Copibar platform privacy notice

Version 2026-11-07 · in force from 7 November 2026

This notice explains what happens to information about you when you use the customer portal my.copi.bar, write to support@copi.bar or send our "Talk to us" form, and how our staff work with that information. Our website copi.bar has its own privacy notice. The Copibar software runs on your own infrastructure. It sends nothing to this platform and is not covered here.

Who we are

The platform is run by XServer OÜ, registry code 17511911 (Estonian commercial register), VAT number EE102988554, Kaupmehe 7-120, 10114 Tallinn, Estonia ("we"). We decide how the data described here is used, so we are its controller. For anything about your data, write to privacy@copi.bar.

What we collect and why

Your account. To open an account, you give us your work e-mail address and a password and choose a language. We store the password only as a one-way hash, never in readable form, and we check it against a list of leaked passwords on our own server. We record which version of the terms of use you accepted and when, and when you confirmed your e-mail address. We do not ask for your name. If you turn on two-step sign-in, we store the secret key that your authenticator app shares with us.

Why: to give you the account and keep it secure. Legal basis: providing the account under our terms of use (GDPR Art. 6(1)(b)). If you use the account for your employer or another organisation, the basis is our legitimate interest in providing the account to that organisation (Art. 6(1)(f)). Do you have to: we cannot open an account without an e-mail address and a password. How long: while the account exists. If you never confirm your e-mail address, we delete the sign-up after 30 days. If an account is not used for 36 months, we warn you by e-mail and delete it 30 days later, unless it is linked to a licence or an unpaid invoice. What we keep after deletion is described under "Security and contract records".

Product news, only if you ask for it. If you tick the box at sign-up, we may send you product news, about once a month. Legal basis: your consent (Art. 6(1)(a)). You can withdraw it at any time with the link in any such e-mail or by writing to privacy@copi.bar. This does not affect what happened before. We keep your choice while the account exists.

Organisations and teams. When you set up an organisation, you give its legal name and country, say whether it is a company or a sole trader, and give your job role there. Its VAT number and the approximate number of hypervisor hosts are optional. We give the organisation a customer number. For each member we record:

• their role in the portal (Owner, Billing, Technical or Viewer);
• when they joined and who invited them;
• for owners, since when they hold the role and whether we have reminded them to turn on two-step sign-in.

When an owner invites someone, we get that person's e-mail address from the owner and send them an invitation. An unused invitation expires after 7 days. If you belong to several organisations, our server remembers which one you are working for: on your session, and on your account for mail to support@. For a company these details are mostly not personal data; for a sole trader they are.

Other members of an organisation see each member's e-mail address, role and job role. Owners also see whether a member uses two-step sign-in and when they were last active.

Legal basis: providing the account (Art. 6(1)(b)). For members acting for their organisation, and for invited people, the basis is the legitimate interest of the organisation and of us in letting a business manage who acts for it (Art. 6(1)(f)). How long: while the organisation exists. A membership ends when the member leaves or is removed. Invitations are deleted one day after they expire or are used.

Signing in. When you sign in, we create a session that records your IP address and your browser's identification string (user agent). A session ends when you sign out, after 24 hours without activity, and at the latest after 30 days. We delete it one day after it ends. To slow down password guessing and abuse, we count sign-in attempts and similar requests by e-mail address and IP address, and we delete these counts after 24 hours. After repeated failures we pause sign-in or the second step for a while, and we may tell you by e-mail. Legal basis: our legitimate interest in keeping accounts secure (Art. 6(1)(f), with Art. 32).

Security and contract records (audit log).

• Security records. We record the action, the time, your IP address and your browser's identification string when you sign in, fail to sign in, or change your password or two-step settings. We do the same when our staff act on your account. We keep the IP address and browser string for 12 months to detect and investigate attacks on accounts (our legitimate interest, Art. 6(1)(f)), and then delete them. Our tamper-evident audit log keeps a record that the action happened, linked to your account number but without those details. Where the log needs to refer to an e-mail address, it holds only a keyed code. We destroy the keys, so a code can no longer be matched to any address about 15 months after it was made at the latest. You can ask us to delete the IP address and browser string sooner. We will, unless they relate to a security incident or a legal claim we are handling; in that case we tell you why.
• Contract records. When you accept our terms of use, we record who accepted (your account and e-mail address), when, and which version. We keep this for 7 years after the end of the year in which you accepted, so that we can show which terms applied and establish or defend legal claims (Art. 6(1)(f)). If you later buy a licence, the period becomes 7 years after the end of the financial year in which your last paid licence term ends, because Estonian accounting law also requires it (Art. 6(1)(c)). We cannot delete these records on request, but we then use them only for those purposes. The IP address and browser string of the request in which you accepted are a security record, which we keep for 12 months.
• Money records. We do not sell yet, so there are no invoices or payments. When sales start, we will describe them here before we take the first order.

Support tickets. You can open a ticket in the portal or by e-mail to support@copi.bar. A ticket holds:

• the subject, your messages and your attachments;
• your e-mail address and, if your e-mail program sends one, your name;
• the language;
• our replies and internal notes.

Every member of an organisation can read the tickets opened for it. When a message arrives by e-mail, our mail server checks whether the sender's domain vouches for it (DMARC) and adds the result. We link a message to a customer account only if that check passes. Any other message is kept, marked "sender not verified", and not attached to any organisation. To protect the service, we count incoming messages per sender address and domain, and we delete these counts within two days.

Why: to answer and fix what you report, and to keep a record of the support we gave. Legal basis: providing the account and the support it includes (Art. 6(1)(b)). For people who write for an organisation or have no account, the basis is our legitimate interest in answering support requests (Art. 6(1)(f)). How long: 3 years after the ticket is closed. Files attached to messages that are not linked to an account are deleted after 30 days. Please send only the logs and files we need. Do not send us personal data of your own customers or users unless we have agreed how it will be handled.

The "Talk to us" form. When you send this form, we receive:

• your name and work e-mail address;
• the legal name and country of your business, whether it is a company or a sole trader, and, where we ask for it, the region;
• the number of hosts, the term and the currency you are interested in;
• if you give them, a VAT number, a purchase-order number and a message.

The form creates a sales request (lead) in our customer records, together with a contact and an organisation record, and we send you a confirmation by e-mail. Legal basis: steps you ask for before a possible contract (Art. 6(1)(b)). When you write for a company, the basis is our legitimate interest in answering business enquiries (Art. 6(1)(f)). How long: as for customer records, below.

Customer records. Our staff keep records about the businesses we deal with and the people we talk to there:

• organisation records;
• contacts: name, e-mail address, phone number, job title, language, whether the person handles billing or technical matters, and how they reached us;
• sales requests and opportunities;
• notes of calls, e-mails and meetings;
• tasks.

Most of this comes from you or your colleagues. Our staff may add business contact details from public sources, such as your organisation's website. Legal basis: our legitimate interest in managing our relationships with business customers and prospects (Art. 6(1)(f)). You can object at any time, and an objection to sales contact always stops it. How long: while your organisation is our customer. Otherwise, 24 months after our last two-way exchange, or 12 months if we contacted you and you never replied. Notes, activities and tasks are deleted with the record they belong to.

E-mails we send. The platform sends e-mail from our own mail server: address confirmations, password resets, invitations, security notices, ticket replies and notifications, and confirmations of sales requests. It keeps a copy of each message for 30 days after sending. In confirmation, password-reset and invitation e-mails, the one-time link is blanked from our copy as soon as the message has been sent. Legal basis: providing the account (Art. 6(1)(b)) and our legitimate interest in reliable and secure delivery (Art. 6(1)(f)).

Server logs. For each request to my.copi.bar, our web server logs:

• your IP address and the time;
• the request method, the address requested without its parameters, and the protocol;
• the response code and size;
• your browser's identification string.

It does not log the page you came from, and it does not log visits to the one-time links in our e-mails. For each message to support@copi.bar, our mail server logs the sender and recipient addresses, the IP address of the server that delivered it and the message identifier. The platform's own service log is kept on the same terms. Legal basis: our legitimate interest in running a secure, working service (Art. 6(1)(f)). How long: 14 days.

Requests about your rights. When you exercise a right listed under "Your rights", we record the request in a register:

• what kind of request it is and how it reached us;
• how we confirmed it was you;
• the due date and any extension;
• what we did: how many records were exported, deleted, restricted or kept, with reason codes;
• the outcome.

The register holds no copy of your data. It refers to you only by your account number or by a keyed code of your e-mail address. Legal basis: our legal duty to handle requests and to be able to show that we did (Art. 6(1)(c) with Arts. 5(2) and 12). How long: 3 years after the request is closed. Your e-mails to privacy@copi.bar and our replies are kept on our mail server and deleted 24 months after they were received or sent, in whatever folder they are kept. We read them in a mail app on our own devices.

Cookies. my.copi.bar sets no analytics or advertising cookies and loads nothing from other companies. It uses only these cookies, which the service you ask for needs (ePrivacy Directive Art. 5(3)):

• __Host-cbp_sess keeps you signed in. It lasts until you close the browser; the session itself ends as described above.
• __Host-cbp_pre protects forms against cross-site request forgery before you sign in. It lasts 12 hours.
• cbp_invite holds an invitation you opened while you sign in. It lasts 30 minutes.
• cs_sent shows the confirmation after the "Talk to us" form. It lasts 10 minutes.
• lang remembers the language you chose with the language switch. It lasts 1 year.

The staff backoffice uses session cookies of the same kind.

Staff. Our staff use a separate backoffice that cannot be reached from the internet. A staff account holds the staff member's name, e-mail address and passkeys. Staff sessions record the IP address and browser string. Every staff action is written to the audit log described above, on the same terms.

Backups. We back up the whole server every day and keep 7 daily and 4 weekly copies, so the oldest copy is about five weeks old at most. The platform also copies its database every hour and keeps these copies on the server for about two days; they are part of the daily backups. Everything described here therefore stays in backups for up to about five weeks after we delete it. We keep the backups ourselves, in the EU, and nobody else has access to them. We use them only to restore the server or the platform after a fault. We do not change backups; deleted data disappears from them when they expire. If we ever restore the platform from a backup, we first re-apply every deletion made since that backup was taken, before anyone uses the platform again.

We do not sell your data. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. Automatic limits only protect the service, for example pausing sign-in after repeated failures or treating mail that fails the DMARC check as unverified.

Who receives it

• Other members of your organisation, as described above.
• Our staff. Inside XServer OÜ only staff who need it can see customer data. Today that is our managing director alone.
• No hosting or other service provider. We run the platform and its mail server ourselves, on our own equipment in a data centre in Germany. The data-centre operator provides only space and power. We use no processors today.
• Spam filtering. As for all mail to copi.bar, our mail server checks the IP address of each server that delivers mail to support@copi.bar against a public DNS blocklist run by SpamCop (Cisco, USA). Each check discloses that server's IP address to SpamCop. This is normally your e-mail provider's server, not you. It relates to you only if you run your own mail server. Legal basis: our legitimate interest in protecting our mail service from spam and abuse (Art. 6(1)(f)).
• Authorities, courts and our professional advisers, when the law requires it or to establish or defend legal claims.
• Later, payment and invoicing providers. We do not sell yet. When we do, a payment provider and the other providers we need for payments and invoicing will receive the data needed for that. Before any of them receives data, we will name them in this notice, with their location and any transfer safeguard.

Transfers outside the EEA. The platform's data and its backups stay in the EU. Data leaves the EEA only through the spam check. SpamCop's operator, Cisco Systems, Inc. (USA), is certified under the EU–US Data Privacy Framework, which the European Commission found adequate (Implementing Decision (EU) 2023/1795 of 10 July 2023).

Your rights

You can ask us for access to your data and a copy of it, and ask us to correct it, delete it or restrict its use. You can receive the data you gave us under the terms of use, or with your consent, in a portable form. You can object at any time to processing based on our legitimate interest, and an objection to direct marketing always stops it. Where we rely on consent, you can withdraw it at any time.

Write to privacy@copi.bar. We may ask you to confirm that it is you, usually by replying from the e-mail address of your account or by opening a link we send to it. We do not ask for identity documents unless there is no other way. We record your request in our register and answer within one month of receiving it. If a request is complex, or you send several, we may extend this by up to two more months; we then tell you why within the first month. There is no charge.

• A copy of your data. We send one archive with JSON and CSV files from each part of the platform and the files you attached. It also explains the purposes, recipients, retention periods and your rights.
• Deletion. We delete or anonymise your account, your sessions, your sign-in counts, our copies of e-mails to you, your messages in tickets, your contact details and the text of notes about you in our customer records. We keep the records of your acceptance of our terms (and, later, invoices and payments), but use them only for legal duties and claims. The business facts of tickets and sales requests stay, without your details. People you invited keep their membership. If you are the only owner of an organisation, an anonymised owner entry stays so that the organisation is not left without an owner; you can make a colleague owner first. Deleted data disappears from backups when they expire (see "Backups").

You cannot yet download or delete your data from inside the portal; until you can, write to us.

If you think we handle your data wrongly, you can complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, info@aki.ee, www.aki.ee. You can also complain to the data protection authority where you live or work.

Changes

When we change this notice, we update the version and date at the top, and we keep every earlier version in our archive of legal documents. If a change matters for how we use your data, we tell account holders by e-mail before it applies. This notice is also available in Ukrainian and Russian; if they differ, the English version applies.