Privacy policy
This is our first version, written for the website and the waitlist. We'll update it as Pastel Cloud gets closer to launch, and we'll email people on the waitlist about any change that matters to them.
This policy explains what personal data we collect when you visit pastel.cloud, join the waitlist or report content, why we collect it, and what you can ask us to do with it. The short version: we collect as little as we can, and we never sell it.
Who we are
Pastel-Cloud OÜ is a private limited company registered in Estonia (registry code 17571600, Jõe tn 3-312, 10151 Tallinn, Estonia). We run pastel.cloud and the Pastel Cloud waitlist, and we are the controller of the personal data described here.
What this policy covers
This policy covers visits to pastel.cloud, joining our waitlist and reporting content. The Pastel Cloud service itself will have its own privacy policy when it opens; the sections marked as drafts below show what we plan for it. What we can and can't see inside the service is explained on How privacy works.
What we collect
| When | What we keep | Why |
|---|---|---|
| You join the waitlist | Your email address, your name if you give it, the consent text you agreed to, the page and time you agreed on, the page that sent you to us, and any campaign tags in the link you followed. | To email you about the launch, and to prove you asked us to. |
| You visit a page | The page address, the time, the website that linked to us (its name only), a rough device type, operating system and browser family, and a visitor code made by scrambling your IP address together with the day's date and a secret key, so the code changes every day. | To count visits and see which pages help people. |
We never store your IP address itself or your full browser identification string. Without the secret key the visitor code can't be turned back into an IP address, and codes from different days can't be linked. Our hosting providers' standard server logs may hold your IP address for a short time for security; we don't use them to identify you. We set no cookies of our own.
Waitlist details are stored encrypted, with keys that only we hold, so our hosting providers can't read them. They are readable only briefly while they travel: when you sign up, and when we send you an email. We don't log them.
Our emails don't track which links you click, and they don't track whether you opened them. If we ever offer open tracking, for example so you can be sure you saw an alert about your account, it will be something you switch on yourself.
Payments
Draft for the Pastel Cloud service, not yet reviewed by our lawyer. It applies once the service opens.
We never see your full card number. Our payment provider, Polar, processes your payment. Polar is the merchant of record: the seller named on your invoice. To run your subscription and send invoices, Polar shares these details with us:
- your email address and name;
- your billing name and billing address (always including your country);
- your tax number, if you give one;
- the billing and tax details on each order;
- for a saved card, the card type, its last four digits and its expiry month and year, never the full number.
Polar also sends the same email address and billing address to our servers in automatic notifications about your subscription. We use these details to provide the plan you bought (Article 6(1)(b) GDPR) and to keep the accounting records the law requires (Article 6(1)(c) GDPR).
What you publish
Draft for the Pastel Cloud service, not yet reviewed by our lawyer. It applies once the service opens.
When you publish a post, anyone with the link can read it, including our staff. Encryption protects your private workspace, not what you choose to publish. Your nickname appears with everything you publish. Copies kept by search engines or web archives are outside our control.
Our legal basis
- Waitlist emails: your consent (Article 6(1)(a) of the General Data Protection Regulation, GDPR). You can withdraw it at any time.
- Visit counts: our legitimate interest in understanding how the site is used, with the protections described above (Article 6(1)(f) GDPR).
Confirming and leaving the waitlist
After you sign up we send one email asking you to confirm. Until you do, we won't send anything else, and the confirmation link expires after 48 hours. Every email we send has an unsubscribe link that works in one click. When you unsubscribe we keep a note that you did, so we never email you again. Ask us and we'll delete that too.
Content reports
When you report content through pastel.cloud/report, we keep the address of the page you report (and, from it, the blog and nickname it belongs to), the kind of problem you chose, your explanation, your good-faith statement, and your name and email address if you give them. The form for child sexual abuse material doesn't ask for your name, and we don't keep one if it is sent. We also keep when the report arrived, how we handled it, our decision and its reason, and whether we sent you the emails described below. If you email a report to report@pastel.cloud instead, we keep your email and copy the same details into the same queue.
We don't store your IP address. To slow down floods of reports, our servers keep a scrambled form of each request's network address only in memory, for no more than an hour, and never write it to storage. Our hosting providers' standard server logs may hold your IP address for a short time for security, as described above. We don't link a report sent through the form to your own Pastel Cloud account or nickname.
We use what you send only to handle the report, as Article 16 of the European Union's Digital Services Act requires. That legal duty is our legal basis (Article 6(1)(c) GDPR). Within Pastel-Cloud OÜ, only the staff who handle reports see them. We don't tell the person you report who you are, unless the law requires it, for example for some copyright claims.
When a report arrives, we email its details to our own report inbox, so the staff who handle reports see it quickly. That email includes the page address and your explanation, but never your name or email address, only whether you left one. AnyPost, which delivers our emails, carries it.
If you give an email address, we email you a receipt and, later, our decision. AnyPost, which delivers our emails, receives your address to send them. So that nobody can use the form to flood someone's inbox, we send no more than three receipts to the same address in 24 hours; to count them, we keep a scrambled form of the address in memory only, for no more than 24 hours.
We keep a report, and its copy in our report inbox, while we handle it and for as long as our decision can still be challenged, then delete them: [retention period to confirm]. Reports, and questions about a report: report@pastel.cloud.
Who helps us
We use a few providers who process data on our behalf:
- Cloudflare hosts this website.
- Fly.io runs our servers. Our API runs in Frankfurt, Germany.
- AnyPost delivers our emails, so it receives your email address and name.
- Polar processes payments for paid plans, as described under Payments. (Draft, not yet reviewed by our lawyer.)
Some of these companies are based outside the European Economic Area. Where data leaves it, we rely on the safeguards the GDPR requires, such as the European Commission's standard contractual clauses.
How long we keep it
Waitlist details stay until you unsubscribe or ask us to delete them, or until we close the waitlist. Visit records are kept only for a short time. After that only totals remain, such as how many people opened a page on a given day, which can't be tied to anyone. We'll state the exact period here when the service launches.
Your rights
You can ask to see, correct, export or delete your data, to limit how we use it, or object to it being used. Write to privacy@pastel.cloud and we'll answer within one month.
If you think we've handled your data wrongly, you can complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or the data protection authority where you live.
Changes to this policy
If we change this policy we'll update the date at the top. If the change matters for people on the waitlist, we'll email them before it applies.
Contact
Pastel-Cloud OÜ, registry code 17571600, Jõe tn 3-312, 10151 Tallinn, Estonia. privacy@pastel.cloud. You can write to us in English or Estonian.