- We are committed to safeguarding the privacy of service users,
individual customers and customer personnel.
- This policy applies where we are acting as a data controller with
respect to the personal data of such persons; in other words, where we determine the purposes
and means of the processing of that personal data.
- In this policy, "we", "us" and "our" refer to subZero Cloud S.R.L. For
more information about us, see Section 10.
- This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
- You must retain the above credit. Use of this document without
the credit is an infringement of copyright. However, you can purchase from us an equivalent
document that does not include the credit.
The personal data that we collect
- In this Section 3 we have set out the general categories of personal
data that we process and, in the case of personal data that we did not obtain directly from you,
information about the source and specific categories of that data.
- We may process data enabling us to get in touch with you
("contact data"). The contact data may include your name, email address, telephone
number, postal address and/or social media account identifiers. The source of the contact data
is you and/or your employer.
- We may process your service user account data ("account
data"). The account data may include your account identifier, name, email address,
business name, account creation and modification dates. The primary source of the account data
is you and/or your employer, although some elements of the account data may be generated by our
- We may process information relating to transactions, including
purchases of goods and/or services, that you enter into with us and/or through our website
("transaction data"). The transaction data may include your name, your contact
details and the transaction details. The source of the transaction data is you and/or our
payment services provider.
- We may process data about your use of our website and services
("usage data"). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency and pattern of your
service use. The source of the usage data is our analytics tracking system.
Purposes of processing and legal bases
- In this Section 4, we have set out the purposes for which we may
process personal data and the legal bases of the processing.
- Operations - We may process your personal data for
the purposes of the processing and fulfilment of orders, providing our services, supplying our
goods, generating invoices, bills and other payment-related documentation, and credit control.
The legal basis for this processing is our legitimate interests, namely the proper
administration of our website, services and business.
- Relationships and communications - We may process
contact data, account data, transaction data and/or communication data for the purposes of
managing our relationships, communicating with you (excluding communicating for the purposes of
direct marketing) by email, SMS, post, fax and/or telephone, providing support services and
complaint handling. The legal basis for this processing is our legitimate interests, namely
communications with our website visitors, service users, individual customers and customer
personnel, the maintenance of relationships, and the proper administration of our website,
services and business.
- Record keeping - We may process your personal data
for the purposes of creating and maintaining our databases, back-up copies of our databases and
our business records generally. The legal basis for this processing is our legitimate interests,
namely ensuring that we have access to all the information we need to properly and efficiently
run our business in accordance with this policy.
- Security - We may process your personal data for the
purposes of security and the prevention of fraud and other criminal activity. The legal basis of
this processing is our legitimate interests, namely the protection of our website, services and
business, and the protection of others.
- Legal claims - We may process your personal data
where necessary for the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis for this
processing is our legitimate interests, namely the protection and assertion of our legal rights,
your legal rights and the legal rights of others.
- Legal compliance and vital interests - We may also
process your personal data where such processing is necessary for compliance with a legal
obligation to which we are subject or in order to protect your vital interests or the vital
interests of another natural person.
Providing your personal data to others
- Your personal data held in our website database will be stored on the
servers of our hosting services providers.
- Financial transactions relating to our website and services are
handled by our payment services providers, Braintree. We will share transaction data with our
payment services providers only to the extent necessary for the purposes of processing your
payments, refunding such payments and dealing with complaints and queries relating to such
payments and refunds. You can find information about the payment services providers' privacy
policies and practices at https://www.braintreepayments.com/.
- In addition to the specific disclosures of personal data set out in
this Section 5, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person. We may also disclose your personal
data where such disclosure is necessary for the establishment, exercise, or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court procedure.
- In this Section 6, we have listed the rights that you have under data
- Your principal rights under data protection law are:
- the right to access - you can ask for copies of your personal data;
- the right to rectification - you can ask us to rectify inaccurate
personal data and to complete incomplete personal data;
- the right to erasure - you can ask us to erase your personal data;
- the right to restrict processing - you can ask us to restrict the
processing of your personal data;
- the right to object to processing - you can object to the processing of
your personal data;
- the right to data portability - you can ask that we transfer your
personal data to another organisation or to you;
- the right to complain to a supervisory authority - you can complain
about our processing of your personal data; and
- the right to withdraw consent - to the extent that the legal basis of
our processing of your personal data is consent, you can withdraw that consent.
- These rights are subject to certain limitations and exceptions. You
can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
- You may exercise any of your rights in relation to your personal data
by written notice to us, using the contact details set out below.
- A cookie is a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a page from the
- Cookies may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until its set expiry
date, unless deleted by the user before the expiry date; a session cookie, on the other hand,
will expire at the end of the user session, when the web browser is closed.
- Cookies may not contain any information that personally identifies a
user, but personal data that we store about you may be linked to the information stored in and
obtained from cookies.
Cookies that we use
visit our website and as you navigate our website, and to help us determine if you are
logged into our website; and
of our website and services.
- We may update this policy from time to time by publishing a new
version on our website.
- You should check this page occasionally to ensure you are happy with
any changes to this policy.
- We may notify you of significant changes to this policy by email.
- This website is owned and operated by subZero Cloud S.R.L.
- We are registered in Romania under registration number 37521270, and
our registered office is at str. Vasile Alecsandri nr. 1410072 Oradea, jud. BihorRomania, EU.
- Our principal place of business is at str. Vasile Alecsandri nr.
1410072 Oradea, jud. BihorRomania, EU.
- You can contact us:
- by post, to the postal address given above;
- by telephone, on the contact number published on our website; or
- by email, using the email address published on our website.