. These third parties may install cookies that are not controlled by us.
    8. We honor "Do Not Track" browser mechanisms. You can also choose to visit the Website anonymously.
  12. Contact information
    1. If you have any questions, comments, or concerns about this Privacy Policy, please contact the Company by:
      1. Email: [email protected]
  13. Amendment of this Privacy Policy
    1. We reserve the right to amend this Privacy Policy from time to time by posting an amended version on the Website. Your continued use of the Website after posting such an amended version will constitute your acknowledgment of the amendments and your consent to abide and be bound by the amended Privacy Policy. Please regularly review this Privacy Policy in order to be aware of new amendments.
    2. For significant changes in the Privacy Policy, or where required by the applicable law, we may seek your explicit consent to the changes stated in the Privacy Policy.
  14. Last amendment
    1. This Privacy Policy was last amended on 16th May 2020.