1. Introduction

Sapling IT Solutions Limited (trading as "Minerack", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal information when you use our free Minecraft server hosting services.

This policy applies to all users of our services, regardless of how you access them. By using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or use our services, we may collect:

• Account Information: Username, email address, password (encrypted)
• Profile Information: Display name, avatar, preferences
• Server Data: Minecraft server configurations, world files, plugin settings
• Communication Data: Support tickets, forum posts, feedback
• Payment Information: For premium services (processed by third-party payment providers)

2.2 Information We Collect Automatically

When you use our services, we automatically collect:

2.3 Information from Third Parties

We may receive information from:

• Social Media Logins: If you log in using Discord, Google, or other providers
• Analytics Services: Anonymous usage statistics from Google Analytics
• Security Services: Threat intelligence and fraud prevention data

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Provision

• Creating and managing your account
• Providing Minecraft server hosting services
• Processing your server configurations and data
• Enabling communication features (forums, support)
• Facilitating file uploads and downloads

3.2 Service Improvement

• Analyzing usage patterns to improve our services
• Developing new features and functionality
• Optimizing server performance and resource allocation
• Conducting research and analytics

3.3 Communication

• Sending service-related notifications and updates
• Responding to your inquiries and support requests
• Sending marketing communications (with consent)
• Providing important security and policy updates

3.4 Security and Compliance

• Protecting against fraud, abuse, and security threats
• Enforcing our Terms of Service and policies
• Complying with legal obligations and requests
• Monitoring for prohibited content or activities

4. Legal Basis for Processing

Under UK GDPR, we process your personal data based on the following legal grounds:

Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental rights and freedoms.

5. Sharing Your Information

We do not sell your personal information to third parties. We may share your information in the following limited circumstances:

5.1 Service Providers

We work with trusted third-party service providers who help us operate our services:

• Cloud Infrastructure: Server hosting and data storage providers
• Payment Processors: Stripe, PayPal for premium service payments
• Communication Tools: Email delivery services, support ticket systems
• Analytics Services: Google Analytics (anonymized data only)
• Security Services: DDoS protection, fraud prevention tools

These providers are contractually required to protect your data and use it only for the purposes we specify.

5.2 Legal Requirements

We may disclose your information if required by law or in response to:

• Court orders or legal proceedings
• Requests from law enforcement or regulatory authorities
• National security requirements
• Protection of our rights, property, or safety
• Prevention of fraud or illegal activities

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred as part of the transaction. We will notify you of any such change and ensure the new entity provides equivalent privacy protection.

5.4 Public Information

Some information may be publicly visible:

• Public forum posts and comments
• Public server listings (if you choose to list your server publicly)
• Username and public profile information

6. Data Retention

6.1 Retention Periods

We retain your personal information for different periods depending on the type of data:

6.2 Deletion Process

When retention periods expire or when you request deletion:

• Data is securely deleted from our systems
• Backups are purged according to our schedule
• Third-party processors are notified to delete data
• Anonymous or aggregated data may be retained for analytics

7. Data Security

We implement comprehensive security measures to protect your personal information:

7.1 Technical Safeguards

• Encryption: All data is encrypted in transit and at rest using industry-standard protocols
• Access Controls: Role-based access with multi-factor authentication required
• Network Security: Firewalls, intrusion detection, and DDoS protection
• Regular Updates: Security patches applied promptly across all systems
• Monitoring: 24/7 security monitoring and incident response procedures

7.2 Operational Safeguards

• Staff Training: Regular security and privacy training for all employees
• Background Checks: Security screening for personnel with data access
• Incident Response: Documented procedures for security breaches
• Regular Audits: Internal and external security assessments

7.3 Your Security Responsibilities

You can help protect your account by:

• Using a strong, unique password
• Enabling two-factor authentication if available
• Keeping your contact information up to date
• Reporting suspicious activity immediately
• Logging out of shared computers

8. Your Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights regarding your personal data:

8.1 Exercising Your Rights

To exercise any of these rights:

• Contact our Data Protection Officer at [email protected]
• Use the data management tools in your account dashboard
• Submit a request through our support system

8.2 Response Times

We will respond to your request:

• Within 1 month of receiving a valid request
• Within 3 months for complex requests (we'll explain any delay)
• Free of charge unless the request is manifestly unfounded or excessive

8.3 Right to Complain

If you're not satisfied with how we handle your data, you can lodge a complaint with:

• Information Commissioner's Office (ICO)
• Website: ico.org.uk
• Helpline: 0303 123 1113

9. Cookies and Tracking

9.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. We use cookies to enhance your experience and provide our services effectively.

9.2 Types of Cookies We Use

9.3 Managing Cookies

You can control cookies through:

• Cookie Banner: Manage preferences when you first visit
• Account Settings: Update cookie preferences anytime
• Browser Settings: Block or delete cookies directly

9.4 Third-Party Tracking

We use these third-party services that may set cookies:

• Google Analytics: Website usage analytics (anonymized)
• Cloudflare: Security and performance optimization
• Social Media: Embedded content from Discord, Twitter, etc.

10. Children's Privacy

10.1 Age Requirements

Our services are designed for users aged 13 and above. We do not knowingly collect personal information from children under 13 without parental consent.

10.2 Parental Controls

For users aged 13-17:

• We encourage parental involvement in account creation
• Parents can request access to or deletion of their child's data
• We provide additional privacy protections for younger users
• Server content is monitored for age-appropriate material

10.3 What to Do If You're Under 13

If you are under 13:

• Ask a parent or guardian to create an account for you
• Do not provide personal information without parental permission
• Use our services only under adult supervision

11. International Transfers

11.1 Data Storage Locations

Your data may be stored and processed in:

• United Kingdom: Primary data centers and offices
• European Union: Backup and redundancy systems
• Other Countries: Third-party service providers with adequate protection

11.2 Transfer Safeguards

When transferring data outside the UK/EU, we ensure protection through:

• Adequacy Decisions: Transfers to countries with adequate data protection
• Standard Contractual Clauses: EU-approved contract terms
• Certification Schemes: Privacy Shield successors or equivalent
• Corporate Rules: Internal policies for multinational transfers

11.3 Your Rights Regarding Transfers

You have the right to:

• Know where your data is being processed
• Object to transfers to specific countries
• Request details about safeguards in place
• Obtain copies of transfer agreements

12. Changes to This Policy

12.1 Policy Updates

We may update this Privacy Policy to reflect:

• Changes in our data processing activities
• New legal requirements or regulations
• Improvements to our services or security measures
• Feedback from users or regulators

12.2 Notification of Changes

When we make significant changes, we will:

• Update the "Last Updated" date at the top of this policy
• Send email notifications to registered users
• Display prominent notices on our website
• Provide at least 30 days' notice for material changes

12.3 Your Options

If you disagree with policy changes:

• You can object to the changes before they take effect
• You may withdraw consent for optional processing
• You can close your account if you no longer agree
• Your rights under previous versions remain protected

13. Contact Information

13.1 Data Protection Officer

Our Data Protection Officer oversees privacy compliance and handles data protection inquiries:

• Email: [email protected]
• Response Time: Within 48 hours for urgent matters
• Languages: English (other languages upon request)

13.2 Privacy Team

For general privacy questions and requests:

• Email: [email protected]
• Support Portal: Available through your account dashboard
• Response Time: Within 5 business days

13.3 Company Information

Sapling IT Solutions Limited
Trading as: Minerack
Company Registration: [To be inserted]
Registered Address: [To be inserted]
Email: [email protected]

13.4 Regulatory Authority

You can also contact our supervisory authority:

• Information Commissioner's Office (ICO)
• Website: ico.org.uk
• Phone: 0303 123 1113
• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Additional Information

Privacy by Design

We implement privacy by design principles in all our systems and processes, ensuring data protection is built into our services from the ground up rather than added as an afterthought.

Regular Reviews

We conduct annual reviews of our privacy practices, data processing activities, and this Privacy Policy to ensure continued compliance with applicable laws and best practices.

Employee Training

All employees receive regular training on data protection, privacy laws, and our internal policies to ensure your personal information is handled appropriately at all times.

Data Protection Impact Assessments

We conduct Data Protection Impact Assessments (DPIAs) for any new processing activities that may pose high risks to your privacy, implementing additional safeguards where necessary.