DRAFT for owner and legal review. This policy has not been approved yet. Text in [brackets] is still to be confirmed.
Privacy Policy
How Cloud365 handles your personal data. Last updated: [date of approval].
Who we are
Cloud365 (cloud365.sh) is an Odoo hosting service built and run by Zero. The controller of the personal data described here is [Zero Group SH.P.K., registered address, company number]. You can reach us about privacy at [privacy contact address].
What we collect on the waitlist
When you join the waitlist or ask for a demo, we collect what you type into the form: your full name, work email, company name and, if you choose to give them, your phone number, country, number of Odoo users, current setup, Odoo version and message. We also record that you agreed to be contacted, and when.
We use this information only to contact you about Cloud365: to tell you when it opens, to arrange a demo you asked for, and to answer your questions. We do not sell it, and we do not use it for advertising.
The legal basis is your consent, which you can withdraw at any time by writing to us. We keep waitlist details until Cloud365 opens and [12] months after that, or until you ask us to delete them, whichever comes first.
Signing in with Google
Customers of Cloud365 can sign in with their Google account. When you do, Google gives us your name, email address and Google account identifier. We use them only to sign you in to your Cloud365 account and to link that account to your Google identity. We do not use Google user data for advertising, and we do not share it with anyone else.
Cookies
This site sets only the cookies it needs to work: session_id, which keeps your session and protects the forms against forged submissions, frontend_lang, which remembers the language of the site, and tz, your browser’s time zone, used to show dates and times correctly. We use no analytics, advertising or third-party cookies, and the site loads no fonts or scripts from other companies.
Logs and spam protection
Like every web server, ours logs each request, including your IP address, to keep the service secure; these logs are kept for [14] days. To stop automated sign-ups, the waitlist form records the IP address of each submission for two days.
Where your data is hosted
The site and its data are hosted in the EU, at DigitalOcean’s data centre in Frankfurt, Germany, with backups stored in Frankfurt too. Zero’s team, who may work from Albania, Kosovo, Malta or the United Kingdom, accesses the data only to provide the service. [Describe the safeguards for access from outside the EU.]
Who receives your data
Zero’s staff who handle Cloud365, and our hosting provider (DigitalOcean), which processes it on our behalf. Nobody else, unless the law requires it.
Your rights
You can ask us for a copy of your data, to correct it, to delete it, to restrict or object to how we use it, and to receive it in a portable format. You can also complain to your data-protection authority [and, in Albania, to the Information and Data Protection Commissioner].
Changes
If we change this policy, we will publish the new version here with its date.