This privacy policy (hereinafter referred to as “Policy”) regulates how ISPmanager LTD (hereinafter referred to as “ISPmanager”) processes personal data and describes the rights granted to you as a user in regard to such processing.

AREA OF VALIDITY

The given Policy applies to (collectively referred to as “ISPmanager Services”):

software products which exclusive rights belong to ISPmanager, with their copies available for download and installation, as well as SaaS software products used online through interactive interaction with their functional part (hereinafter referred to as "Software products");the secured user account at https://ISPmanager.com (hereinafter referred to as “Account area”);
ISPmanager websites and their subdomains (hereinafter referred to as “Websites”);
any related services and certificates, such as SSL certificates, webinars, conferences, or contests (hereinafter referred to as “Related services”);
requests to technical support, other departments, or via online chat (hereinafter referred to as “Requests”).

If you refuse to accept this Policy, please do not use ISPmanager Services.

This Privacy policy does not apply to:

third party services, platforms, social media, or services that can be available through ISPmanager Services or integrated with them (hereinafter referred to as “Third party services”). For instance, during the payment process you can be redirected to a specific payment service website. You can leave comments on Websites through the integrated comments service. In such cases, data processing will be out of ISPmanager control. Such Third party services are independent controllers acting upon their own privacy policies,
third party companies using ISPmanager Software products e.g. for web hosting. In this case, your personal data will be processed directly by your web hosting provider.

Certain rules clarifying statements of this Policy can be included in other regulations, agreements, and rules which define terms and conditions of ISPmanager Services. Please read these documents carefully and agree with them to continue.

COLLECTED INFORMATION

ISPmanager can process personal and other information (including anonymized information) which is not directly considered as personal data. It can be technical device specifications, connection data, error logs, or interface interaction methods (hereinafter referred to as “Supplementary data”).

ISPmanager receives information from the following sources:

Personal data provided by users.
The user provides this information by signing up on Websites, sending Requests, purchasing Software products, and using Account area and Related services. ISPmanager uses this data to deliver its obligations, provide transactions, meet tax obligations, and protect itself against complaints and suits. This data may include family name, first name, email, address, billing details, and phone number. Depending on the scope of obligations, other personal information might be also requested. ISPmanager does not collect or store any bank card information.
ISPmanager has the right to use the single authorization center mechanism where an individual user account is valid for all or specific ISPmanager services.
ISPmanager is eligible to use a single-point authorization system to provide access to all or specific ISPmanager Services with the unified User login data.
Supplementary data processed while using Software products, Websites, Account area, and Related services:
Log data (log information). Our servers automatically save technical information about access to them. This takes place when you open Websites, receive Software product, use your Account area or Related services. Log data can contain information about IP address, browser specifications, date, time, activities duration and their sequence.
Usage data. ISPmanager collects information about how you use ISPmanager Services to make them better. Such information may include device type, operating system version, error logs, and quantity usage parameters. Specific data to be collected is determined by the type of ISPmanager Service.
IP addresses of servers where Software products are installed and their license IDs. In effort to protect products from unauthorized copying, the factual IP address and license ID verification are established to check whether the address matches the one specified during agreement signing in your Account area.
Cookie files. ISPmanager uses cookie and other identical technologies to collect information. Further details can be found in the Cookie policy section.
Data provided to ISPmanager by third parties. In most cases, you have the right to grant, deny, or limit revelation of information by a third party. For instance, you can sign in on Websites via social media. In this case, you allow the social media to provide your email address or other information to ISPmanager. ISPmanager is not able to receive any information by itself, unless you have allowed it in your social media settings.

ISPmanager does not process data of specific types such as: biometric data, information about political or religious beliefs, previous convictions, health condition, or other similar information.

ISPmanager strongly recommends you to not specify your personal data on forums or other public sections of Websites. ISPmanager does not moderate the entered data and is not liable for public data revelation.

HOW ISPMANAGER USES PERSONAL DATA

ISPmanager uses personal data strictly in accordance with the applicable law and goals of data collection.

ISPmanager operates the following principles when processing personal data:

Personal data is processed on legal and reasonable grounds;
Personal data processing is limited by specific predetermined legal goals. Contents and volume of data to be processed shall not be excessive. Data processing incompatible with the goals of data collection shall not be permitted;
Databases with personal data to be processed for goals inconsistent with each other shall not be consolidated;
It is only allowed to process personal data that meets the goals of data collection;
During personal data processing, this data shall be kept accurate, sufficient, and actual in relation to the goals of personal data collection. Inaccurate or insufficient data shall be deleted or elaborated where it is required;
Personal data shall be stored not longer than it is required by the goals of personal data collection;
Data shall be secured against nonauthorized or illegal processing, unintentional loss, damage, and elimination.

ISPmanager uses personal data for the following goals:

Execution of reciprocal liabilities of ISPmanager and user, based on agreements and conditions of ISPmanager Service provisioning.
Meeting law requirements e.g. tax laws.
Establishment and control of payments, account management and its administration.
Protection against copyright violations, fraud, or other inequitable conduct.
Improvement, support, and modernization of ISPmanager Services. Such processes are required to avoid and eliminate errors, provide security, fix technical issues, analyze and monitor usage.
Interaction with the user e.g. to reply to requests and contact the user directly to discuss installation, settings, and purchasing of ISPmanager Services. For this purpose, we use data provided by the user during ordering of ISPmanager Services and data from open sources.
Email sendouts and other communication channels. ISPmanager can send different types of messages, including email, SMS, and Messages in Account area. System messages are required for ISPmanager to perform its obligations towards users in due time. Such messages shall be used to guarantee proper performance of ISPmanager Services. It can be messages about service status, payments, password changes, and other similar matters. Marketing and advertising messages shall be sent only in cases when the user has expressed evident consent to receive such messages. You can always set up settings for receiving such messages in your Account area.
Establishment of researches with the usage of anonymized data.

If data is processed for the purposes specified in para. 1-8, with the exceptions for marketing and advertising messages, ISPmanager proceeds from the presence of the relevant legitimate interest.

DATA STORAGE

ISPmanager stores data within the time period required to meet the goals of data collection.

Regardless a request from the user to delete information, ISPmanager has the right to store information if it is required to protect legitimate business interest, meet its obligations, and settle disputes.

Once the goals of data processing have been accomplished, there is no further need of accomplishing such goals, or in case of receiving relevant requirements this data shall be eliminated or depersonalized.

ISPmanager has the right to store data despite the requirement to delete it if this data is required for specific legal business interests, to enforce obligations, or dispute resolutions.

INFORMATION DISCLOSURE

ISPmanager discloses information to the third parties only when it is regulated by the given Policy or applicable law, to the extent needed to accomplish the goals of information disclosure.

Information disclosure is allowed in the following cases:

for providers of additional services as referenced by ISPmanager. It can be services for email sending, Website activity monitoring, subcontractors, or licensors. Such providers shall use personal data only in accordance with ISPmanager guidelines for the purposes specified in the given Policy. Additional information about limits of disclosure and persons whose data can be disclosed is described in the section “Processors”.
if specific notice has been received from the user. Such notice can be an addition of a new trusted subject in Account area by the User and granting to it access to the corresponding information.
to meet the requirements of the applicable law. Data can be disclosed only upon receiving of request from the competent body.
for affiliated persons of ISPmanager for the purposes of executing obligations towards the user. Such affiliated persons are described in the section “Processors”.
to prevent illegal activities, secure rights, guarantee security of ISPmanager and other parties, and protect against disputes and suits.
to transfer information during ISPmanager reorganization, as well as during execution of user contracts. In such cases, ISPmanager keeps the right to disclose information to the third party which acquires the rights according to the contract, or to the party which will be established in consequence of such reorganization.
if general, aggregated, or impersonalized data is used. ISPmanager has the right to disclose impersonalized statistical data e.g. about the most used functions of Software products.
in other cases when user consent has been received.

SECURITY

ISPmanager utilizes solid technical and organizational measures to secure data. ISPmanager can:

assign a person responsible for organization of personal data processing;
establish local documents describing processing of personal data. These documents regulate procedures allowing to avoid or identify violations and eliminate consequences of such violations;
apply any legal, organizational, and technical measures to provide security of personal data during its processing;
organize periodic checking of terms regulating processing of personal data;
introduce employees directly involved in processing of personal data to terms of laws regulating personal data, including specific requirements to personal data protection, documents, or any other internal documents covering processing of personal data.

ISPmanager cannot guarantee that information will be closed fully against intrusions during its transfer through Internet or its storage. ISPmanager uses pseudonimization and data encryption where conditions allow.

AGE LIMIT

ISPmanager shall not process intentionally any personal data of individuals who have not reached 16 years of age.

If you believe that ISPmanager might have received personal data from a person who is not of the age allowing to provide independent consent to data processing, please let us know about such case by using one of the methods listed in the section “DEFINITION OF DATA CONTROLLER. CONTACT INFORMATION”.

POLICY REVISIONS

ISPmanager has the right to revise the current Policy in accordance with the changes in legislation or business processes. All such revisions shall be published on ISPmanager Website. If such revision affects user rights directly or indirectly, ISPmanager shall send notifications to users via email and/or Account area and Software products.

DATA TRANSFER

ISPmanager can transfer data to processors located outside ISPmanager location and specified in the correspondent section. Such Processors shall provide decent data protection not lower than established by the given Policy.

DEFINITION OF DATA CONTROLLER. CONTACT INFORMATION

Controller (operator) of data is ISPmanager LTD, Registration number HE432447, Tepeleniou, 13, Tepelenio Court, 2nd floor, 8010, Paphos, Cyprus.

Any questions related to data processing can be sent to privacy@ISPmanager.com or to ISPmanager address in a written form.

ISPmanager shall strive to review such incoming letters as swiftly as possible but not longer than within one month.

RIGHTS OF DATA SUBJECT

User rights shall be observed in compliance with the Applicable law and the recognized norms of international law.

The user has the right to:

call back its consent to personal data processing, if such processing is based on the consent. E.g. you can always unsubscribe from advertising or marketing emails in your Account area.
receive information about personal data processing. ISPmanager supports its current policy in the actual state, thus providing you with correct information about data collected, goals of its collection, and other processing aspects.
receive access to information, its updates, alterations, and specifications. In most cases, you can manage status of your information in your Account area.
object against data processing. The user can object against personal data processing made with the purpose of direct marketing.
request processing restriction. Such right can be used only in specific cases e.g. to dispute data accuracy during the period of data clarification or determine improper processing. If such request to restrict data processing has been received, ISPmanager has no right to process any data without further consent from the user. However, data processing required to provide protection against complaints and suits still can be performed even without such consent from the user.
request data export, or import if it is technically feasible. Such right can be achieved by the user per his/her request in Account area. Data is exported in CSV.
request deletion of data. ISPmanager keeps the right to continue data processing after the request has been received if it is allowed by the applicable law.

Other rights might be provided by the applicable law.

ISPMANAGER PROCESSORS

ISPmanager can attract subcontractors and service providers (hereafter – Processors) to meet its obligations towards users and establish its reasonable legal interests.

Processors receive the strictly limited data kit required to accomplish their functions. ISPmanager shall take any possible measures to guarantee confidentiality of data transfer before attracting a processor.

COOKIE FILE USAGE POLICY

The given section determines how, when and why ISPmanager uses Cookie and identical technologies. Terms and definitions provided in this section are used in their meaning specified in Privacy Policy.

By using ISPmanager Services you automatically agree to use cookie files and identical technologies in accordance with the given document and Privacy Policy. If you do not wish to use these technologies, please use the settings described in the section “HOW TO DISABLE COOKIE”.

WHAT IS COOKIE?

Cookies are small text files saved on your computer or mobile device during usage of Websites and Account area. Each Cookie is unique for every account or web browser.

WHAT COOKIE ISPMANAGER USES

ISPmanager uses Cookie files and identical technologies such as pixel and web beacon. Normally, it is a gif file of 1 pixel which opening allows to receive information e.g. about technical parameters of your connection.

ISPmanager uses session and permanent Cookies. Session cookies are created for the time period of when your web browser is opened and to be deleted automatically after the browser has been closed. Permanent cookies are created until they have been deleted on their own or the time period specified in Cookies has expired.

Furthermore, ISPmanager uses Cookies which are installed by third parties e.g. analytical systems such as Google Analytics.

Some Cookies are linked to your account and establish authorization. Other Cookies are not linked to your account; however, since they can be unique, they can still save settings, interface elements, your preferences, and previous choices.

Cookies allow to use all of the features of Websites and accounting area.

Also, Cookies differ in the ways they are used. ISPmanager utilizes a few such cookies.

Usage	Description
Authorization	If you have entered your account details on a Website, Cookie will make is possible to switch from one webpage to another while keeping access to secured areas. Website can operate with malfunctions without such files.
Security	Such cookies allow to determine malicious actions or bots.
Settings and processes	Cookies save information about your language, forms filled, and system status.
Marketing	Cookies can be used to organize marketing campaigns e.g. to show advertisement and analyze their efficiency. Also Cookies can be utilized in marketing email sendouts to analyze opening and reading rates and links usage. If you live in Europe, you can disable advertisement from certain advertisement systems e.g. by using such services as http://www.aboutads.info/choices/ or http://www.youronlinechoices.eu/.
Enhance stability, analytics, development	Cookies help to collect and analyze information about how users interact with Website and Account area. This information is not identifying.

HOW TO DISABLE COOKIE

Most modern web browsers allow you to manage security settings. The user can restrict saving and using cookie files and add specific websites to exceptions.

Settings for each web browser are described in its documentation.

Use the following links to find settings for the most popular web browsers.

You can restrict using cookies from third parties such as Google Analytics on the Google website. Furthermore, you can restrict the usage of pixels or web beacons in social networks in security settings of these social networks.

If you restrict the usage of cookies, ISPmanager Services might perform with malfunctions. For example, the system might not be able to save settings, provide successful authorization, send messages, or guarantee proper operation of Software products.

ISPmanager shall not be liable for impossibility of using ISPmanager Services due to the limits set on the usage of cookie technology.