privacy-policy.md

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Your privacy is critically important to us. At Cloud68.co OÜ, we have a few fundamental principles:

* We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.

* We store personal information for only as long as we have a reason to keep it.

* We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.

* We help protect you from overreaching government demands for your personal information.

* We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

#### Who We Are and What This Policy Covers
Howdy! We are the folks behind a variety of products and services designed to allow anyone — mainly freelancers (or as we call them solopreneurs) and Small Medium Enterprises (SMEs)— to take full advantage of the power and promise of the open web through open source software. Our mission is to offer as many freedoms as possible to everyone that wants to use technology for personal, institutional and business use. We believe in powering the open Internet with software and tools that are open source and are proud to say that our internal infrastructure and the tools we offer to our partners are available under open source licenses. In addition, we are contributors to our local and transnational open source community for many years. <br>
This Privacy Policy applies to information that we collect about you when you use:

* Our website (cloud68.co );

* Our other Cloud68.co OÜ products and services that are available on or through our websites;

Throughout this Privacy Policy we’ll refer to our websites, and other products and services collectively as “Services.” <br>
Please note that this Privacy Policy does not apply to any of our products or services that have a separate policy namely [Terms of Service](https://cloud68.co/legal/terms-of-service).<br>
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.<br>

#### Creative Commons Sharealike License
This legal text is a remix of the work done by the amazing folks at [Automattic](https://automattic.com/). Creative Commons Sharealike License means that you can grab a copy of this Privacy Policy and other legal documents on [Github](https://github.com/Automattic/legalmattic). You’re more than welcome to copy it, adapt it, and repurpose it for your own use. Just make sure to revise the language so that your policy reflects your actual practices.

#### Information We Collect
We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better. <br>
We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.


###### Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:

* Basic Account Information: We ask for basic information from you in order to set up your instance(s). For example, we require individuals who sign up for one or more Cloud68.co instances to provide an email address along with a name, depending on the chosen package.

* Transaction and Billing Information: If you buy something from us – a subscription to one of the packages we offer, for example – you will provide additional personal (or company) and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.

* Communications with Us (hi there!): You may also provide us information when you respond to surveys, communicate with our Support Team about a support question or sign up for a newsletter. When you communicate with us via form, email, phone or otherwise, we store a copy of our communications (including any internet call recordings as permitted by applicable law).


###### Information We Collect Automatically

We also collect some information automatically:

* **Log Information**: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use Services offered from our servers. We do this by using open source tools such as Matomo and Mautic hosted in our infrastructure. We avoid services like Google Analytics due to our efforts on not sharing your data with companies and entities we have indications that do not respect your privacy and personal data.

* **Usage Information**: We collect information about your usage of our Services. For example, we collect information about the size of the hosting space you are using, the number of users that are using one or more of our instances etc. We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.

* **Location Information**: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.

* **Information from Cookies & Other Technologies**: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails (including newsletters). Cloud68.co OÜ uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign and newsletter effectiveness.

###### Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log into our chat.cloud68.co chat platform through another service (like Gitlab) we will receive information from that service (such as your username and basic profile information) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.

###### How and Why We Use Information. Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:

* To provide our Services–for example, to set up and maintain your account, host your Nextcloud instance, backup and restore your InvoiceNinja instance, charge you for any of our paid Services.

* To further develop and improve our Services–for example, by adding new features that we think our users will enjoy or will help them to create and manage their instances more efficiently.

* To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use.

* To measure, gauge, and improve the effectiveness of our promotional activities, and better understand user retention and attrition — for example, we may analyze how many individuals purchased a paid plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time.

* To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Cloud68.co OÜ and others, which may result in us declining a transaction or the use of our Services.

* To communicate with you, for example through an email, about offers and promotions offered by Cloud68.co OÜ and others we think will be of interest to you, solicit your feedback, or keep you up to date on Cloud68.co OÜ and our products (which you can unsubscribe from at any time), and

* To personalize your experience using our Services, provide content recommendations, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time), and serve relevant information.

###### Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:<br>

(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or<br>
(2) The use is necessary for compliance with a legal obligation; or<br>
(3) The use is necessary in order to protect your vital interests or those of another person; or<br>
(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or<br>
(5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookie Policy pop-up.<br>

###### Sharing Information. How We Share Information
We do NOT sell our users’ private personal information.<br>
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:<br>

* Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.

* Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your instances. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you and/or our server provider. We always choose our vendors carefully in order to make sure they have solid data protection policies and respect your data.

* Legal and Regulatory Requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request. We do so by making sure that governmental agencies follow the law and do not request data in an abusive way. We will make sure to protect your data in cases of governmental requests that do not make sense and are considered abusive from our part and will do so by using any legal means. 

* To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Cloud68.co OÜ, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.

* Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Cloud68.co OÜ goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy. In case of any change in this document we will reflect these changes in our website.

* With Your Consent: we may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so.

* Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.

* Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.

###### How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it — which are described in the section above on How and Why We Use Information — and we are not legally required to continue to keep it.<br>
For example, we keep the web server logs that record information about a visitor to one of Cloud68.co OÜ’s websites, such as the visitor’s IP address, browser type, and operating system, for at least 12 months. We retain the logs for this period of time in order to, among other things, analyze traffic to Cloud68.co OÜ’s websites and investigate issues if something goes wrong on one of our websites and services.
 
###### Security
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks. </br>
To enhance the security of your account, we encourage you to enable our advanced security settings, like Two Step Authentication. We also make sure that at our offices me take measures to make sure that our systems are not compromised. In addition, we have backup policies based on the latest security standards.
###### Choices
You have several choices available when it comes to information about you:<br>

* **Limit the Information that You Provide**: If you have an account with us, you can choose not to provide the optional account information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.

* **Opt-Out of Marketing Communications**: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or <a href="https://cloud68.co/our-virtual-office">let us know</a>. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.

* **Set Your Browser to Reject Cookies**: You can usually choose to set your browser to remove or reject browser cookies before using Cloud68.co OÜ website and services, with the drawback that certain features of Cloud68.co OÜ website and services may not function properly without the aid of cookies.

* **Close Your Account**: While we’d be very sad to see you go, if you no longer want to use our Services :( :( :( :(, you can ask us to close your account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

###### Your Rights
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:  <br>
* Request access to your personal data;
* Request correction or deletion of your personal data;
* Object to our use and processing of your personal data;
* Request that we limit our use and processing of your personal data; and
* Request portability of your personal data.

You can usually access, correct, or delete your personal data using tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to contact us. <br>
EU individuals also have the right to make a complaint to a government supervisory authority.<br>

#### Controllers and Responsible Companies
Different Cloud68.co OÜ companies are the controller (or co-controller) of personal information, which means that they are the company responsible for processing that information, based on the particular service and the location of the individual using our Services.<br>
Depending on the Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is the Cloud68.co OÜ company that entered into the contract with you under the Terms of Service for the the product or service you use. In addition, Cloud68.co OÜ, an Estonian-based company, is the controller for some of the processing activities across all of our Services in EU and worldwide.

#### How to Reach Us
If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in this document, please contact us at [office@cloud68.co](mailto:{{ 'office@cloud68.co' | encode_email }}).

#### Other Things You Should Know (Keep Reading!)
###### Transferring Information
Because Cloud68.co OÜ’s Services are offered in specific countries, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, or third party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

###### Visitors to Our Users’ Websites
We also process information about visitors to our users’ websites and digital infrastructure, on behalf of our users and in accordance with our user agreements. Please note that our processing of that information on behalf of our users for their websites and digital infrastructure isn’t covered by this Privacy Policy. We encourage our users to post a privacy policy that accurately describes their practices on data collection, use, and sharing of personal information. An example of this case is if one of our Subscribers that has created a website by using a <a href="https://cloud68.co/instances/ghost">Ghost instance</a> from us. 

###### Privacy Policy Changes
Although most changes are likely to be minor, Cloud68.co OÜ may change its Privacy Policy from time to time. Cloud68.co OÜ encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (such as adding a statement to our homepage or the Cloud68.co OÜ Blog, social media or by sending you a notification through email. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.<br>

That’s it! Thanks for reading.