Privacy Policy

Responsible for the data protection laws, in particular for the EU General Data Protection Regulation (GDPR), is:

Spiral Hosting Limited
71 Baggot Street Lower
Dublin, D02 P593, Ireland

Company 513696, EU VAT number IE3586480SH

Telephone: +353.16917108

1. Your data subjects’ rights

Under the contact details provided, you can exert the following rights at any time:

Information about your stored data and their processing,
Correction of incorrect personal data,
Deletion of your data stored with us,
Restriction of data processing, if we are not yet allowed to delete your data due to legal obligations,
Objection to the processing of your data with us and
Data portability, if you have consented to the data processing or have concluded a contract with us.

If you have given us your consent, you can withdraw it at any time with effect for the future.

You can always submit a complaint to the supervisory authority responsible for you. Your competent supervisory authority depends on the state of your domicile, work or alleged violation. A list of the non-public-sector supervisory authorities can be found at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

2. Purposes of data processing by the responsible body and third parties

We process your personal data only for the purposes stated in this privacy policy. A transfer of your personal data to third parties for purposes other than those mentioned does not take place. We only share your personal information with third parties if:

You have given your express consent,
the processing is required to complete a contract with you,
the processing is necessary to fulfill a legal obligation,
processing is necessary to protect legitimate interests and there is no reason to believe that you have an overriding legitimate interest in not disclosing your information.

3. Deletion or blocking of data

We adhere to the principles of data avoidance and data economy. Therefore, we only store your personal data for as long as is necessary to achieve the purposes mentioned here or as provided for by the various storage periods provided for by law. After discontinuation of the respective purpose or expiration of these deadlines, the corresponding data will be routinely and in accordance with the legal regulations blocked or deleted.

4. Collecting general information when visiting our website

When you access our website, a cookie automatically records information of general nature. This information (server log files) includes, for example, the type of web browser, the operating system used, the domain name of your Internet service provider and similar information. This is only information that does not allow conclusions about your person.

This information is technically necessary to correctly deliver the contents of web pages requested by you and is mandatory when using the internet. They are processed in particular for the following purposes:

Ensuring a hassle-free connection to the website,
Ensuring a smooth use of our website,
Evaluation of system security and stability as well as
for further administrative purposes.

The processing of your personal data is based on our legitimate interest for the aforementioned purposes of data collection. We do not use your information to draw conclusions about you. The recipient of the data is only the responsible body and, if necessary, the processor.

Anonymous information of this kind may be statistically evaluated by us to optimize our website and the underlying technology.

5. Cookies

Like many other websites, we also use so-called “cookies”. Cookies are small text files that are transferred from a website server to your hard drive. This automatically gives us certain data, such as IP address, browser used, operating system and your connection to the Internet.

The validity and expiration periods of cookies and other similar trackers may vary. Some of them expire upon termination of the browsing session, others expire after up to 1 year.

Cookies cannot be used to launch programs or to transfer viruses to a computer. Based on the information contained in cookies, we can facilitate navigation and enable the correct presentation of our websites.

In no case will the data collected by us be passed on to third parties, neither will a link to personal data be established without your consent.

Of course, you can also view our website without cookies. Internet browsers are regularly set to accept cookies. In general, you can disable the use of cookies at any time through the settings of your browser. Please use the help features of your internet browser to find out how to change these settings. Please note that some features of our website may not work if you have disabled the use of cookies.

6. Registration on our website

When registering for the use of our personalized services, some personal information will be collected, such as name, address, contact and communication information, such as telephone number and e-mail address. If you are registered with us, you can access content and services that we offer only to registered users. Registered users also have the option of changing or deleting the data specified during registration at any time. Of course, we also provide you with information about the personal data we hold about you at any time. We are happy to rectify or delete these at your request, as far as no statutory storage requirements preclude. To contact us in this context, please use the contact details given at the end of this Privacy Policy.

7. Provision of paid services

To provide paid services we ask for additional data, such as payment details to complete your order. We store this data in our systems until the legal retention periods have expired.

When paying by credit card, Apple Pay, SOFORT, GiroPay or direct debit, payments are processed through Stripe by the payment processor Stripe Payments Europe Ltd, Block 4, Harcourt Center, Harcourt Road, Dublin 2, Ireland. For more information about Stripe’s privacy policy, please visit https://stripe.com/privacy

When paying by direct debit, payments are processed through GoCardless by the payment processor GoCardless GmbH, Herzogspitalstr. 24, München, 80331, Deutschland. For more information about GoCardless’ privacy policy, please visit https://gocardless.com/privacy/

When paying by PayPal, payments are processed through PayPal by the payment processor PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. For more information about PayPal’s privacy policy, please visit https://www.paypal.com/en/webapps/mpp/ua/privacy-full

8. SSL and TLS encryption

To protect the security of your data during transmission, we use state-of-the-art encryption techniques (such as SSL and/or TLS) over HTTPS.

9. Comment feature

When users leave comments on our site, besides the comment, the time of its creation, full name and email address will also be saved. This information is saved for our security, as we may be prosecuted for any illegal content on our website, even if created by other users.

10. Newsletter

On the basis of your expressly given consent, we will regularly send you our newsletter or comparable information by e-mail to your specified e-mail address.

For the receipt of the newsletter, the provision of your email address is sufficient. When you sign up to receive our newsletter, the data you provide will be used exclusively for this purpose. Subscribers may also be notified by e-mail about circumstances relevant to the service or registration (such as changes to the newsletter offer or technical conditions).

For an effective registration, we require a valid e-mail address. To verify that a subscription is actually made by the owner of the e-mail address, we use the “Double opt-in” procedure. For this purpose, we record the order of the newsletter, the dispatch of a confirmation mail and the receipt of the requested answer. Further data is not collected. The data will be used exclusively for the newsletter and will not be passed on to third parties.

The consent for the storage of your personal data and its use for the newsletter can be revoked at any time. Each newsletter has a respective link to it. In addition, you can unsubscribe through this website at any time or inform us of your request via the contact option indicated at the end of this Privacy Notice.

11. Contact form

If you contact us by e-mail, through our contact form or helpdesk regarding any questions you may have, you give us your consent for the purpose of establishing contact. This requires the specification of a valid e-mail address. This serves for the assignment of the request and the subsequent answering of the request. The specification of further data is optional. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions. After completing the request, personal data will be automatically deleted.

12. Use of script libraries (Google Webfonts)

In order to render our content correctly and graphically appealing across browsers, we use script libraries and font libraries on this website, such as: Google Webfonts (https://www.google.com/webfonts/). Google web fonts are transferred to the cache of your browser to prevent multiple loading. If the browser does not support Google Web fonts or prohibits access, content will be displayed in a standard font.

The request of script libraries or font libraries automatically triggers a connection to the operator of the library. It is theoretically possible – but currently also unclear whether if and for what purposes – that operators of such libraries collect data.

The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy/

13. Use of Google Maps

This website uses Google Maps API to visually display geographic information. When using Google Maps, Google also collects, processes and uses data about the use of map features by visitors. For more information about Google’s data processing, please refer to the Google Privacy Notice. There you can also change your personal privacy settings in the privacy center.

Detailed instructions on how to manage your own data related to Google products can be found here.

14. Use of Google reCAPTCHA

We use Google reCAPTCHA on our websites. Provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

Google reCAPTCHA is designed to verify if data entry on our websites (for example, in a contact form) is done by a human or by an automated program. For this, Google reCAPTCHA analyzes the behavior of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For analysis, Google reCAPTCHA evaluates various information (for example, the IP address, website visitor’s time spent on the website or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.

The Google reCAPTCHA analyzes are done completely in the background. Site visitors are not advised that an analysis is taking place.

The data processing is based on Art. 6 para. 1 lit. f of the EU GDPR. The web site operator has a legitimate interest in protecting its web sites from abusive automated spying and SPAM.

For more information about Google reCAPTCHA and Google’s privacy policy, please visit the following links: https://policies.google.com/privacy and https://www.google.com/recaptcha/intro/android.html.

15. Embedded YouTube videos

On some of our websites we embed YouTube videos. The corresponding plug-ins are operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit a page with the YouTube plug-in, it will connect to YouTube’s servers. YouTube will be informed which pages you visit. If you are logged into your YouTube account, YouTube can assign your surfing behavior to you personally. This can be prevented by logging out of your YouTube account beforehand.

If a YouTube video is started, the provider uses cookies that collect information about user behavior.

Anyone who has disabled the storage of cookies for the Google Ad program will not have to expect such cookies when watching YouTube videos. YouTube also stores non-personal usage information in other cookies. If you want to prevent this, you must block the storage of cookies in the browser.

Further information on data protection at “YouTube” can be found in the provider’s privacy policy at: https://policies.google.com/privacy

16. Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website, in order to contact and be contacted by this Website‘s support service.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

16.1. Tidio Chat

The Tidio Live Chat widget is a service for interacting with the Tidio live chat platform provided by Tidio LLC, Tidio Ltd or by Tidio Poland Sp. z o.o., depending on the location this Website is accessed from.

Personal Data processed: Data communicated while using the service, Tracker and Usage Data.

Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; Poland – Privacy Policy.

17. Use of Pingdom

On this website, data about your use of the website, including your IP address, are collected by the web analytics service Pingdom Real User Monitoring (RUM) Tool and stored on the Pingdom servers in the USA. After geolocating your IP address, the IP address will be deleted. In order to enable recognition when visiting our website again, cookies (small text files) can be used that are stored locally on the site visitor’s computer. Using the collected data, usage profiles are created using pseudonyms. This information is used to analyze visitor behavior (e.g., mouse movements, scrolling, clicks, activities with form fields, etc.) and will be evaluated to improve the experience of our website.

This information may be transferred to third parties if required by law or as far as third parties process this data on behalf of Pingdom.

By using this site, you consent to the processing of the data collected through the Pingdom Real User Monitoring (RUM) Tool in the described manner and for the purposes mentioned above. For more information about the Pingdom Real User Monitoring (RUM) Tool data collection, please visit the following link: https://documentation.solarwinds.com/en/success_center/pingdom/content/topics/data-stored-in-rum-real-user-monitoring-.htm.

You can disable the Pingdom Real User Monitoring (RUM) Tool tracking at any time by updating your consent preferences for tracking technologies and disabling the “Measurement” category. These preferences can be found in the bottom left corner on every page on the current site.

18. Use of MaxMind

Our website uses the API of maxmind.com operated by MaxMind Inc. Operator is MaxMind Inc., 14 Spring Street, 3rd Floor, Waltham, MA 02451, USA.

As part of real-time fraud detection, we use the minFraud service. With the minFraud service we get statistical analyzes with regard to IP address, devices and location. No personal data will be stored or passed on to third parties. For more information about how user information is handled, please refer to the MaxMind Inc. Privacy Policy at: https://www.maxmind.com/en/privacy_policy.

19. Use of Validation.com

Our website uses the KYC and Identity Verification of validation.com operated by Validation.com Inc. Operator is Validation.com Inc., 4600 East Washington Street, Suite 305, Phoenix, AZ 85034, USA.

Validation.com provides a secure environment to upload and review personal information related to our customers. We use this service to verify the identity of our clients. The Validation.com platform and related services are built so that only we have access to the client information that has been uploaded. Validation.com does not have the ability to access, download or review this information.

The verification process is initiated by sending a link directly to the client. This link provides access to a tool that will request information that verifies a client’s identity. Information requested may include images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws, photos of you, and/or other authentication information.

Validation.com uses, stores, and processes information, including personal information about our clients, as described above, to provide identity verification and fraud detection services to us. The scope of the verification process is to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity or conduct security investigations and risk assessments.

All submitted information is used solely for the scope of identity verification. All related information shall be purged from Validation.com as soon as the verification is completed, but no later than 90 days.

The provision and upload of any personal information as part of this verification process is voluntary. You have the right to refuse completing the verification process. However, we may be unable to fulfill orders and services for unauthenticated orders and identities.

For more information about how client information is handled, please refer to the Validation.com Inc. Privacy Policy at: https://validation.com/privacy-policy/.

20. Use of Matomo

If you have given your consent, Matomo (formerly Piwik), an open source software for statistical analysis of visitor access, is used on this website. The provider of the Matomo software is InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand.

Matomo places a cookie (a text file) on your end device with which your browser can be recognized. If subpages of our website are called up, the following information is saved:

the user’s IP address, shortened by the last two bytes (anonymized)
the subpage accessed and the time of access
the page from which the user came to our website (referrer)
which browser is used with which plugins, which operating system and which screen resolution
the length of time spent on the website
the pages that are accessed from the accessed subpage

Matomo is used for the purpose of improving the quality of our website and its content. This tells us how the website is being used and enables us to continuously optimize our offer.

By anonymizing the IP address by six digits, we take the website visitor’s interest in the protection of personal data into account. The data is not used to personally identify the user of the website and is not merged with other data. The information generated by the cookie about your use of this website will not be passed on to third parties.

Revocation of consent:

You can revoke your consent to the storage and evaluation of your data by Matomo at any time using the button below. A so-called opt-out cookie is then stored on your device, which is valid for two years. As a result, Matomo does not collect any session data. Please note, however, that the opt-out cookie will be deleted if you delete all cookies.

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

You can also prevent the use of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.

21. Third-Party Service Providers

We may at times provide information about you to third party service providers to provide various services on our behalf, such as processing payments or providing complementary services (e.g. domain registration, hosting add-ons). We will only share your information when necessary for the third party to provide the required service. These third-party service providers are prohibited from sharing or storing your personal identifiable information for any purposes unrelated to providing the respective service.

22. Change of our privacy policy

We reserve the right to amend this privacy policy to always comply with the latest legal requirements or to implement changes to our services in the privacy policy, e.g. when introducing new services. Your new visit will be subject to the new privacy policy.

23. Identity of the controller

If you have any questions about our data protection or privacy protection, please contact us.

Responsible in terms of data protection and privacy protection: