Privacy Policy

This Privacy Policy explains how Custos Cloud ("we", "us") collects, uses and protects personal data when you visit custoscloud.com or get in touch with us. We handle your data in line with the EU General Data Protection Regulation (GDPR).

Who we are

The data controller is Liran Aknin, operating under the trading name Custos Cloud, an independent practitioner based in Antwerp, Belgium. For any privacy question, contact us at info@custoscloud.com.

What data we collect and why

• When you email us (including through the email link on our contact page), we receive your name, email address and the content of your message. Our email is provided by Google, which processes your message on our behalf so we can respond to your enquiry. Legal basis: our legitimate interest in answering you and, where relevant, taking steps at your request before entering into a contract (GDPR Article 6(1)(f) and 6(1)(b)).
• When you book a call, our scheduling provider, Cal.com, collects your name, email and the details needed to arrange the meeting, and may also collect technical data such as your IP address as part of providing its booking page. The meeting is then scheduled and held through Google (a calendar invitation and a video call), so Google also processes the booking and call details on our behalf. Legal basis: our legitimate interest in arranging the call and, where you would be the contracting party, steps taken at your request before entering into a contract (GDPR Article 6(1)(f) and 6(1)(b)).
• Technical data. Our hosting and content-delivery provider may keep standard server logs (such as IP address and request time) for security and reliability. We do not use these to identify you. Legal basis: our legitimate interest in the security and reliable operation of the site (GDPR Article 6(1)(f)).

We do not use analytics, advertising or social-media tracking on this site.

Providing any of this is voluntary. You do not have to contact us or book a call, but we cannot respond if you do not.

Cookies

This website does not use cookies or similar tracking technologies. If we ever add something that does (for example website analytics or an embedded booking widget), we will update this policy and ask for your consent where the law requires it.

Who we share data with

We do not sell your personal data. We share it only with the service providers that help us run the site and respond to you:

• Hosting and delivery: Amazon Web Services.
• Email, calendar and video meetings: Google.
• Scheduling: Cal.com (EU region).

These providers act on our behalf under appropriate data-processing terms.

International transfers

Your booking data is processed within the European Economic Area (EEA): our scheduling provider, Cal.com, hosts it in its EU region, with the European Commission's Standard Contractual Clauses in place as a safeguard for any limited processing outside the EEA.

Our hosting provider (Amazon Web Services) and our email, calendar and meeting provider (Google) process some data, including server logs and the details of any call you book, on servers in the United States. Cal.com also uses a small number of providers located outside the EEA. Where data leaves the EEA, the transfer is covered by a safeguard recognised under the GDPR: the European Commission's adequacy decision for the EU-US Data Privacy Framework where the provider is certified under it, or the Commission's Standard Contractual Clauses. You can ask us for more detail using the contact details below.

How long we keep it

We keep enquiry and booking correspondence for up to 24 months after our last contact with you, unless it relates to an engagement. In that case we keep it for the duration of the engagement and for any period we are legally required to afterwards. Server logs held by our hosting provider are kept for a short period, typically a few weeks.

How we protect your data

We take appropriate technical and organisational measures to keep your personal data safe, including encrypted connections (HTTPS), access controls, and collecting only the data we actually need.

Automated decisions and profiling

We do not use your personal data for automated decision-making or profiling.

Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you
• have inaccurate data corrected
• have your data erased
• restrict or object to how we use it
• receive your data in a portable format
• withdraw your consent at any time, where we rely on it

Where we process your data based on our legitimate interests, you have the right to object at any time. Email us and we will stop, unless we can show compelling legitimate grounds to continue.

To exercise any of these, email info@custoscloud.com. You also have the right to lodge a complaint with a supervisory authority. In Belgium this is the Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données), Rue de la Presse 35, 1000 Brussels, www.gegevensbeschermingsautoriteit.be.

Changes to this policy

We may update this policy from time to time. The date at the top shows when it was last changed.

Contact

Questions about this policy or your data? Email info@custoscloud.com.