Privacy Policy
Mino UG
[Business Address]
Germany
Version 1.0 | Updated January 15, 2025
1. Data Controller and Contact Information
Responsible Entity (Data Controller)
Mino UG
[Business Address]
Germany
Email: [email protected]
Phone: [Phone Number]
This privacy policy explains how Mino UG (operating as "vps.direct") collects, uses, and protects your personal data in accordance with the General Data Protection Regulation (GDPR) and the Personal Information Protection and Electronic Documents Act (PIPEDA).
2. Legal Basis and Purpose of Data Processing
We process your personal data based on the following legal grounds under Article 6 GDPR:
Art. 6(1)(b) GDPR - Contract Performance
Processing necessary for the performance of our hosting services contract
Art. 6(1)(c) GDPR - Legal Obligation
Processing for compliance with legal obligations (tax law, telecommunications law)
Art. 6(1)(f) GDPR - Legitimate Interest
Processing for our legitimate interests in providing secure and reliable hosting services
Art. 6(1)(a) GDPR - Consent
Processing based on your explicit consent for marketing communications
3. Categories of Personal Data Collected
Account and Registration Data
- Name (first name, last name)
- Email address
- Billing address
- Phone number (optional)
- Company information (for business accounts)
- VAT number (where applicable)
- Account credentials (encrypted passwords)
Technical and Usage Data
- IP addresses and connection logs
- Server resource usage statistics
- Service uptime and performance metrics
- Support ticket communications
- System error logs and security events
- Bandwidth usage and transfer volumes
Payment and Billing Data
- Payment method information (processed by secure payment providers)
- Transaction history and invoices
- Billing preferences and payment status
- Tax-relevant information
4. Purposes of Data Processing
Service Provision
- • Account creation and management
- • VPS deployment and configuration
- • Technical support and maintenance
- • Service monitoring and optimization
Billing and Payment
- • Invoice generation and processing
- • Payment collection and verification
- • Tax compliance and reporting
- • Fraud prevention and detection
Security and Compliance
- • Infrastructure security monitoring
- • Abuse prevention and investigation
- • Legal compliance obligations
- • Network integrity protection
Communication
- • Service notifications and updates
- • Technical support communications
- • Marketing communications (with consent)
- • Legal notices and policy updates
5. Data Retention Periods
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law:
Account Data
Duration of contract + 30 days
Billing Records
10 years (tax law requirements)
Server Logs
7 days (security), 30 days (billing)
Support Communications
3 years after issue resolution
6. Data Sharing and International Transfers
We do not sell, trade, or rent your personal data to third parties. We only share your data in the following circumstances:
Service Providers
We work with trusted service providers for payment processing, infrastructure management, and support services. All processors are bound by data processing agreements (DPAs) and GDPR compliance requirements.
Legal Requirements
We may disclose your data when required by law, court order, or to protect our rights, property, or safety of our users. We will notify you of such requests unless legally prohibited.
Data Center Locations
Your data is processed in our data centers located in Germany and Canada. No data is transferred to countries outside the EU/EEA without adequate protection measures or your explicit consent.
7. Your Rights Under GDPR and PIPEDA
You have the following rights regarding your personal data:
Right of Access
Request access to your personal data and information about how we process it
Right to Rectification
Request correction of inaccurate or incomplete personal data
Right to Erasure
Request deletion of your personal data under certain circumstances
Right to Portability
Receive your personal data in a structured, machine-readable format
Right to Restrict Processing
Request limitation of processing under certain circumstances
Right to Object
Object to processing based on legitimate interests or for marketing purposes
To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days. You also have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.
8. Data Security Measures
We implement comprehensive technical and organizational measures to protect your personal data:
Technical Measures
- • End-to-end encryption (TLS 1.3)
- • Data encryption at rest (AES-256)
- • Regular security audits and penetration testing
- • Multi-factor authentication
- • Network segmentation and firewalls
- • Automated backup systems
Organizational Measures
- • Staff training on data protection
- • Access controls and role-based permissions
- • Data processing agreements with vendors
- • Incident response procedures
- • Regular policy reviews and updates
- • Physical access controls to data centers
9. Cookies and Similar Technologies
Privacy-First Approach: Essential Cookies Only
vps.direct uses only essential cookies that are strictly necessary for website functionality and security. We do not use analytics, marketing, or tracking cookies. No consent banner is required because all cookies we use are technically necessary for the service you have explicitly requested.
Our website uses the following types of cookies and similar technologies:
Essential Functionality Cookies
These cookies are strictly necessary for the operation of our website and services. They enable core functionality such as security, authentication, and basic website operations.
- User authentication and session management
- Security features and CSRF protection
- Basic website functionality and navigation
- Load balancing and server communication
- Form submission and data processing
Legal Basis: Article 6(1)(f) GDPR - Legitimate Interest
Retention: Session duration or until logout
Consent Required: No - These cookies are strictly necessary
What We Don't Use
To protect your privacy, we deliberately do not use the following types of cookies or tracking technologies:
- Analytics or tracking cookies (Google Analytics, etc.)
- Marketing or advertising cookies
- Social media tracking pixels or buttons
- Third-party tracking scripts
- Cross-site tracking mechanisms
- Behavioral profiling cookies
Managing Cookies: Since we only use essential cookies required for website functionality, there is no need for cookie preferences or consent management. However, you can always manage or delete cookies through your browser settings. Please note that disabling essential cookies may prevent certain parts of our website from functioning properly.
Browser Settings: Most web browsers allow you to view, manage, and delete cookies through their settings menu. Consult your browser's help documentation for specific instructions.
Transparency Commitment: If we ever decide to use analytics or marketing cookies in the future, we will update this privacy policy and implement appropriate consent mechanisms before any such cookies are deployed. You will be notified of any changes to our cookie practices.
10. Children's Privacy
Age Restrictions
Our services are not intended for individuals under the age of 16 (or 13 in jurisdictions where applicable). We do not knowingly collect personal data from children. If you become aware that a child has provided us with personal data, please contact us immediately.
11. Changes to This Privacy Policy
We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will:
- Post the updated policy on our website with a new effective date
- Notify you by email of material changes that affect your rights
- Provide 30 days notice before significant changes take effect
- Maintain previous versions for reference upon request
Continued use of our services after changes become effective constitutes acceptance of the updated policy.
Privacy Contact Information
For any questions about this privacy policy or to exercise your data protection rights:
Data Protection Officer
[email protected]General Inquiries
[email protected]Mailing Address
Mino UG
Data Protection Department
[Business Address]
Germany
Supervisory Authority
German Data Protection Authority
(Bundesbeauftragte für den Datenschutz)
www.bfdi.bund.de
This Privacy Policy is effective as of January 15, 2025 and complies with GDPR (EU) 2016/679 and PIPEDA requirements.
Last reviewed and updated: January 15, 2025