Privacy Statement

Your privacy is important to HOSTKEY B.V. (hereinafter “HOSTKEY”). HOSTKEY is therefore pleased to provide this Privacy Statement to inform you of HOSTKEY’s practices with respect to the collection, storage and use of your personal information (hereinafter “Data”).

Please read this Privacy Statement carefully to understand our policies and practices regarding your information and how we treat it.

By accessing or using our services, you agree to this privacy statement.

How HOSTKEY collects information about you

In general, HOSTKEY will only collect and store the Data you have provided if this is required in order to provide you with services and products you have ordered from HOSTKEY or to answer your inquiry.

HOSTKEY may collect your Data when:

1.

You order a service from HOSTKEY.

2.

You participate in a HOSTKEY survey.

3.

You subscribe to HOSTKEY newsletters.

4.

You ask HOSTKEY for more information about its services, or contact HOSTKEY with a question, comment or complaint.

5.

You submit an abuse notification to HOSTKEY.

6.

You use the HOSTKEY network, HOSTKEY infrastructure and/or other HOSTKEY services.

In addition, HOSTKEY may collect and transmit Data about you to the extent permitted by law from and/or to fraud-prevention agencies, referral partners and credit reference agencies.

What types of information HOSTKEY collects about you

1.

Your name / company name, (business/private) address, VAT number if applicable, phone number and email address. We may also collect the URL from which you linked into our site, your IP address & ISP, your browser type and version, and a history of your actions on our website.

2.

Your HOSTKEY account information — such as HOSTKEY services you ordered, domain name registration information, the IP addresses assigned to you, your customer ID, service charges owed and received, the use of HOSTKEY services or any other information related to your account.

3.

Your communication with HOSTKEY — such as a recording of a call you make to HOSTKEY, a chat transcript when you engage in a chat session on HOSTKEY’s website, an email or letter you send to HOSTKEY or other records of any contact you have with HOSTKEY.

4.

Information about your payment method, such as credit card number, bank account number or other banking information, transaction IDs & payment dates.

5.

Information provided by you to HOSTKEY when you notify HOSTKEY of a (suspected) breach of HOSTKEY’s acceptable use policies.

6.

Copies of documents and information that certify your identity according to applicable law.

Why HOSTKEY processes your personal information

HOSTKEY processes your Data for the following purposes:

1.

Processing of orders and provision of services.

2.

Conducting market research, conducting retention and customer satisfaction surveys, conducting marketing activities (including email newsletters and social media), conducting sales activities (including analyzing your Data and your use of HOSTKEY services for making (personalized) offers and quotes with the aim of entering into a customer relationship, and/or maintaining, renewing or expanding a customer relationship) and offering promotional games of chance.

3.

Communicating with customers:

3.1

to provide information about services of HOSTKEY;

3.2

to provide information about offers, orders, provision of services, order status and payment;

3.3

to provide support and maintenance of services;

3.4

to handle complaints;

3.5

to answer questions from (potential) customers.

4.

Performing financial processes, including:

4.1

calculating, invoicing and collecting of service charges;

4.2

processing financial transactions regarding the acceptance of orders;

4.3

granting debt collection rights to third parties;

4.4

investigating creditworthiness and risk management, including prevention of overextending credit to (potential) customers and verifying whether (potential) customers will be able to comply with financial obligations.

5.

Investigating and processing suspected violations of HOSTKEY’s General Terms and Conditions, Terms of Services.

6.

Ensuring the security of persons, goods and objects, and performing fraud detection.

7.

Conducting legal processes, including:

7.1

conducting legal proceedings;

7.2

collecting evidence for civil legal proceedings relating to HOSTKEY’s customers.

8.

Complying with statutory obligations, including:

8.1

provision of data to authorities in the context of criminal investigations;

8.2

complying with (applicable) data retention obligations;

8.3

the provision of Data to third parties concerning customers in connection with an infringement of these third parties’ rights.

Data sharing

HOSTKEY may share Data about you if HOSTKEY has obtained your consent; or in cases allowed by law, with the following third parties:

1.

Partners or agents involved in delivering the services you have ordered from HOSTKEY.

2.

Credit reference, fraud prevention or business scoring agencies, or other credit scoring agencies.

3.

Domain name registries when HOSTKEY registers a domain name on your behalf.

4.

Debt collection agencies or other debt recovery organizations.

5.

Law enforcement agencies, regulatory organizations, courts or other public authorities to the extent required by law.

6.

HOSTKEY’s customer, if you notify HOSTKEY that this customer’s use of HOSTKEY services violates HOSTKEY’s General Terms and Conditions , Terms of Services, or applicable law.

7.

A third party that has claimed that your use of the HOSTKEY services violates the HOSTKEY’s General Terms and Conditions, Terms of Services, or applicable law (to the extent such sharing is required by law).

Data Security

HOSTKEY has implemented technical and organizational measures, to the extent technically possible, to keep your Data safe from outside attacks, loss, misuse, alteration, or destruction. When collecting, processing or sharing your Data, HOSTKEY will use current encryption methods to protect your Data. HOSTKEY has been focused on implementing fair information practices that are designed to protect your data privacy effectively. It believes that everyone benefits from the free flow of information when that information is gathered and used responsibly. The Data you may provide is shared only with authorized employees of HOSTKEY, and on a limited basis, with distributors who will supply information or further data for your benefit and the other parties mentioned in this statement. In addition, HOSTKEY may disclose personally identifiable information only as may be required by subpoena, search warrant, or other legal processes.

Know-your-customer verification

HOSTKEY uses the SumSub third-party service to verify the identity of customers. The data requested by SumSub is used to make such verification and not for any other purpose. HOSTKEY only receives confirmation that the Customer’s identity is legally accurate. See the SumSub privacy policy for more information.

HOSTKEY needs this identify verification to ensure it is dealing with known customers. Without this information HOSTKEY cannot provide it services to Customer.

Cookies

HOSTKEY uses cookies and statistics to analyze how visitors use our website. Cookies contain a unique combination of letters and numbers. Cookies do not contain any form of personal data. Therefore, cookies cannot be used to identify you personally. Furthermore, cookies cannot be used to identify you on other websites. Our website uses Google Analytics cookies. By using these cookies we collect data about the usage of our website. We analyze and use this data to improve our website.

Deletion of the data collected and stored

Legislation has stipulated a wide range of obligations for the collection and storage of data. After expiration of such periods, the corresponding data will be routinely deleted by HOSTKEY. In addition, unrelated to these foresaid timeframes, we will delete such data as soon as the purpose outlined above does not exist any longer.

Your rights

Under applicable law, you have the right:

1.

to check whether HOSTKEY holds your Data;

2.

to access that Data;

3.

to amend any Data that is incorrect or no longer valid.

You may exercise these rights by contacting the HOSTKEY customer Support Department through the ‘Contact’ page on the hostkey.com website.

Modification

This Privacy Statement may change from time to time. Your continued use of our services after we make changes is deemed to be acceptance of those changes. HOSTKEY advises you to periodically review this page to see if any changes have been implemented.

If you have any questions or suggestions about HOSTKEY’s privacy practices, please feel free to contact us by e-mail.

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