PRIVACY POLICY
1. Introduction
This Privacy Policy explains how Proactivity Group Limited (“we,” “us,” or “our”)
processes and protects personal data of its clients and website users in accordance
with applicable data protection laws. We recognise the importance of protecting personal
data and are committed to lawful and transparent handling.
We provide hosting services, including virtual servers and related connectivity
solutions. This Policy describes what personal data we collect, how we use it, and the
rights you have under such laws.
2. Who Is the Controller of Your Personal Data?
Controller: Proactivity Group Limited
Business Registration Number: 72919011
Registered Office: 6/F, Block 3, Nan Fung Industrial City,
18 Tin Hau Road, Hong Kong
When you store or process third parties’ data on our hosting infrastructure, you
(the Customer) may be the controller of that data, and we act as a processor.
See Section 8 below.
3. Contact Person for Data Protection
For questions related to personal data or to exercise your rights, please email: privacy@thehosting.io
4. Purposes and Legal Bases for Processing
We process personal data for:
• Performance of a Contract (under the lawful basis provided by
applicable data protection legislation)
Providing hosting services and related support.
• Compliance with Legal Obligations (where required by applicable law)
Meeting tax, accounting, or other statutory requirements.
• Legitimate Interests (as permitted by applicable data protection laws)
Securing our network and preventing fraud,
Improving service delivery,
Tailoring our offers to your needs (unless overridden by your fundamental rights).
• Consent (where explicitly provided)
Sending marketing communications if you have opted in.
5. What Personal Data Do We Process?
Depending on how you interact with us:
• Identification Data
Name, date of birth (if legally required), or business registration details.
• Contact Data
Address, email, phone number.
• Registration and Payment Data
Records of purchased services, payment details, billing info, transaction IDs.
• Technical Data (Hosting & Server Usage)
IP addresses, system/access logs, resource usage (CPU, RAM),
event history (restarts, configuration changes).
• Additional Data for Security and Compliance
Potential anti-fraud checks, government ID if legally required.
• Marketing and Communication Preferences
Opt-in/opt-out choices, if you subscribe to newsletters.
We do not intentionally collect special category data (e.g., health or biometric data)
unless legally required or with your explicit consent.
6. Sources of Personal Data
• You, the data subject: via registration forms, support tickets, etc.
• Public sources: official registers or publicly available information if relevant.
• Third-party partners: payment gateways or business partners, where lawful.
7. Consent for Certain Purposes
In some cases, we request your consent for:
• Marketing communications beyond the normal retention period,
• Sharing data with select partners for special promotions,
• Other scenarios where consent is the lawful basis.
You can withdraw consent at any time (see Section 10).
8. Data Sharing and Transfers
• Processors
We may engage processors (e.g., data centre staff, payment processors) who process data
on our behalf, subject to strict data protection obligations.
• Within the Company
Only authorised personnel can access your data.
• Third Parties
We share data with third parties (e.g., domain registrars, SSL providers) only if
necessary to provide services or comply with legal obligations.
• Transfers Outside the Original Jurisdiction
If data is transferred outside the jurisdiction where it was collected, we use
appropriate safeguards (e.g., standard contractual clauses) to ensure protection, in line
with applicable data protection requirements.
• Role as a Processor
When you (the Customer) store third-party personal data on our servers, you are the
controller, and we are the processor. A separate Data Processing Agreement (DPA) may
apply if required by applicable law or contract.
9. Retention Period
We retain personal data for the duration of the contract plus a reasonable period
(usually up to 3 years) unless longer retention is required by law (e.g., tax records
for 6+ years). Technical logs may be stored for up to 12 months for security/diagnostics.
If processing is based on consent, we delete or anonymise data upon withdrawal, unless
another legal basis applies.
10. Your Rights
Under applicable data protection law, you have the right to:
• Access: Request confirmation of whether we process your data and
obtain a copy.
• Rectification: Correct inaccurate or incomplete data.
• Erasure: Request deletion of data if it’s no longer needed or
was processed unlawfully.
• Restriction: Ask us to restrict processing under certain conditions.
• Portability: Receive data in a structured, commonly used format.
• Withdraw Consent: If processing is based on consent, you can
revoke it at any time.
• Object: Object to processing based on our legitimate interests
or for direct marketing.
• Complain: Lodge a complaint with us or with the competent data
protection authority if you believe your data protection rights are violated.
11. Data Security Measures
We implement a range of technical and organisational measures to protect personal data
against unauthorised or unlawful processing, accidental loss, destruction, or damage.
These include:
• Secure server infrastructure and firewalls,
• Access controls (passwords, 2FA, least-privilege),
• Encryption where feasible,
• Staff training on data protection.
12. Cookies and Similar Technologies
We use cookies and similar technologies on our website to provide core functionality, analyse usage, and enhance user experience. For more details, please see our Cookie Policy or contact privacy@thehosting.io.
13. ASA and PECR
We adhere to applicable requirements regarding marketing communications. We only send marketing emails or SMS messages where we have a lawful basis (such as consent), and we respect your right to opt out at any time. If you have any questions, please contact privacy@thehosting.io
14. Changes to This Privacy Policy
We may update this Policy to reflect legal, technical, or business changes. We will post the new version on our website and, where required, notify you via email or another channel. Please review it periodically to stay informed.
15. Contact and Further Information
If you have questions or wish to exercise any rights related to personal data,
please contact:
Proactivity Group Limited
6/F, Block 3, Nan Fung Industrial City, 18 Tin Hau Road, Hong Kong
Email: privacy@thehosting.io