How CUZY processes personal data as a controller (this website, customer accounts, orders, support) and as a processor (the HumHub communities we host for our customers).
*Version 2.0, effective 1 October 2026. Replaces the "Privacy policy and terms and conditions of sale" of the former site; the conditions of sale now live in the [terms of service](https://www.cuzy.app/terms).*
## 1. Our two roles
**Controller.** For visitors of cuzy.app, holders of a customer account, buyers of module licenses or hosting subscriptions, and people who write to us, CUZY decides why and how data is processed.
**Processor.** For the members of a HumHub community hosted by CUZY, the customer who administers that community is the controller. CUZY processes members' data only on the customer's instructions, under the Data Processing Agreement accepted at subscription. Members should read the privacy policy published by their community's administrators.
## 2. Data we process as a controller
| Purpose | Data | Legal basis |
|---|---|---|
| Serving this website | IP address, user agent, requested pages, timestamps in server logs | Legitimate interest (security, operation) |
| Customer account on cuzy.app | Name, email, password (hashed), language, company details, consents with version and time | Contract |
| Orders and invoices | Billing name and address, VAT number, products, amounts, payment status; card data is processed by Stripe and never stored by CUZY | Contract; legal obligation (accounting) |
| Hosting subscription | Community name and address, plan, usage counters (members count, storage, emails), technical events, availability | Contract |
| Support | Ticket content, attachments, email address, license key or instance URL | Contract; legitimate interest |
| Service emails | Trial reminders, invoices, security and maintenance notices | Contract |
| Newsletter | Email address, if you opt in; unsubscribe link in every message | Consent |
| Fraud and abuse prevention | Hashed IP addresses of signups, disposable-domain checks, rate-limit counters | Legitimate interest |
| Operational AI assistance | Anonymized technical logs of the hosting platform and the text of support tickets, analyzed by an AI service to help our team respond; no member content | Legitimate interest |
We do not sell personal data and we do not use it for advertising.
## 3. Data we process as a processor
Hosted communities contain whatever their administrators and members put in them: profiles, posts, files, messages. CUZY stores and backs up this data, keeps the software running and updated, and accesses it only for support at the administrator's request (logged and visible to the administrators), to investigate an incident, or when required by law. Usage counters and technical health indicators reported to our operations tools contain no member data.
The Data Processing Agreement (Article 28 GDPR) describes instructions, confidentiality, security measures, sub-processors, assistance with members' rights, breach notification within 72 hours, deletion at the end of the contract and audit rights. It is accepted online with the subscription and available for download in the customer account.
## 4. Sub-processors and transfers
| Provider | Purpose | Location |
|---|---|---|
| Hetzner Online GmbH | Servers for cuzy.app and hosted communities | cuzy.app: Germany (EU). Hosted communities: the region chosen by the customer: Germany (EU), the USA or Singapore (APAC) |
| Backblaze, Inc. | Encrypted backups and customer exports | Storage in the same region as the community, except Singapore communities, whose encrypted backups are stored in the United States; US company under Standard Contractual Clauses |
| Cloudflare, Inc. | DNS for cuzy.app and community addresses; forwarding of replies sent to our service addresses (@account.cuzy.app, @news.cuzy.app) to our own mailboxes | Global; US company under the EU-US Data Privacy Framework |
| Stripe Payments Europe, Ltd. | Payments, invoices, VAT validation | Ireland (EU) |
| SMTP2GO (SMTP2GO Ltd) | Delivery of notification and service emails | EU sending infrastructure; company in New Zealand (adequacy decision) |
| Brevo SAS (formerly Sendinblue) | Sending our newsletter to people who opted in (email address only; no community member data) | France (EU) |
| Anthropic, PBC | AI assistance for incident analysis (anonymized logs) and support drafting (ticket text) | US, under Standard Contractual Clauses; no member content |
| External uptime monitor | Availability checks of cuzy.app (hostnames only) | EU or US depending on provider |
| Infomaniak Network SA | Our own mailboxes: everything you write to us (support, contact, security reports) is stored there | Switzerland (adequacy decision) |
**Before we add or replace a sub-processor** we announce it by email to every customer and on this page at least
30 days in advance. A customer who objects within those 30 days may terminate the affected service without
penalty; we do not charge for the remaining period. The list above is the current one and carries the date of
the version you are reading.
Hosting and backups of a community stay in the region its customer chose, except that backups of Singapore communities are stored in the United States because our backup provider has no Asian data center; they are encrypted before they leave the server. Customers whose members are in the European Union should choose the Germany (EU) region, which is the default and keeps hosting and backups inside the EU. Customers are informed before a sub-processor is added or replaced and may object under the Data Processing Agreement.
## 5. Retention
- Server logs: 7 days.
- Customer account: for the duration of the relationship, then deleted on request or after the inactivity period announced in the account.
- Orders and invoices: 10 years (accounting obligations).
- Support tickets: kept for the relationship, anonymized on request.
- Hosted community data: the community is archived about 30 days after the end of the subscription (it stops being reachable, the data is kept) and is deleted with its backups **at the latest 6 months** after that date. You can ask for deletion at any time before then, and we act on it. Trial communities are deleted 28 days after the trial ends and are not backed up.
- Customer exports: download links valid 24 hours, files deleted after 48 hours.
- Signup anti-abuse data: hashed, 90 days.
## 6. Cookies
cuzy.app loads no third-party scripts, fonts or trackers and uses no analytics cookies. The site, the customer area and the hosted communities set only strictly necessary cookies: the HumHub session cookie and the security (CSRF) cookie, which require no consent. If you choose a light or dark color theme, the choice is kept in your session or, when you are logged in, in your account settings.
## 7. Your rights
Under the GDPR you may access, rectify, erase and receive a copy of your data, restrict or object to some processing, and withdraw consent at any time. Customer account holders do most of this from their account; otherwise write to [contact@cuzy.app](mailto:contact@cuzy.app). We answer within one month. You may lodge a complaint with the Data Protection Commission (Ireland) or your local supervisory authority. Members of a hosted community should address requests to that community's administrators, whom we assist as their processor.
## 8. Security
Isolated environments per community, encryption in transit and for backups, least-privilege access, monitoring, tested restores and a documented incident process. The [security and reliability page](https://www.cuzy.app/security) describes the measures in detail.
## 9. Contact
CUZY, 80 St. Columbanus Road, Dundrum, Dublin 14, D14 WP98, Ireland. Privacy questions: [contact@cuzy.app](mailto:contact@cuzy.app). Security reports: [security@cuzy.app](mailto:security@cuzy.app).