Privacy Policy
1. Controller
The controller of personal data processed in connection with the ironwire service (the "Service") is Portfoliobox Stockholm AB, a company registered in Sweden. All privacy-related enquiries and requests can be directed to root@ironwire.sh.
Where you use the Service to process personal data belonging to third parties (for example, data stored on your machines or received by email), you are the controller of that data and Portfoliobox acts as your processor under the Data Processing Agreement. This policy covers the data Portfoliobox processes as controller.
2. Personal data we process, and why
| Data | Purpose | Legal basis (Art. 6 GDPR) |
|---|---|---|
| Account handle, SSH public keys and their fingerprints | Account identification and authentication | Performance of a contract (Art. 6(1)(b)) |
| Terms acceptance record (version, timestamp) | Evidence of the agreement | Performance of a contract; legitimate interest in record-keeping (Art. 6(1)(b), (f)) |
| IP addresses and connection metadata in operational logs | Security, abuse prevention, troubleshooting | Legitimate interest in operating a secure service (Art. 6(1)(f)) |
| Machine metadata (names, sizes, status, resource usage) | Operating and displaying your machines | Performance of a contract (Art. 6(1)(b)) |
| Machine disk contents and inbound email you elect to receive | Storage and delivery on your instruction | Performance of a contract (Art. 6(1)(b)); processed as processor where the content contains third-party personal data |
| Push notification token of each device on which you sign in to the mobile app, and the name of the machine a notification concerns | Delivering push notifications to your devices | Performance of a contract (Art. 6(1)(b)) |
| Email address and payment-provider identifiers (paid accounts) | Billing and receipts | Performance of a contract (Art. 6(1)(b)); legal obligation to keep accounting records (Art. 6(1)(c)) |
| Email address you leave on the waitlist (on the website or over SSH), or that we invite by email, with when and where it joined | Inviting you, and telling you when ironwire opens | Consent (Art. 6(1)(a)), which you may withdraw at any time |
| Invite record: the email address an invite code was issued to, when it was issued, and when it was used | Letting the person we invited in, once | Consent (Art. 6(1)(a)), which you may withdraw at any time |
| Correspondence with us (email) | Support and administration | Legitimate interest in responding to enquiries (Art. 6(1)(f)) |
We do not use your data for advertising, we do not sell it, and we do not use automated decision-making or profiling within the meaning of Art. 22 GDPR. Your email address is collected only for billing; an address you leave on the waitlist, or that we invite, is used only to invite you and to tell you when ironwire opens, and is not linked to your SSH key until you use an invite; if you correspond with us, the address you write from is used only for that correspondence. Push notifications carry no message content — only the machine name and a fixed text — and are sent only to devices on which you have signed in and allowed notifications.
3. Retention
- Account data (handle, keys, acceptance record) is retained for the lifetime of the account and deleted when the account is deleted.
- Machine contents and received email are deleted when the machine or account they belong to is deleted.
- A device's push notification token is deleted when that device is unlinked from the account, when the push service reports the device as no longer registered, or when the account is deleted.
- A waitlist email address and any invite record for it are kept until you ask us to delete them, which you can do at any time by writing to root@ironwire.sh.
- Operational logs containing IP addresses are retained for a limited operational window and then deleted or anonymised.
- Records we are legally required to keep (for example accounting records) are retained for the statutory period.
4. Sub-processors and recipients
We use the following sub-processors to provide the Service:
| Provider | Role | Location |
|---|---|---|
| Hetzner Online GmbH | Server hosting (all machines, account data, and stored content) | Germany (EU) |
| Stripe Payments Europe, Ltd. | Payment processing | Ireland (EU) |
| Expo (650 Industries, Inc.) | Push notification delivery for the mobile app | United States |
Stripe processes subscription payments on our behalf. Stripe receives your email address, billing details and payment card data; card data is collected by Stripe directly and never reaches our servers. We store only your email address and Stripe's customer and subscription identifiers. Stripe processes this data within the EU/EEA; where it transfers data outside the EEA, it does so under the European Commission's Standard Contractual Clauses.
Expo relays push notifications from us to your device. Expo receives the push token of each device on which you have signed in to the mobile app and the content-free notification (machine name and a fixed text), and forwards it to the push service of your device's operating system — Apple Push Notification service (Apple Inc.) or Firebase Cloud Messaging (Google LLC), under those companies' own terms — for display on the device. Expo retains push tokens and does not store notification content beyond delivery.
5. International transfers
Your account data, your machines and their contents, and our operational logs are stored and processed exclusively within the EU/EEA and are not transferred outside it.
The only personal data transferred outside the EU/EEA is the push notification data described in section 4 — device push tokens and the machine name in a notification — which is transferred to Expo in the United States and onward to Apple or Google. Expo is certified under the EU-U.S. Data Privacy Framework (including its UK and Swiss extensions), which the European Commission has recognised as providing adequate protection (Art. 45 GDPR), and additionally commits to the Standard Contractual Clauses. This transfer takes place only if you install the mobile app and allow notifications on a device; the Service is fully usable without it.
6. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you (Art. 15);
- have inaccurate data rectified (Art. 16);
- have your data erased (Art. 17);
- restrict processing (Art. 18);
- receive your data in a portable format (Art. 20);
- object to processing based on legitimate interest (Art. 21).
To exercise any of these rights, contact root@ironwire.sh. We respond within one month as required by Art. 12(3) GDPR. You also have the right to lodge a complaint with a supervisory authority; the authority responsible for Portfoliobox is the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), www.imy.se.
7. Security and personal data breaches
We apply technical and organisational measures appropriate to the risk, including tenant isolation between machines, encrypted transport (SSH and HTTPS) for all access to the Service, encryption at rest for stored secrets, and access restricted to authorised operators. Personal data breaches are handled in accordance with Art. 33 and 34 GDPR: where a breach is likely to result in a risk to your rights, we notify IMY within 72 hours, and where the risk is high, we notify you directly.
8. Cookies
The public website sets no analytics or tracking cookies. Should this change, this policy will be updated and consent obtained where required.
9. Changes to this policy
Material changes to this policy are announced through the Service. The current version and its date are shown at the top of this page.