This Privacy Policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website at www.crafthost.com or our customers or potential customers as a user of our services, or other business partners, or in any other cases where we specifically state that this policy will apply. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organization who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. In this sense, Crafthost SRL of Umberto Giordano Square, 220122 Milan MI, Italy (“Crafthost”, “we”, “us”, “our”) is the data controller. If you have any questions about data protection at Crafthost in general, please contact us.

WHAT IS PERSONAL DATA?

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.

WHAT IS SPECIAL CATEGORY DATA?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing

WHY DO WE HAVE A PRIVACY POLICY?

Italy’s Data Protection Code Legislative Decree no. 101 (“DPC”) and the EU's General Data Protection Regulation (“GDPR”) control how your Personal Data is used by us. We are also required to explain which Personal Data we collect from you via our website and shop, what we use it for, when we delete it, and how your data is protected.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA

All Personal Data that we obtain from you via our website will only be processed for the purposes described in more detail below. This is done within the framework of the DPC and the GDPR and only if at least one of the following applies: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: a) IP address of the requesting computer, b) Date and time of access, c) name and URL of the file accessed, d) website from which the access was made (referrer URL), e) browser used and, if applicable, the operating system of your device as well as the name of your access provider. The legal basis is our legitimate interest.

To provide our website, we use the services of Data Center Park Nuremberg, Germany, Data Center Park Falkenstein, Germany, Data Center Ashburn, Virginia, USA, Data Center Hillsboro, Oregon, USA, who process the below-mentioned data and all data to be processed in connection with the operation of our website on our behalf. The legal basis is our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of contractual services.

For the processing of personal data using cookies and similar technologies on our website, please refer to our Cookie Policy. The legal basis for the use of cookies is our legitimate interest or your consent when you agree to the use of technically non-essential cookies as further explained in our Cookie Policy.

As set out in the DPC and the EU's Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of technically nonessential cookies. For this purpose we use a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via our cookie consent tool: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; e) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.

For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use Google Analytics. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.

We also use Google`s reCAPTCHA to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for using reCAPTCHA is our legitimate interest.

We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection and the message itself. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service and your consent.

As part of the registration process, users provide their name, e-mail, phone number, business details and contact information, and password. The data provided will be used for the purposes of creating and using the account and providing and/or using our services. In the context of the use of our log in and sign-up functions, as well as the use of the user account, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as consent.

We process the Personal Data that arises when you enter into a contract with us in order to provide our contractual services. In this regard, we typically process your contract and contact information as well as other data relevant to the fulfilment of our obligations. This in particular includes our support, correspondence with you, invoicing, fulfilment of our contractual obligations, accounting, and tax obligations. Accordingly, the data is processed on the basis of the fulfilment of our contractual obligations and our legal obligations.

For optimal customer support, we use first name, last name, e-mail address, and the data related to your contact or contract with us. Your data will be stored on our website and/or our customer relationship management system. This data processing is based on our legitimate interest in providing our service.

If you wish to use our hosting services, managed hosting services, domain services, or auxiliary services, we process the data you provide, which typically includes Personal Data, Special Category Data and non-personal data (“Service Data”). We recognize that you own your Service Data and provide you with complete control over your Service Data by providing you the ability to a) access your Service Data, b) share your Service Data, and c) request export or deletion of your Service Data.

When we process Service Data, we become your Data Processor or in other words, we will process the Service Data involved in your use of our services in accordance with your instructions and shall use it only for the purpose of providing you our services.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly. The legal basis for the processing of your Service Data is our obligation to fulfill the contract we have with you.

Please note: Some jurisdictions may require you to disclose your use of our services and us as your processor in your privacy policy and/or data processing agreement as applicable. For this purpose all Service Data processed by us will be processed using the servers of Data Center Park Nuremberg, Germany, Data Center Park Falkenstein, Germany, Data Center Ashburn, Virginia, USA, Data Center Hillsboro, Oregon, USA and take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of your Service Data. For further information, please refer to our Data Processing Addendum.

If you make a purchase your payment data will be processed via our payment service provider, Stripe. Payment data will solely be processed through Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

We process data in the context of administrative tasks as well as the organization of our business and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

If you create a support ticket, we will request Personal Data and, where applicable, non-Personal Data in accordance with your request; this may include your name, email address, and other service-related data you voluntarily provide. The data provided is not shared with third parties and cannot read your data when it is entered. If you submit a support ticket, we process the data for the purpose of processing and handling your ticket.

Our employees will also have access to data that you knowingly share with us for technical support or to import data into our services. We communicate our privacy and security guidelines to our employees and enforce privacy safeguards strictly. The legal basis of the data processing is our obligation to fulfil the contract and/or our legitimate interest in processing your support ticket.

If you apply for a role or job, we process the information we receive from you as part of the application process, e.g., through your letter of application, CV, references, correspondence, telephone, or verbal details. In addition to your contact details, information about your education, qualifications, work experience, and skills is particularly relevant to us. Your data will initially be processed solely for the purpose of carrying out the application process. If your application is successful, it will become part of your personnel file and will be used to carry out and terminate your employment and will be deleted in accordance with the rules applicable to personnel files. If we are unable to offer you employment, we will continue to process your data for up to six months after sending the rejection in order to defend ourselves against any legal claims, in particular alleged discrimination in the application process. The legal basis for processing data during the application process is the initiation of a contract and your consent.

Within our website, we may also display certain Personal Data, share certain details, knowledge, and insights in the form of testimonials. When you approve and submit your testimonial to us your consent is obtained, and you have choices about the information in your testimonial. The storage of testimonials is based on your consent.

We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers via email. In addition, we reserve the right to use your first and last name as well as your postal address for our own advertising purposes, e.g., to send you interesting offers and information about our products by post. This serves to protect our legitimate interests.

If you register for our newsletter, we use your email address to send you our email newsletter on a regular basis on the basis of your consent. Unsubscribing from the newsletter is possible at any time and can be done via the unsubscribe link provided in each newsletter. After unsubscribing, we will delete your email address unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.

OTHER USES OF YOUR PERSONAL DATA?

We may also collect, store, and use your Personal Data for the following purposes:

We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances, we may also be required by law to disclose or otherwise process your Personal Data.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

DATA SHARING

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

If necessary, we transfer your Personal Data within Crafthost. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to provide our products or services or to contact you in case of queries.

Personal Data is transferred to our service providers in the following instances:

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements, including non-disclosure agreements, data processing agreements, and standard contractual clauses regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

SOCIAL MEDIA

We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media website are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Information collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Information from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

MARKETING

Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing message sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance where:

Sometimes, however there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

HOW WE SECURE YOUR PERSONAL DATA

We take appropriate organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we collect and process. However, no method of collection, storage, or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions.

LINKED SITES

For your convenience, there may be hyperlinks on our website that link to other websites. We are not responsible for, and this Privacy Policy does not apply to the privacy practices of any linked websites or of any companies that we do not own or control. The website links may collect information in addition to the information we collect.

We do not endorse any of these linked websites, their products, services, or any of the content on their websites. We encourage you to seek and read the Privacy Policy of each linked website that you visit to understand how the information that is collected about you is used and protected

YOUR RIGHTS AND PRIVILEGES

• a) Privacy rights

  You can exercise the following rights:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to data portability;
• b) Updating your information and withdrawing your consent

  If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

• c) Access Request

  In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

• d) Complaint to a supervisory authority

  You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Italy is the Italian Data Protection Authority, Garante per la protezione dei dati personal, Piazza Venezia 11, 00187 Rome, (www.garanteprivacy.it). However, we would appreciate the opportunity to address your concerns before you contact the Garante per la protezione dei dati personal or any other supervisory authority.

• e) What we do not do
  • We do not request Personal Data from minors and children;
  • We do not process special category data without obtaining prior specific consent;
  • We do not use automated decision-making including profiling; and
  • We do not sell your Personal Data.

USA SPECIFIC PROVISIONS

The following applies to users located in the United States. While we understand and appreciate that privacy and consumer data protection laws differ as they are subject to each state's legislature and that no data protection framework similar to the EU’s GDPR exists on a federal level, we are committed to follow and apply the relevant privacy rules and regulations for your state.

As of the day of drafting, the following states had enacted privacy and consumer data protection laws: California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia. Under consideration of the similarities of the above provisions, no conflict should arise pursuing a uniform approach in granting all users in the USA the same rights and privileges as set out above. However, should ambiguity occur, the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your Personal Data.

Further, the following also apply

• 
  I) “Shine the Light”

  “Shine the Light” law (Civil Code Section 1798.83) requires us to respond to requests from California asking about the business’s practices related to disclosing Personal Data to third parties for the third parties’ direct marketing purposes. You may make a request about our collection and disclosure of your Personal Data using the contact details provided.

• 
  II) COPPA (Children Online Privacy Protection Act)

  When it comes to the collection of Personal Data from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.

• 
  III) CAN SPAM Act

  The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.

• 
  IV) Telephone Consumer Protection Act (TCPA)

  If we process your Personal Data for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalized direct advertising per SMS.

• 
  V) Controls For Do-Not-Track Features

  Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.

• 
  VI) Right to complain

  Finally, in regard to the right to complain to a supervisory authority. You have the right to lodge a complaint about our processing of Personal Data with a supervisory authority responsible for data protection. Users based in the above-mentioned States may lodge a complaint with the relevant district attorney or attorney general office. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.

CANADA AND MEXICO SPECIFIC PROVISIONS

Both Canada and Mexico have introduced data protection laws that are similar to the GDPR, namely Federal Law for the Protection of Personal Data in the Possession of Private Parties (“LFPDPPP”) supplemented by the Rules of the Federal Law for the Protection of Personal Data in the Possession of Private Parties in Mexico and the Personal Information Protection and Electronic Documents Act (“PIPEDA”) in Canada. Under consideration that the GDPR has played a pivotal role, no conflict should arise pursuing a uniform approach in granting all users in Mexico or Canada the same rights and privileges as set out above. However, should ambiguity occur, the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your personal data.

In terms of your right to complain, Canada’s national supervisory authority is the Office of the Privacy Commissioner ( www.priv.gc.ca) and the National Institute of Transparency, Access to Information and Personal Data Protection (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales) (“INAI”) is the national supervisory authority in Mexico ( www.ifai.org.mx).

HELP AND COMPLAINTS

If you have any questions about this policy or about data protection at Crafthost in general, please contact us.

CHANGES

The first version of this policy was issued on Sunday, 26 January, 2025, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.