Privacy Policy

1) Information on the Collection of Personal Data and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website and our services. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is:

[LEGAL ENTITY NAME]

[STREET AND NUMBER]
[POSTCODE] [CITY]
Germany

Email: support@stealthlink.co

The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data Collection When You Visit Our Website

2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called “server log files”). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:

• Our visited website
• Date and time at the moment of access
• Amount of data sent in bytes
• Source/reference from which you came to the page
• Browser used
• Operating system used
• Screen resolution
• IP address used (anonymized)

Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently if there are any concrete indications of illegal use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.

3) Hosting & Content Delivery Network

Kinsta

Our website is hosted by Kinsta Inc., 8605 Santa Monica Blvd #92581, West Hollywood, CA 90069, USA. For more details, visit Kinsta’s privacy policy: https://kinsta.com/legal/privacy-policy/.

The use of Kinsta is based on Art. 6 (1) point f GDPR. We have a legitimate interest in displaying our website as reliably as possible. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) point a GDPR and § 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

A data processing agreement has been concluded with Kinsta. For data transfers to the USA, Kinsta participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

Cloudflare

We use a content delivery network offered by the following provider: Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. For more details, visit Cloudflare’s privacy policy: https://www.cloudflare.com/privacypolicy/.

This service enables us to deliver large media files such as graphics, page content or scripts faster via a network of regionally distributed servers. The processing is carried out to protect our legitimate interest in improving the stability and functionality of our website pursuant to Art. 6 (1) point f GDPR. We have concluded an order processing agreement with the provider, ensuring the protection of our site visitors’ data and prohibiting unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

4) Content Management & E-Commerce

We use WordPress and WooCommerce, both of which are owned and developed by Automattic Inc., as our Content Management System (CMS) and e-commerce tool stack. For more information about their privacy policies, please visit: https://automattic.com/privacy/. These open-source solutions are installed and operated by us on our own hosting (see section 3), ensuring that we have full control over how your personal data is handled. They use personal information and cookies to achieve their functionality. You can find more details about the use of cookies and other storage mechanisms in the sections below.

WordPress

Our website is built and managed using WordPress, a widely used content management system (CMS). WordPress may collect certain data automatically, such as IP addresses, browser type and access times, through the use of cookies, which help improve the performance and security of our website. It is important to note that WordPress runs on our own server and not on Automattic’s systems. Additionally, we may employ various plugins that extend the functionality of WordPress. These plugins might collect additional data for features such as analytics, performance optimization, security and user experience improvements.

The data collected via WordPress and its plugins is processed to maintain and optimize the functionality of our website, ensure security (such as preventing unauthorized access or attacks), and analyze performance to improve the user experience.

WooCommerce

Our website uses WooCommerce, an open-source e-commerce platform that allows us to provide you with the ability to browse and purchase products or services online. WooCommerce is integrated into our WordPress website, and while WooCommerce itself does not collect personal data beyond what is necessary for the functioning of its core services, it facilitates the collection of personal information during the checkout and account creation process. Below, we outline how WooCommerce collects, processes and stores data, and how it interacts with other services.

When you place an order through our website using WooCommerce, we collect the following types of personal data, which are necessary to process and fulfill your order:

• Personal Identifiable Information (PII): This includes your name, company name (if applicable), billing address, VAT ID (if provided), email address and phone number. These details are necessary for processing your order, issuing invoices, calculating the applicable tax, and contacting you about the order if needed.
• Order Information: This includes details of the products and subscriptions you have purchased, the purchase date, renewal dates, account balance top-ups and the payment status.
• Payment Information: Depending on the payment method selected (e.g. card payment), WooCommerce collects payment-related details, such as partial card information or a transaction ID. WooCommerce does not store full payment card details on our servers, as we use third-party payment providers (see section 7).

The processing of this data is carried out under Art. 6 (1) point b GDPR (necessary for the performance of a contract). This means we collect and process this information solely for the purposes of fulfilling your purchase or responding to your inquiries related to the services you request.

5) Data Processing When Opening a Customer Account and for Contract Processing

Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed to the extent required in each case if you provide us with this data when opening a customer account. The data required for opening an account can be found in the input mask of the corresponding form on our website. Deletion of your customer account is possible at any time and can be done by sending a message to support@stealthlink.co. After deletion of your customer account, your data will be deleted, provided that all contracts concluded via it have been fully processed, no legal retention periods are opposed and no legitimate interest on our part in the continued storage exists.

6) Newsletter and Marketing Communications

If you have given us your express consent pursuant to Art. 6 (1) point a GDPR, we will use your email address, first name and last name to send you marketing communications, including notifications about sales, product updates and stock availability. Consent can be given either during registration or subsequently via your account dashboard.

Brevo

We use Brevo (Sendinblue SAS, 17 rue Salneuve, 75017 Paris, France) to send transactional emails (e.g. order confirmations, invoices, renewal and account notices) and marketing emails. Transactional emails are sent on the basis of Art. 6 (1) point b GDPR, as they are necessary for the performance of our contract with you. Brevo processes data primarily within the European Union. Where data is transferred to countries outside the EU, this takes place on the basis of appropriate safeguards pursuant to Art. 46 GDPR, such as the EU Standard Contractual Clauses. A data processing agreement has been concluded with Brevo. For more details, visit Brevo’s privacy policy: https://www.brevo.com/legal/privacypolicy/.

Brevo may collect information about whether marketing emails were opened and which links were clicked, for the purpose of measuring engagement and improving our communications. This processing is likewise based on your consent pursuant to Art. 6 (1) point a GDPR.

You may withdraw your consent at any time, with effect for the future, by clicking the unsubscribe link included in every marketing email, or by adjusting your preferences in your account dashboard. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Your data will be stored for this purpose until you withdraw your consent.

7) Processing of Data for the Purpose of Order Handling

7.1 Insofar as necessary for the processing of the contract for payment purposes, the personal data collected by us will be passed on to the commissioned payment service provider in accordance with Art. 6 (1) point b GDPR.

If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact data (name, address, email address) provided by you when placing the order in order to inform you personally by suitable means of communication (e.g. by email) about upcoming updates within the legally stipulated period of time within the framework of our statutory duty to inform pursuant to Art. 6 (1) point c GDPR. Your contact details will be used strictly for the purpose of informing you about updates owed by us and will only be processed by us for this purpose to the extent that this is necessary for the respective information.

In order to process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information. Data that is processed by the provider after you initiate a payment with them is outside our influence and subject to the provider’s own privacy policy.

7.2 Use of Payment Service Providers

Stripe

Online payment methods from the following provider are available on this website: Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland. For more information, please visit Stripe’s privacy policy: https://stripe.com/privacy.

If you select a payment method of the provider (e.g. card payment), your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose. For subscriptions, Stripe stores your payment method so that recurring renewals can be charged automatically until you cancel.

We also use Stripe Tax to calculate the VAT or sales tax that applies to your order. For this purpose, your billing address, country and, if provided, your VAT ID are passed on to Stripe in accordance with Art. 6 (1) point c GDPR (compliance with our tax obligations).

8) Technical Usage Data, Logging and Abuse Prevention

8.1 Processing of Technical Usage Data

When you use our Services, we may process technical usage data and metadata to the extent necessary for the provision, operation, security, stability, troubleshooting and protection of our Services, as well as for fraud prevention, abuse detection, compliance and enforcement of our Terms and Conditions.

Depending on the Service and the technical setup, this may include:

• account identifiers, user identifiers and access credentials or access keys
• authentication events, login attempts and access timestamps
• source IP addresses and, where technically available and legally permitted, destination IP addresses, domains, ports or protocol information
• session identifiers, connection times, session durations and usage frequency
• traffic volumes, endpoint information, routing information and technical error data
• device information, security alerts, abuse reports and technical indicators of suspected misuse
• records relating to suspensions, restrictions, investigations and compliance reviews

8.2 Purposes and Legal Bases

The processing is carried out on the basis of:

• Art. 6 (1) point b GDPR, where processing is necessary to provide and operate the contracted Services;
• Art. 6 (1) point f GDPR, where processing is necessary for our legitimate interests in ensuring service security, stability, fraud prevention, abuse detection, troubleshooting, compliance and enforcement of our Terms and Conditions;
• Art. 6 (1) point c GDPR, where processing is necessary to comply with legal obligations.

8.3 Retention Period

Technical usage data and metadata are retained only for as long as reasonably necessary for the respective purpose. Unless a longer retention period is required by law or necessary in connection with a security incident, abuse investigation, legal claim or lawful authority request, such data will be deleted or anonymized once it is no longer needed for that purpose.

8.4 Disclosure to Authorities and Other Authorized Recipients

Where required by law or permitted on another valid legal basis, we may disclose relevant account information, technical usage data, metadata and communications to competent authorities, courts, regulatory bodies, law enforcement agencies, upstream providers, mobile network operators (o2 / Telefónica, Telekom and Vodafone) or other authorized recipients.

Such disclosure will only take place to the extent necessary and legally permitted.

8.5 No Guarantee of Complete Logging

Stealthlink does not guarantee that all activity is logged or that logs are complete. The scope of logging may vary depending on the Service, technical setup and applicable legal requirements.

9) Contacting Us

When you contact us (e.g. via contact form, email or Telegram), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.

The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.

Telegram

Our main support channel is Telegram (@stealthlinkproxy, https://t.me/stealthlinkproxy). If you contact us via Telegram, your messages, your Telegram username, profile name, profile picture and, depending on your privacy settings, your phone number are processed by us and by the provider of Telegram, which operates outside the EU. We have no influence on how Telegram processes your data; for details, visit Telegram’s privacy policy: https://telegram.org/privacy. The legal basis is Art. 6 (1) point f GDPR (our legitimate interest in fast and simple communication with our customers) and, where your request relates to a contract, Art. 6 (1) point b GDPR. If you do not want to use Telegram, you can contact us by email at support@stealthlink.co at any time.

10) Rights of the Data Subject

10.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:

• Right of access by the data subject pursuant to Art. 15 GDPR;
• Right to rectification pursuant to Art. 16 GDPR;
• Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
• Right to restriction of processing pursuant to Art. 18 GDPR;
• Right to be informed pursuant to Art. 19 GDPR;
• Right to data portability pursuant to Art. 20 GDPR;
• Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
• Right to lodge a complaint pursuant to Art. 77 GDPR.

To exercise your rights, contact us at support@stealthlink.co. If you are located outside the EU, you may have similar rights under the data protection laws of your country; we will handle your request in line with the law that applies to you.

10.2 RIGHT TO OBJECT

IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.

11) Duration of Storage of Personal Data

The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and – if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).

If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes their consent.

If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.

When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises their right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If personal data is processed for the purpose of direct marketing based on Art. 6 (1) point f GDPR, this data is stored until the data subject exercises their right of objection pursuant to Art. 21 (2) GDPR.

Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.

12) Cookies & Storage Items

In order to make your visit to our website more attractive and to enable the use of certain functions, we use storage items and cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called “session cookies”), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called “persistent cookies”). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.

If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

We use services from third-party partners, such as payment providers, which may set cookies that we cannot directly control. These cookies are set after you have accepted this Privacy Policy and clicked the order button, which either processes your information on our site or redirects you to the payment provider. In these cases, the responsibility for the use of cookies lies with the respective provider, and it is your responsibility to ensure that you are comfortable with how they handle your data before initiating payment.

You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

We use only necessary cookies and therefore do not collect an opt-in. The functionality and safety of our website will be limited if cookies are not accepted.