This Privacy Policy reflects how Speedyrails Inc., its officers, employees, subsidiaries and affiliates, (“We”, “Us”, “our”) provide its web hosting services (the “Services”) through the Speedyrails Inc. website and platforms to end Users and Customers (“Customer”, “User”, “You”, “your”), and how Speedyrails Inc. collects, uses, retains, and discloses your Personal Information.

We may change this Privacy Policy at any time by posting a new version available on our home page. The new version will be effective as of the “Last Update” date. We will notify You by email if We make material changes to the Privacy Policy and You will have the option to opt-out of our Privacy Policy and Services.

If You have any questions or concerns about this Privacy Policy, please email privacy@speedyrails.com.

This Privacy Policy applies to all Services provided to You by Speedyrails Inc. This Privacy Policy does not apply to Services provided to You by third party companies, other individuals, links on our website, or references through our Services.

“Consent” means the voluntary, unequivocal, expressed, informed, and unambiguous indication from You stating that You, wish to affirm or agree to this Privacy Policy or permit the processing of your Personal Information.

“Controller” means the person or organization responsible for deciding the purpose of processing the Personal Information.

“DPA” means the Data Protection Act 1998, which serves to regulate data protection for residents of the UK. To read the full text, please visit https://www.legislation.gov.uk/ukpga/1998/29/pdfs/ukpga_19980029_en.pdf.

“GDPR” means the General Data Protections Regulation, which serves to regulate privacy and data protection for residents of the UK and EU. To read the full text, please visit http://data.consilium.europa.eu/doc/document/ST-5419-2016-INIT/en/pdf.

“PECR” means the Privacy and Electronic Communications Regulation, which serves to regulate individual privacy rights in relation to electronic communications such as marketing calls, emails, texts, faxes, cookies and similar technologies, traffic and location data, itemized billing, line identification, and directory listings. To read the original version, please visit http://www.legislation.gov.uk/uksi/2003/2426/contents/made. The UK government last updated the PECR in 2016: http://www.legislation.gov.uk/uksi/2016/524/pdfs/uksi_20160524_en.pdf.

“Personal Information” or “personally identifiable information” means any information related to a natural person or what is sometimes called a ‘data subject’, whether collected on the internet or not, which can be used to directly or indirectly identify the person (sometimes referred to as ‘personal data’). This can be anything from a name, telephone number, photo, email address, bank details, posts on social networking websites, medical information, or a computer internet protocol (“IP”) address. Personal Information also includes characteristic, opinions, health, or financial information about/of an individual.

“PIPEDA” means the Personal Information Protection and Electronic Documents Act, which serves to regulate privacy and data protection for residents of Canada. To read the full text, please visit http://laws-lois.justice.gc.ca/PDF/P-8.6.pdf.

“Processing” means any work we do with Personal Information, including how we change Personal Information into non-personally identifiable information or aggregate information (i.e. pseudonymization), whether by automated means or not. This includes collecting, retaining, using, disclosing, and destroying the information.

“Third Party” means a person or organization other than the Controller or Processor who is authorized by agreement or contract with the Controller or Processor to access and process the Personal Information.

We collect and process Personal Information or we engage third party services that do the same to

• develop, operate, support, maintain, and improve our Services,
• analyze trends,
• optimize our website,
• conduct security checks and verify identities,
• comply with audit and regulatory purposes,
• send marketing communications,
• process payments,
• provide receipts and reports,
• resolve disputes,
• collect fees,
• troubleshoot problems, and
• informing You of security breaches, if any.

We only collect information to perform Services for you, in relation to our legitimate interests (namely, to operate our web hosting Services and communicate with you accordingly), and with your Consent. Speedyrails Inc. will only retain and process information that is absolutely necessary to provide its Services to You and will limit access to your Personal Information to those who need it to carry out the processing. We do not collect or process Personal Information further than what We require to fulfil customer transactions and basic functionalities of our Services.

We collect Personal Information and non-identifiable information for our own security, diagnostic, authentication and billing purposes; and, IP address information for legitimate interests, namely, to prevent hacking and fraud, and for diagnostics and data traffic analysis to improve our Services. For a detailed list of Personal Information we collect, please see Section 6 below.

We also obtain information from You, for instance your website use and preferences, by sending “cookies” to your browser, which then saves them your computer hard drive. Cookies and similar technologies recognize any given User who visits multiple website pages during the same session and remembers the User’s preferences. When you visit our website, your browser will send cookies to Us, which contain the information about your session and preferences. You may block cookies through your browser settings but this may limit your use of our Services.

We track Speedyrails Inc. website Users to help improve our Services and marketing using third party services such as Google Analytics, Intercom and Drift (for more information on our third party partners please see Section 14). If You do not want Us to track your use of our website or Services, please enable the ‘Do Not Track’ function on your web browser. We will do our best to stop tracking You.

We engage the services of third party companies that may track non-personally identifiable information when you access our website. Once We receive the ‘Do Not Track’ request, we will send the request to the third party companies. For more information, please see Section 6 and 14.

We collect your Personal Information You provide to Us either through the use of our website, cookies and similar technologies, or Services, etc. Using Google Analytics, cookies and similar technologies, We collect different types of information, including but not limited to:

• IP address
• Domain used to access our website
• Your browser type/version
• When You accessed our website
• The website You accessed our website from
• Which page You entered on or exited from our website
• How long You spend on any given page on our website
• How You interact with any given page on our website
• Your location when you accessed the website or used our Services

Speedyrails Inc. Customers must register and sign up for our Services through our website. If You provide it to Us when You sign up for our Services or communicate with Us, in addition to the information above, We may collect and retain your

• Name
• Mailing address
• Email address(es)
• Telephone number(s)
• Payment details*
• Other contact information You provide to Us

*While we collect your payment details through our website, and engage third party companies to process payments. Your financial information is never stored on our servers. For more information on third party payment companies, please see Section 14.

We may store Personal Information on our servers in Toronto and Vancouver. Most of our information is held and processed through our servers in Toronto. We may keep your information on our servers until it is no longer required for the purpose of its collection or as required by law.

We store logs and aggregate information we have collected through our servers and website for at least 3 months.

For residents in the UK, Personal Information regarding purchases or any other financial transaction will be kept for a minimum of 6 years as required by UK law.

For residents in Canada, Personal Information regarding purchases or any other financial transaction will be kept for a minimum of 7 years as required by Canadian law.

For residents in the US, financial information will be kept according to state laws.

You have the right restrict the processing of your Personal Information where We have no legitimate reason to process your information. These situations include where:

• the accuracy of the information is contested;
• You object to processing;
• processing is unlawful; and
• We no longer need your Personal Information but You require the information to establish a legal claim.

You may email Us at privacy@speedyrails.com using Your email address registered on our systems to restrict processing.

You have the right to obtain your Personal Information that We have collected, to know how and what we have done with your Personal Information, and how we store, protect, share, disclose, or destroy your Personal Information. You also have the right to receive your Personal Information in a way that is commonly used, in a readable format, and request to transmit your information to another company or person.

You may request our records of your Personal Information from Us by emailing privacy@speedyrails.com using Your email address registered on our systems. Once We have verified your identity, We will provide You with a copy of your Personal Information, free of charge, in PDF format within 28 days.

We strive to maintain accurate information in our records. Where We become aware that our records are incorrect, We may contact You to update our records. If You become aware of any changes or errors in our records regarding your Personal Information, please email privacy@speedyrails.com using Your email address registered on our systems so that We can correct our records.

You are entitled to request that your Personal Information be deleted from our records, that We stop providing your data to third party companies, and request that those companies remove your data from their records, provided that there are no legal reasons to keep your Personal Information. These reasons would include:

1. You withdraw Consent or there are no legal grounds for processing;
2. You object to processing and there are no legal grounds for processing;
3. the Personal Information was processed unlawfully;
4. the Personal Information must be erased because of a legal obligation of the UK as a member state of the EU; and,
5. the Personal Information was collected under Article 8 of the GDPR through an offer of information society services.

If You would like Us or third party companies We use to delete your Personal Information, please email Us at privacy@speedyrails.com using Your email address registered on our systems. Unless We have a legal obligation to keep the information, We will delete your Personal Information and communicate with third party companies, subsidiaries, and affiliates to do the same.

If You are a resident of the United Kingdom, You accept that information We collect is by default held and processed through servers located in Toronto, Canada. The laws governing the collection and use of the information may be different from the laws of the UK. You understand and Consent to the transfer of your Personal Information to Toronto, Canada.

If You requested to house your information at our servers located in a different location, the laws of that jurisdiction apply. You maintain the right to legal remedies despite the transfer of your Personal Information to any of our server locations.

To further safeguard your Personal Information from breaches following the transfer, We execute standard data protection contracts with our third party partners who are located in third countries that have not been deemed to provide adequate protection by the EU Commission.

To ensure the confidentiality, integrity and availability of our systems, Services, and your Personal Information, We have implemented physical, technical, procedural and organizational precautions to safeguard against unauthorized access, disclosure, alteration, or destruction. Specifically, We have implemented the following measures:

• Encryption of data at rest and in transit;
• Strict filtering rules;
• Stateless firewalls;
• Brute force detection;
• Additional care to protect your financial information, such as credit card or bank account numbers;
• Secure and monitored facilities;
• Authorization to access Personal Information only for employees, contractors, and agents who have undergone background checks and signed confidentiality agreements;
• Vault clusters to store API keys, application passwords and other secrets;
• VPN solutions to further secure our servers; and
• Cloudflare DDOS protection.

For more information, please read our Security page or contact Us at privacy@speedyrails.com using Your email address registered on our systems.