This policy explains what personal data SiteBunker processes, why, on what legal basis, how long we keep it and what rights you have. It follows Regulation (EU) 2016/679 (“GDPR”) and Romanian Law no. 190/2018.
Our principles
SiteBunker is a web services provider that receives and stores customers’ personal data in accordance with European Union law. We process data under the principles of Article 5 GDPR:
lawfully, fairly and transparently;
only for specified, legitimate purposes, with no further processing incompatible with them;
adequately, relevantly and limited to what the purpose requires;
accurately and kept up to date, with inaccurate data corrected or erased promptly;
kept only as long as the purpose requires (exact periods are in section 3);
confidentially and securely;
without disclosure to third parties, except those needed to provide the services or required by law (section 6).
1. Who we are
The data controller is EXIM HOST S.R.L., operating the SiteBunker brand (sitebunker.net, sitebunker.ro, client.sitebunker.net).
Registered office: Str. Frunzei nr. 109, bl. 9G, sc. 4, et. 1, ap. 64, camera 1, Galați, Romania
This policy covers visitors to our websites, customers and prospective customers, contact persons of business customers, and affiliate partners.It does not cover data that customers store on our hosting services (websites, databases, mailboxes). For that data the customer is the controller and we act as processor, under our Data Processing Agreement (DPA).
3. What we process, why and for how long
Purpose
Data
Legal basis (Art. 6 GDPR)
Retention
Creating your client account and providing services
Name, e-mail, phone, address, company and tax ID, login credentials
Performance of contract – Art. 6(1)(b)
Duration of the contract plus 3 years (general limitation period)
Domain registration and renewal
Registrant and domain contact data
Performance of contract – (b)
Duration of the registration plus 3 years; registries keep data under their own rules
Invoicing and accounting
Billing data, invoices, payment history
Legal obligation – (c) (Romanian Accounting Law 82/1991, Fiscal Code)
Up to 10 years, as required by accounting law
Online payments
Transaction ID, amount, status, last 4 card digits (we do not store full card details)
Contract – (b); legal obligation – (c)
Up to 10 years, as an accounting record
Answering questions and technical support
Ticket and e-mail content, contact details
Performance of contract – (b); legitimate interest – (f)
Duration of the contract plus 3 years
Service security, diagnosing technical issues and abuse prevention (access and security logs)
IP address, date and time, requested resource, browser, login events, firewall events
Legitimate interest – (f)
30 days, after which logs are deleted automatically
Security incident investigation
Logs relevant to a specific incident
Legitimate interest – (f); legal obligation – (c)
Until the investigation or related legal proceedings close
Order fraud prevention
IP address at checkout, order details
Legitimate interest – (f)
Duration of the contract plus 3 years
Marketing: newsletter and offers
E-mail, name
Consent – (a); for existing customers, similar services under Art. 12 of Law 506/2004
Affiliate identity and payout details, referral cookie
Performance of contract – (b)
Duration of participation plus 3 years; payouts, 10 years
Responding to authorities
Data lawfully requested
Legal obligation – (c)
As required by law
Legal claims
Data relevant to the dispute
Legitimate interest – (f)
Duration of the dispute until all appeals are exhausted
Access logs that a customer chooses to archive in their own hosting account (via cPanel › Raw Access) are managed by that customer, as controller.When these periods end, data is deleted or anonymised. Backup copies are overwritten automatically within 7 days at most.
4. Where we get data from
Most data comes directly from you, through forms, your client account or support. Technical logs are generated automatically by our servers. Some data may come from domain registries, payment processors or affiliate partners.
5. Is providing data mandatory?
Data needed for the contract, invoicing and domain registration is mandatory; without it we cannot provide the service. Newsletter and analytics data is optional.
6. Who we share data with
Recipient category
Examples
Why
Domain registries and registrars
ICI – RoTLD (.ro), EURid (.eu), eNom (international domains)
Domain registration; data may appear in WHOIS under each registry’s rules
Payment processors
ING Bank, Stripe, PayPal
Processing online payments
Web analytics
Google (Analytics, Tag Manager)
Traffic statistics, with consent only
DDoS and network protection
Voxility
Filtering malicious traffic
Server software vendors
cPanel (WebPros), CloudLinux
Technical support for the hosting platform, only when needed
Advisers
Accountant, lawyer, auditor
Legal obligations, legal claims
Public authorities
Tax authority (ANAF), courts, law enforcement, ANSPDCP
Only upon a lawful request
Providers processing data on our behalf are bound by contracts compliant with Article 28 GDPR. We do not sell personal data.
7. Transfers outside the European Economic Area
Some recipients (Google, Stripe, PayPal, eNom, cPanel, CloudLinux) may process data in the United States. These transfers rely on the European Commission’s adequacy decision for the EU–US Data Privacy Framework, for certified companies, or on Standard Contractual Clauses. You may request a copy of the applicable safeguards at contact@sitebunker.ro.
8. Automated decisions
We do not make decisions based solely on automated processing that produce legal effects for you. Automated anti-abuse and anti-malware systems may temporarily block suspicious access; you can always ask for a human review.
9. How we protect data
We use encrypted connections (HTTPS/TLS), firewalls, DDoS protection, security monitoring, malware scanning, strict staff access control and backups. Our servers are hosted in a Tier III data centre in Romania. Staff with access to data are bound by confidentiality obligations.
10. Your rights
You have the right to:
access your data and obtain a copy;
rectify inaccurate data;
erasure, where data is no longer needed or processed unlawfully;
restrict processing;
data portability for data you provided, in a structured format;
object to processing based on legitimate interest and, at any time, to direct marketing;
withdraw consent, without affecting earlier lawful processing.
Send your request to contact@sitebunker.ro. You can also ask us there whether we have processed your data at a third party’s request. We reply within one month, extendable by two months for complex requests. We may ask you to confirm your identity, usually via the e-mail linked to your account.You may lodge a complaint with the Romanian supervisory authority, ANSPDCP, B-dul G-ral Gheorghe Magheru 28–30, Sector 1, Bucharest, www.dataprotection.ro, anspdcp@dataprotection.ro, or with the supervisory authority in your EU country of residence.
11. Children
Our services are intended for persons aged 18 or over. We do not knowingly collect data from minors.
12. Cookies
Details on cookies and how to manage your choices are in our Cookie Policy.
13. Changes
We may update this policy. The current version is published on this page with its last-updated date. Material changes are notified to customers by e-mail.
Cookie Policy
We use strictly necessary cookies without consent and analytics cookies only after you accept them. The legal basis is Article 4(5) of Romanian Law 506/2004 (implementing the ePrivacy Directive) and the GDPR. The controller is EXIM HOST S.R.L., VAT ID RO40672655.
What cookies are
Cookies are small text files saved by your browser on your device. They let the website work properly, remember your preferences and show us, in aggregate, how it is used.
Cookies we use
Cookie
Provider
Category
Purpose
Duration
wp-wpml_current_language
sitebunker.net
Strictly necessary
Remembers your chosen language
Session
WHMCS[random code]
client.sitebunker.net
Strictly necessary
Client area session and shopping cart
Session
WHMCSAffiliateID
client.sitebunker.net
Strictly necessary for the affiliate program
Credits your order to the referring affiliate
90 days
Consent cookie
sitebunker.net
Strictly necessary
Stores your cookie choices
12 months
_ga
Google Analytics
Analytics
Distinguishes unique visitors
2 years
ga[ID]
Google Analytics
Analytics
Keeps session state
2 years
If we enable other tools (for example marketing pixels), we add them to this table before they go live.
Consent
On your first visit we show a banner where you can accept, reject or choose cookie categories. Rejecting is as easy as accepting. Analytics cookies are not loaded until you accept them. You can change your choice at any time via the “Cookie settings” link in the page footer.
Google Analytics
We use Google Analytics 4 (a service provided by Google) with Google Consent Mode. Without consent, no analytics cookies are set. Analytics data is kept for 14 months. It may be transferred to the US as described in section 7 of our Privacy Policy. Details: Google’s privacy policy.
Managing cookies in your browser
You can delete or block cookies in your browser settings. Blocking strictly necessary cookies may prevent logging in to your client account or placing orders.
This agreement sets out the terms required by Article 28 GDPR under which EXIM HOST S.R.L. (Str. Frunzei nr. 109, bl. 9G, sc. 4, et. 1, ap. 64, camera 1, Galați, Romania; VAT ID RO40672655; Trade Register no. J17/481/2019), “SiteBunker”, as processor, processes personal data on behalf of the customer (“Customer”), as controller. It forms an integral part of the Service Agreement (Terms and Conditions) and applies automatically to every customer who stores personal data on SiteBunker services.
1. Subject matter and duration
1.1. SiteBunker processes the personal data that the Customer uploads or generates through web hosting, reseller, VPS, dedicated server and e-mail services (“Customer Data”).1.2. This agreement applies for the term of the contract and until Customer Data is deleted under section 9.1.3. Data that SiteBunker processes for its own purposes (client account, invoicing, infrastructure security logs) is outside this agreement. For that data SiteBunker is controller, as described in the Privacy Policy.
2. Nature and purpose of processing
Item
Description
Nature of processing
Storage, hosting, e-mail transmission, backups, restores, malware scanning, website access logs, technical support at the Customer’s request
Purpose
Solely to provide the contracted services
Data categories
Any data the Customer stores: typically identification and contact data, user accounts, orders, e-mail correspondence, visitor IP addresses
Data subjects
The Customer’s visitors, customers, users, employees and correspondents
Special categories (Art. 9–10 GDPR)
Only if the Customer chooses to store them; the Customer is responsible for any additional safeguards
Processing location
Tier III data centre in Romania
For unmanaged VPS and dedicated servers, SiteBunker does not access server contents and provides only the physical and network infrastructure.
3. Customer instructions
3.1. SiteBunker processes Customer Data only on the Customer’s documented instructions. The contract, this agreement and the settings the Customer makes in the control panels (cPanel, client area) are the complete instructions.3.2. If SiteBunker believes an instruction infringes data protection law, it informs the Customer immediately.3.3. SiteBunker may process data without instructions only where the law requires it. In that case it informs the Customer beforehand, unless the law prohibits doing so.
4. Confidentiality
SiteBunker staff access Customer Data only when necessary for service delivery, support or security. All authorised persons are bound by contractual or statutory confidentiality obligations.
5. Security
SiteBunker applies the technical and organisational measures in Annex B, appropriate to the risk, under Article 32 GDPR. Measures may be updated provided the overall level of protection is not reduced.The Customer is responsible for the security of its own content: application updates, passwords, configuration and its own backups, as set out in the Terms and Conditions.
6. Sub-processors
6.1. The Customer gives general authorisation for the sub-processors listed in Annex A.6.2. SiteBunker notifies the Customer by e-mail of any new or replacement sub-processor at least 30 days in advance. The Customer may object on reasonable grounds within that period. If no solution is found, the Customer may terminate the affected services without penalty and receive a refund of prepaid fees for the unused period.6.3. SiteBunker imposes data protection obligations on sub-processors equivalent to those in this agreement and remains liable to the Customer for their acts.
7. Assistance to the Customer
7.1. Data subject rights. Most requests can be handled by the Customer directly in cPanel. If SiteBunker receives a request addressed to the Customer, it forwards it without delay and does not respond on the Customer’s behalf, unless required by law.7.2. Impact assessments and consultations. SiteBunker provides reasonable information needed for data protection impact assessments (Art. 35) and prior consultations with the supervisory authority (Art. 36).7.3. Assistance beyond standard information may be charged at the current technical support rates.
8. Personal data breaches
8.1. SiteBunker notifies the Customer without undue delay and within 48 hours at most of becoming aware of a breach affecting Customer Data.8.2. The notification includes, as far as available: the nature of the breach, the categories and approximate number of data subjects and records affected, likely consequences, measures taken or proposed, and a contact point. Missing information is provided as it becomes available.8.3. Notification is not an admission of fault. Notifying the supervisory authority and data subjects remains the Customer’s obligation as controller.
9. Deletion and return of data
9.1. The Customer can download its data at any time, including a full account archive generated in cPanel.9.2. After the service ends, or 30 days after an unpaid due date, Customer Data is deleted from production servers, as set out in the Terms and Conditions.9.3. Maximum retention after deletion or during normal operation:
Data
Maximum period
Daily backups (JetBackup)
7 days
Disaster recovery copies
7 days
Files quarantined by the anti-malware system
30 days
Website access logs kept by SiteBunker
30 days
Log archives that the Customer chooses to keep in its own cPanel account remain under the Customer’s control.9.4. SiteBunker may retain data longer only where the law requires it, isolating it from any further processing.
10. Audits
10.1. On the Customer’s written request, no more than once a year, SiteBunker provides the information needed to demonstrate compliance with this agreement, including answers to reasonable security questionnaires.10.2. If that information is insufficient or the supervisory authority requires it, the Customer may carry out an audit, directly or through an independent auditor bound by confidentiality. Audits require at least 30 days’ notice, take place during business hours, must not affect other customers and are at the Customer’s expense.
11. International transfers
Customer Data is stored in Romania. A transfer outside the EEA may occur only occasionally, when a support sub-processor listed in Annex A accesses a server to resolve a ticket, and only with appropriate safeguards under Chapter V GDPR: an adequacy decision (including the EU–US Data Privacy Framework) or Standard Contractual Clauses.
12. Final provisions
12.1. In case of conflict, this agreement prevails over the Terms and Conditions on data protection matters.12.2. Liability is as set out in the Terms and Conditions, without limiting data subjects’ rights under the GDPR.12.3. This agreement is governed by Romanian law. Disputes are resolved as set out in the Terms and Conditions.
Annex A – Sub-processors
Sub-processor
Service
Processing location
Transfer safeguards
Voxility
DDoS protection and traffic filtering
EU
Not applicable (EEA)
cPanel, L.L.C. (WebPros)
cPanel/WHM platform support, on request
USA
Standard Contractual Clauses / Data Privacy Framework
CloudLinux, Inc.
CloudLinux OS support, on request
USA
Standard Contractual Clauses / Data Privacy Framework
Domain registries and payment processors are not sub-processors for Customer Data; they receive data from SiteBunker acting as controller.
Annex B – Technical and organisational measures
Access control: administrative access for authorised staff only, two-factor authentication for admin panels, least privilege, periodic access reviews.
Network security: perimeter firewall, DDoS protection through continuous traffic analysis (Voxility, Arbor), brute-force protection for logins (cPHulk).
Encryption: TLS for control panels, e-mail and websites; SSL certificates available for all hosted domains.
Malware protection: continuous account scanning and automatic quarantine, with deletion after 30 days.
Backups: server RAID, daily off-site backups with up to 7 days’ retention, disaster recovery copies kept for 7 days.
Updates: operating system, cPanel and services regularly updated to stable releases.
Monitoring and logs: continuous server monitoring; access and security logs kept for 30 days and deleted automatically.
Physical security: Tier III data centre with controlled access, dual power feeds (UPS and generator) per rack, N+1 redundant cooling, three internet uplinks from different carriers.