Privacy Policy

Effective Date: June 3, 2025

1. Introduction

Welcome! This Privacy Policy describes how my services (“I”, “me”, “my”) collects, uses, stores, and protects your personal information when you use my VPS node hosting and maintenance services (the “Services”). I am committed to protecting your privacy and handling your data in an open and transparent manner.

I operate as an individual service provider based in Šiauliai, Lithuania. This policy is intended to comply with applicable data protection laws, including the General Data Protection Regulation (GDPR) and relevant laws in the jurisdictions of my clients, such as the USA (e.g., California Consumer Privacy Act – CCPA/CPRA), Australia (Privacy Act 1988), and Canada (Personal Information Protection and Electronic Documents Act – PIPEDA).

By using my Services, you acknowledge that you have read and understood this Privacy Policy.

2. Information I Collect

I collect the following types of personal information to provide and improve my Services:

  • Contact Information: Your name and email address, which you provide when you engage my Services or communicate with me.
  • Service Operational Data: Credentials (e.g., passwords, API keys) for your node software and VPS access that you provide to me to enable me to perform the agreed-upon setup and maintenance services.
  • Payment and Transaction Information: Information related to your service subscriptions and payments. Payments are processed through Stripe, a third-party payment processor. I do not directly collect or store your full credit card details, but I will have access to transaction confirmations, subscription details, and billing information (like your name and email associated with the payment).
  • Communications: Records of our communications (e.g., emails regarding service setup, support, or billing).
  • Technical Information (Indirectly): While I do not directly collect technical information from your personal devices, in the course of managing your VPS, I will interact with technical data on the server. This data relates to the server’s operation and the node software, not your personal browsing activities.

3. How I Collect Your Information

I collect personal information in the following ways:

  • Directly from You: When you provide it to me through email or other direct communication methods for the purpose of engaging and using my Services (e.g., when you send me your node software credentials).
  • Through Third-Party Services:
    • Stripe: When you make a payment for the Services, Stripe collects your payment information. I receive confirmation of payment and related transaction details from Stripe.
    • Contabo (or other VPS provider): While I don’t collect personal data from Contabo, they are the underlying provider of the VPS service I manage for you.

4. How I Use Your Information (Purposes and Legal Basis)

I use your personal information for the following purposes, and I rely on the following legal bases under GDPR (where applicable):

  • To Provide and Maintain the Services:
    • Purpose: To set up, configure, maintain, update, and monitor your VPS and node software as agreed. This includes using the operational data (credentials) you provide.
    • Legal Basis: Performance of a contract with you.
  • To Process Payments:
    • Purpose: To manage your subscription and process payments for the Services through Stripe.
    • Legal Basis: Performance of a contract with you.
  • To Communicate With You:
    • Purpose: To respond to your inquiries, provide support, send service-related announcements (e.g., maintenance notifications, password change alerts), and manage our client relationship.
    • Legal Basis: Performance of a contract with you; my legitimate interests in maintaining good client relations.
  • For Security and Compliance:
    • Purpose: To maintain the security of my services and your data, prevent fraud, and comply with applicable legal or regulatory obligations.
    • Legal Basis: My legitimate interests in protecting my services and your data; compliance with legal obligations.

5. Data Sharing and Disclosure

I do not sell your personal information. I will only share your personal information with third parties in the following limited circumstances:

  • Service Providers (Sub-processors):
    • Stripe: To process your payments. Stripe has its own privacy policy governing its use of your data.
    • Contabo: As the provider of the underlying server infrastructure, Contabo will host the data on your VPS. Their data handling is subject to their terms and privacy policy.
    • I will only share information necessary for these providers to perform their services.
  • Legal Obligations: If required by law, regulation, legal process, or governmental request (e.g., a court order or subpoena), I may disclose your information. I will endeavor to notify you of such requests unless prohibited by law.
  • To Protect Rights and Safety: If I believe it’s necessary to protect my rights, property, or safety, or that of my clients or others (e.g., in cases of potential fraud or security threats).

6. Data Storage and Security

I take the security of your personal information seriously. I implement reasonable technical and administrative measures to protect your personal information from unauthorized access, use, alteration, or disclosure. These measures include:

  • Using strong passwords and multi-factor authentication (2FA) for my administrative systems and access to your operational data.
  • Securely storing any credentials you provide.
  • Limiting access to your personal information to me only, for the purposes outlined in this policy.

Despite these measures, please be aware that no method of transmission over the internet or electronic storage is 100% secure. While I strive to use commercially acceptable means to protect your personal information, I cannot guarantee its absolute security.

7. Data Retention

I will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the duration of your active subscription and for a reasonable period thereafter, as required to:

  • Comply with my legal and regulatory obligations (e.g., financial record-keeping).
  • Resolve disputes.
  • Enforce my agreements.

Operational data you provide (like node software passwords) will be permanently deleted from my active systems within a reasonable timeframe after the termination of your Services and settlement of any outstanding dues.

8. International Data Transfers

Your personal information may be processed and stored in countries outside of your country of residence, including Lithuania (where I am based) and countries where my service providers (like Stripe and Contabo) operate. These countries may have data protection laws that are different from those in your country.

When I transfer your personal information internationally, I will take steps to ensure that your information is treated securely and in accordance with this Privacy Policy and applicable data protection laws (e.g., by relying on adequacy decisions, Standard Contractual Clauses where applicable for GDPR).

9. Your Data Rights

Depending on your jurisdiction (e.g., GDPR, CCPA/CPRA, PIPEDA, Australian Privacy Act), you may have certain rights regarding your personal information. These may include the right to:

  • Access: Request access to the personal information I hold about you.
  • Rectification: Request correction of inaccurate or incomplete personal information.
  • Erasure (Deletion): Request deletion of your personal information, subject to certain conditions (e.g., if it’s no longer necessary for the purposes for which it was collected).
  • Restrict Processing: Request that I restrict the processing of your personal information under certain circumstances.
  • Data Portability: Request to receive your personal information in a structured, commonly used, and machine-readable format (where applicable).
  • Object to Processing: Object to the processing of your personal information based on my legitimate interests (I will stop processing unless I have compelling legitimate grounds).
  • Withdraw Consent: If I rely on your consent to process your personal information, you have the right to withdraw that consent at any time.
  • Lodge a Complaint: Lodge a complaint with a supervisory authority if you believe your data protection rights have been violated. For GDPR, this would be the Lithuanian State Data Protection Inspectorate or the authority in your EU member state.

To exercise any of these rights, please contact me using the details provided in the “Contact Us” section below. I will respond to your request in accordance with applicable data protection laws. I may need to verify your identity before processing your request.

Note for California Residents (CCPA/CPRA): I do not “sell” your personal information as defined under the CCPA. You have the rights listed above, including the right to know what personal information is collected, used, and disclosed.

10. Children’s Privacy

My Services are not directed to individuals under the age of 18 (or the relevant age of majority in their jurisdiction). I do not knowingly collect personal information from children. If I become aware that I have inadvertently collected personal information from a child, I will take steps to delete it promptly.

11. Changes to This Privacy Policy

I may update this Privacy Policy from time to time to reflect changes in my practices, service offerings, or applicable laws. If I make material changes, I will notify you by email or through other appropriate communication channels before the change becomes effective. I encourage you to review this Privacy Policy periodically for the latest information on my privacy practices.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or my data practices, please contact me at:

Martynas Dijokas support@nodec.digital