Privacy Policy

Version 2026-11-01 · Last updated: 1 November 2026
Portfoliobox Stockholm AB · Contact: root@ironwire.sh

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

DataPurposeLegal 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

4. Sub-processors and recipients

We use the following sub-processors to provide the Service:

ProviderRoleLocation
Hetzner Online GmbHServer 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 appUnited 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:

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.