Legal

GDPR

Compliance measures under the General Data Protection Regulation.

Last updated: 2026-08-05 v 4.3 · 6 sections

1. Information clause (Art. 13)

Full text in the Privacy Policy. Summary: we collect data only to provide the service, store it in the EU, and transfer it outside the EEA only when necessary (e.g. transactional e-mail, consented marketing analytics) under Standard Contractual Clauses (SCC).

2. Security measures (Art. 32)

Encryption in transit (TLS) across the site, app, and API.
Passwords hashed with bcrypt (cost factor 12); sessions in httpOnly cookies.
Role-based access control (RBAC) for workspaces and admin actions.
Admin actions are logged in an audit trail.
Regular backups with time-limited retention.

3. Privacy contact (no dedicated DPO)

No dedicated Data Protection Officer (DPO) has been appointed. Privacy contact: Maciej Zmitrukiewicz · rodo@cometweb.io (also iod@cometweb.io). Rights requests — response in 72h, substantive decision within 30 days.

4. List of sub-processors

Stripe Payments Europe Ltd. Payments IE Stripe DPA ↗
Hostinger International Ltd. Hosting (EU servers) LT / DE Hostinger DPA ↗
Resend Inc. Transactional e-mail US (SCC) Resend DPA ↗
Google LLC (Tag Manager / Analytics 4) Marketing-site tag container and traffic analytics (consent) US (SCC) Google Ads Data Processing Terms ↗
Microsoft Corporation (Clarity) Marketing-site UX analytics / session replay (consent; inputs masked) US (SCC) Microsoft Products and Services DPA ↗

5. Data Protection Impact Assessment (DPIA)

We assess the privacy impact of features that process personal data before shipping them. Documentation available on request.

6. Breach notification procedure

We notify the supervisory authority within 72 hours and the affected users. Security vulnerability reports (product or cometweb.io): email security@cometweb.io — we reply on business days, 09:00–17:00 CET. Please do not include customer personal data unless required to reproduce the issue.

Document version 4.3 · Effective from 2026-08-05