z3box PRIVACY POLICY Effective Date: April 27, 2026 This Privacy Policy describes how BSQL Networking ("BSQL Networking," "we," "us," "our") collects, uses, discloses, and safeguards information when you visit our website, create an account, or use our Services (offered under z3box hosting). It applies to information we process as a controller about our customers and website visitors. It does not apply to data you store on the Services as Customer Content, where we act as a processor or service provider on your behalf. 1. INFORMATION WE COLLECT 1.1 Information You Provide - Account information: name, email address, billing address, and account credentials. - Communications: messages you send to support, abuse, or legal contacts. - Service configuration: hostnames, SSH keys, OS choices, and similar technical inputs. 1.2 Information Collected Automatically - Server and connection logs: IP address, user-agent, request timestamps, request paths, and bandwidth usage. - Security and abuse logs: authentication attempts, rate-limit events, and signals associated with abuse detection. IP addresses and similar identifiers may constitute personal data under applicable law. - Cookies: strictly necessary cookies for authentication and session integrity. We do not use tracking cookies, third-party analytics, advertising trackers, or behavioral profiling. 1.3 Information from Third Parties - Payment processor: payments are handled by Stripe under its own privacy policy at https://stripe.com/privacy. We receive only limited transaction metadata (such as confirmation, last four digits of the payment instrument, country of issuance, and a transaction identifier). We do not receive or store full payment card numbers. 1.4 Categories Collected (CCPA/CPRA) For California residents, the categories of personal information we have collected in the past 12 months are: identifiers (name, email, IP address, account ID); customer records (billing address); commercial information (transaction history); internet/network activity (server and connection logs); approximate geolocation (IP-derived only); and inferences drawn for fraud and abuse prevention. We disclose these same categories to service providers (Stripe, infrastructure vendors) for the business purposes described in Section 3. We do not collect sensitive personal information beyond account credentials. 2. CONTROLLER AND PROCESSOR ROLES For account, billing, and server-usage data we collect about you, we are the data controller (or "business" under California law). For Customer Content, you are the controller and we act only as a processor (or "service provider") to the extent we incidentally handle such data in operating the underlying infrastructure. We do not access, monitor, analyze, or use Customer Content for our own purposes. No Data Processing Agreement (DPA) is provided by default; if you require one, contact hello@z3box.net. Provision is at our discretion and may be subject to additional terms. 3. HOW WE USE INFORMATION - To provide, maintain, and support the Services, including provisioning servers and processing payments through Stripe. - To secure the Services, detect and prevent fraud and abuse, and enforce our Terms and AUP. - To communicate with you about your account, transactions, and service-impacting events. - To comply with legal obligations, respond to lawful requests, and protect rights, property, and safety. We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising as those terms are defined under California law. 4. LEGAL BASES (EEA / UK USERS) If you are in the European Economic Area, the United Kingdom, or another jurisdiction with similar laws, we process your personal data on the following legal bases under the GDPR / UK GDPR: - Contract (Art. 6(1)(b)): to provide the Services you requested. - Legitimate interests (Art. 6(1)(f)): to secure our infrastructure, prevent abuse, and operate the business. - Legal obligation (Art. 6(1)(c)): to comply with tax, accounting, and law-enforcement requirements. - Consent (Art. 6(1)(a)): where required, for optional communications. 5. CUSTOMER CONTENT AND ACCESS We respect the confidentiality of Customer Content. As a general practice, we do not examine, access, or use Customer Content. We reserve the right to access it where, in our reasonable judgment, doing so is necessary to: comply with valid legal process or applicable law; investigate, prevent, or respond to suspected fraud, abuse, security incidents, or violations of our Terms; diagnose or remediate a specific technical issue you reported, or address a clear and present threat to our infrastructure or other customers; protect the rights, property, or safety of BSQL Networking, our customers, or others; or act with your explicit consent. The backup service requires client-side encryption and is delivered as a VPS without a public IP, accessible only through a NAT-translated SSH port. We generally do not have access to encrypted contents but retain access to associated metadata (account identifiers, file sizes, timestamps, access logs). We do not hold your encryption keys. If you lose your keys, your data is unrecoverable. Where we are legally compelled to disclose Customer Content, we will, where permitted by law and reasonably practicable, give you notice so you may seek to challenge the request. We are not obligated to challenge legal process on your behalf and may be prohibited from notifying you in cases involving non-disclosure or gag orders. 6. DISCLOSURES OF INFORMATION We disclose information only as described below: - Service providers (processors): Stripe for payment processing, and infrastructure and colocation vendors that process data on our behalf under appropriate confidentiality obligations. - Legal and safety: to comply with subpoenas, court orders, search warrants, or other legal process; to respond to lawful emergency requests under 18 U.S.C. ยง 2702(b)(8)/(c)(4); to NCMEC and law enforcement where required by law; and to protect the rights, property, or safety of BSQL Networking, our users, or the public. - Successors: in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to confidentiality. - With your direction or consent: for any other disclosure you authorize. 7. INTERNATIONAL DATA TRANSFERS We are based in California, USA, and process data in the United States. If you access the Services from outside the U.S., your information will be transferred to and processed in the U.S., which may not provide the same level of data protection as your home jurisdiction. Where required, we rely on appropriate safeguards such as the EU Standard Contractual Clauses and the UK International Data Transfer Addendum. 8. DATA RETENTION - Account email and profile information: while your account is active and up to 12 months after closure for record-keeping and fraud prevention. - Server and connection logs and performance metrics: up to 90 days, except where a longer period is necessary to investigate a specific incident or comply with legal obligations. - Billing and transaction records: as required by tax and accounting laws (typically 7 years). - Support communications: up to 24 months after the matter is resolved. - Backup ciphertext: retained according to your subscription; deleted immediately and permanently on cancellation, suspension, non-payment, or termination. 9. SECURITY AND BREACH NOTIFICATION We use administrative, technical, and physical safeguards designed to protect personal information, including TLS in transit, restricted administrative access, access logging, and host hardening. The backup service additionally requires client-side encryption and is not exposed to the public internet (no public IP; access only via a NAT-translated SSH port). No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for the security of your own credentials, encryption keys, and the data you process on the Services. In the event of a personal data breach affecting your information, we will notify affected users and applicable regulators in accordance with applicable law and without undue delay. 10. YOUR CHOICES AND RIGHTS 10.1 California Residents (CCPA / CPRA) California residents have the following rights, subject to verification and statutory exceptions: - Right to know what personal information we collect, use, and disclose. - Right to access and obtain a copy of your personal information. - Right to correct inaccurate personal information. - Right to request deletion of personal information. - Right to limit the use and disclosure of sensitive personal information. - Right to opt out of sale or sharing for cross-context behavioral advertising. We do not sell or share personal information as those terms are defined by California law. - Right to non-discrimination for exercising any of these rights. To exercise these rights, contact hello@z3box.net. We will verify your request by confirming control of the account email or by other reasonable means. You may use an authorized agent; we will verify the agent's authority and your identity. 10.2 EEA / UK Residents (GDPR / UK GDPR) You have the rights of access, rectification, erasure, restriction, portability, and objection, and the right not to be subject to a decision based solely on automated processing producing legal effects. Where processing is based on consent, you may withdraw consent at any time. You have the right to lodge a complaint with your supervisory authority (e.g., the UK ICO or your local EEA Data Protection Authority). We would appreciate the opportunity to address your concerns first. 10.3 Other U.S. State Privacy Laws Residents of states with comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and others as enacted) may have similar rights of access, deletion, correction, and opt-out of certain processing. Contact hello@z3box.net to exercise these rights. 10.4 Global Privacy Control Our website honors the Global Privacy Control (GPC) signal as an opt-out of "sale" and "sharing" where applicable. Because we do not engage in such activities, the practical effect is informational. 11. CHILDREN'S PRIVACY The Services are not directed to children under 13 (or under 16 in the EEA / UK). We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact hello@z3box.net so we can delete it. 12. THIRD-PARTY SERVICES The Services may interact with third-party services (e.g., Stripe, upstream networks). Their use of information is governed by their own privacy policies, which we encourage you to review. 13. CHANGES TO THIS POLICY We may update this Policy from time to time. We will post the updated version with a new effective date and, for material changes, provide additional notice by email to your account address or by prominent notice on our website. Continued use after the effective date constitutes acknowledgment. 14. CONTACT US BSQL Networking z3box hosting General: hello@z3box.net Abuse: abuse@bsql.net