At Spatros ApS we care about your privacy and believe in transparency. That’s why we are committed to being upfront about our privacy practices. We only collect personal information necessary to deliver our services and we handle it carefully and sensibly.
Collection of Information:
When you access and browse the Site (including when you submit personal information to us through data entry fields on the website) we will collect the following from you:
Information you provide:
- Contact information – we receive and store any information you enter on our Site. Our Site uses forms to collect your personal information including your name, address, telephone number, email address so you can place orders, request information, get support and use our services.
- Payments and billing information – when signing up for any of our Services, products, or programs, we request additional personal and payment information such as your name, credit card information, PayPal or relevant service, billing address, personal, government or TAX identification number or other information including but not limited to certificates, tax declarations, forms, payment documents and other relevant documents.
- Surveys and contests – we may, from time to time, offer surveys and opinion polls and ask you to provide information about your experience and feedback for our services. Occasionally we may organize contests, sweepstakes, competitions, prize draws, or other promotions (collectively “Contests") on our Site or through our Social Media channels and may offer a prize as a sign of appreciation to the people who have participated, qualified and/or completed our Contest. Information requested for entry may include personal contact information such as your name, email, address, phone number, etc. Participation is entirely voluntary and it’s up to you whether you choose to disclose any information or not.
Information we receive from your use of our services or third-parties
- Automated information – when you visit our website we receive and collect information, which may in certain circumstances constitute personal information and which includes your IP address, referral URL, exit URL, browser software, operating system, date/time and/or clickstream data.
- Website Analytics tools – We use analytics services by third parties to collect information about the use of this Site, such as the number of visits, pages visited, the popularity of certain content. Analytics tools use tracking technologies (like cookies) to recognize your device and compile information about you. They collect information such as what pages you visit and how much time you spend on these pages, the IP address assigned to you, what operating system and web browser you use, and what site you visited prior to visiting our website.
- Information Logs – when you visit the Site, view content provided by us, use our services, use our Chat service, ask us a question, request technical assistance in regards to our services, send us an email or participate in a contest or survey on our website, we automatically collect and store certain information in log files. This includes your IP address, URL, referral URL, exit URL, browser software, operating system, date/time, requests type to our Site and error responses returned by our Site or Services.
- Other information – we also receive and store any information that you provide on our Site, our Chat service, any forms on our site, email, telephone, or any other type of communication with our team or related to the provisioning of our services. Whenever you contact us, we will record the ticket, chat or call to ensure we have an accurate record of all communication, which is needed to provide our services and to support any action taken by our team as a result in the event of a dispute over our response.
How we utilize information
Information you provide:
We collect, store and use the information you provide for the following reasons:
- Contact information – to contact you regarding the progress of your orders, status of the services, functionality changes to our products and our Site, and – where you have opted in to receive such information – other/new services, and/or special offers/newsletters we think you might find useful, we use email, telephone, and/or text message, as well as to inform you about hosting account issues, service interruptions or updates, service improvements or new products in accordance with our Terms of Service and applicable law.
- Payment and billing information – we need it together with your contact details, to open a Client or an Affiliate account for you, to process your orders and renewals, to enter into a contractual agreement for any Services, to invoice you and to fulfil our legal obligations for tax calculations.
- Surveys and Contests –
- any answers to surveys and opinion polls are stored separately from your details and we either anonymize or pseudonymize the data collected, which can be used for ascertaining the usage of certain aspects of our Site and services and market research. We may share the anonymised or pseudonymised data with third parties when they need the information to fulfil their obligations to process it on our behalf. However, neither the anonymised data nor the pseudonymised data allow to identify you personally without the use of additional information which is kept separately and is subject to technical and organisational measures to ensure that none of the data is attributed directly to you.
- If you enter a contest, we use the data you provide for the successful administration of the Contest, to contact you or work with third parties to contact you in case you’ve won anything and fulfil prizes in accordance with the announcement and terms of the participation for the respective Contest. We may also, where you have opted in to receive such communication, and unless prohibited by law, use your information provided via our surveys and Contests to send you details about our services or offers.
Information we receive from your use of our services or third-parties
We collect, store and use the information that we receive from your use of our services or third parties for the following reasons:
- Automated information – to diagnose problems with our servers, to administer our Site and services. This is not linked to any personally identifiable information, except if necessary to prevent fraud or abuse on our Site and systems.
- Analytics tools – to improve services on our Site.
- Information Logs – for diagnosing problems, administering our Site and resolving issues.
- Other information – to maintain your account and purchased products, to have an accurate record of any inquiries in case of a dispute and to identify certain characteristics that could help us optimize and improve our products and services.
Purposes of data processing
When you access or use our Services, we need to collect, use, and otherwise process your information, as set out in this Policy. We are committed to your privacy and follow a few fundamental principles when we process personal data:
- We strive to collect only the minimum personal data that we need to deliver any Services to you.
- We aim for full transparency on how we use your information to comply with legal or other lawful purposes and respect your privacy.
- We make sure we only use your information for the purposes you have given us permission for.
We rely on a number of legal bases to use your information, as set out in this Policy:
- Contract – the use of your information is necessary to perform any contractual obligations in order to provide any Services to you or to administer any Contests you enter into;
- Legal obligations – our use of your personal information is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims. For example, if we are requested to disclose your personal information to regulatory bodies or law enforcement authorities; or to use your personal information for tax calculations.
- Our legitimate interests – necessary for the purposes of our legitimate interests, such as to:
- run, grow, develop and deliver our services;
- detect and prevent fraudulent activities;
- enhance the security of our network and information systems;
- better understand how people interact with our website;
- determine the effectiveness of our promotional campaigns and advertising; and
- enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.
- Consent – we rely on your consent for us to use your personal information to send you marketing information (such as our newsletters and promotional offers) by email, SMS, or telephone. You may withdraw your consent at any time by updating your personal Info/Settings in your user profile in our User Area, using our Unsubscribe option in relation to email subscriptions, or contacting us using the details set out in the “Further questions and contacts" section of this Policy.
Cookies, beacons, tags, pixels
Our Site includes marketing cookies and remarketing pixels provided by third parties. That allows these parties to collect the information that you have visited our Site and were interested in certain offers. We also use beacons, tags, click tracking codes and scripts to analyze trends and movements of users around the Site, gather information about the user base as a whole and how we can improve our service and Site, to provide advertising based upon activities and interests and to measure advertising effectiveness. As a result, we may display targeted, or interest-based offers to you based on the products you currently own or have recently viewed and deliver other communication more relevant to you and your interests outside of our Site, on other websites part of the third party's network.
You can manage your preferences regarding Cookies either by modifying your browser settings or using the designated pop-up tool on our website. In the ‘Cookie Settings’ pop-up on our Site, you will find a list of all cookies within each category (required, statistics, marketing), or a list of vendors serving cookies and similar technologies and will be able to choose which types of cookies you would like our Site to use if any.
You can also modify your Cookie preferences straight from your browser. Please note that if you simply disable all of our cookies or cookies in general in your browser settings, you may find that certain sections or features of our Site will not work, because your browser may prevent us from setting Site functionally required cookies.
How we share your personal information and who we share it with
All personal information collected by Spatros Hosting is treated as confidential. We disclose the entire or part of your data in the limited circumstances described below and with appropriate safeguards on your privacy:
- If we are required by law – we will disclose information about you in response to a subpoena, court order, or other legitimate governmental requests.
- To Protect Rights and Property – We will share account and personal information with companies, organizations or individuals when we believe in good faith that access, use, preservation or disclosure of the information is necessary to meet any applicable law, comply with regulation, legal process or enforceable request; to enforce or apply our Terms of Service and other agreements; to investigate potential violations; to protect against harm to the rights, property or safety of Spatros Hosting, our users or the public as required or permitted by law. To the extent we are legally permitted to do so, we will take all reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of the legal process.
- Domain Registrars – the domain’s owner information (WHOIS Data) for any domain name is required and controlled by the ICANN-accredited registrar provider and the Registry for the top-level domain which you wish or have registered. We share your information to the extent necessary to comply with ICANN's rules, regulations and policies, with rules and policies by the ICANN-accredited registrar providers we represent and the rules and policies of the top-level domain Registry. These registrar providers are located in Europe, the USA and Canada. The information is also shared with the Registry for the top-level domain which may be located in another jurisdiction. The use and disclosure of the personal information as part of the domain registration process is governed by the Domain Name terms in our Terms of Service and the applicable agreements with the ICANN-accredited registrar.
We host, store or otherwise handle your personal information within the borders of the European Economic Area (EEA) and the USA.
We will make sure that any transfers of your personal information from one country to another comply with thе data protection and privacy laws that apply.
European data protection laws, in particular, include specific rules on transferring personal information outside the EEA.
When transferring personal information outside the EEA to the USA, we will include the standard data protection clauses approved by the European Commission under Article 46.2 of the General Data Protection Regulation (GDPR) into our contract with the US-based Spatros Hosting group company or other Partners.
You can find out further information about the rules on data transfers outside the EEA, including the mechanisms that we rely upon, on the European Commission website here.
We use Secure Sockets Layer (SSL) software to encrypt the information you enter on our Site in order to protect its security during transmission to and from our Site. When storing information, we protect its security by encryption and pseudonymization of critical data. When we process credit card information and payments, the credit card is subject to tokenization and strong security measures.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures require us in some cases to request proof of identity before disclosing personal information to you.
To protect against unauthorised access to your account and information, we implement session management, login expiration mechanisms and the option of using 2-factor authentication for User Area access. As an additional safety measure, be sure to sign off when you finish using your account and your computer
Although we take all these measures to maintain the safety and security of your personal information, please note that no transmission over the Internet can ever be guaranteed to be secure. Consequently, please note that we cannot fully guarantee the security of any personal information that you transfer over the Internet to us.
Information collected on our website will only be retained for as long as necessary to fulfil the purpose for which it was collected. In general, we will automatically delete your User Area account information 2 years after you no longer have any active services with us. Since we offer a service for customers worldwide and we need to comply with regulations across the globe in regard to retention of personal information related to contractual agreements, provision of services, financial, billing, invoicing operations and tax calculations, a versioned copy of your contact, payment and billing personal data associated with your past invoices is stored for a period of 10 years after deactivating an account. Your personal data is deleted automatically by our systems in accordance with these retention periods.
By visiting the My Details page in your User Area, you can access, correct, change, and delete certain personal information associated with your account. If you need further assistance, you can contact us using the details in the “Further questions and contacts" section of this policy to request any of the following:
- confirm whether or not personal data about you is being processed;
- provide you with further details about how we process your personal data;
- provide you with a copy of any data which we hold about you;
- withdraw your consent to using your personal information, where we rely on your consent as a legal basis to justify using your personal data;
- consider any valid objection to the processing of your personal information (including the right to object to processing on grounds relating to your particular situation where we are relying on our legitimate interests as a legal basis for processing);
- request to update or delete personal data which we hold about you;
- restrict the way that we process your personal data;
- consider any valid request to transfer your personal data to a third-party provider of services (data portability); and
We will consider all those requests. However, certain personal information may be exempt from those requests in certain circumstances, which include a need to keep processing information for our legitimate interests or to comply with a legal obligation. If such an exception applies, we will notify you when responding to your request. Please note that we may ask you to provide us with information necessary to confirm your identity before responding.
In accordance with Spatros Hosting Terms of Service, we do not sell products, provide services or collect information from any individual under the age of 13. If you are under the age of 13, you are not allowed to use the Site and you must request your parent or guardian to use the Site instead. Should you have evidence that someone under the age of 13 has bought services and provided their personal information to us, please contact us using the details set out in the “Further questions and contacts" section below.
If we make material changes to this Policy, we will notify you here, by email, or by means of a notice via our Site, at least ten (10) calendar days before the changes take effect.
Further questions and contacts