We hold your data carefully — and only what we need.
Last updated: February 2026
1. Who we are (joint controllers)
This privacy notice is issued jointly by:
- Intellix IT Solutions Limited — UK parent, registered in England & Wales. Address: 82A James Carter Rd, Mildenhall, Bury Saint Edmunds, IP28 7DE, United Kingdom. Controller for personal data of UK residents.
- Cloudvoro Ltd — Irish subsidiary, registered in Ireland. Address: 1 Emmett St, Thurles Townparks, Thurles, Co. Tipperary, E41 YH05, Ireland. Controller for personal data of EU/EEA residents.
The two entities operate this website jointly. You can reach the Data Protection Officer at hello@cloudvoro.com.
2. What personal data we collect
We only collect what we need to deliver the service you asked for. Concretely:
2.1 Contact form & lead enquiries
- Your name, work email, company name, optional phone number.
- The free-text message you submit.
- The consent text shown to you at submission, with a server-side timestamp.
- The interest tag (e.g. cybersecurity-audit, scan-full-report) attached to the enquiry.
- The IP address and User-Agent string of the device that submitted the form — recorded once, only with the submitted lead, to evidence consent and to deter abuse.
2.2 Free Attack Surface Scan
- The domain you submit for scanning (this is not personal data in itself, but is logged).
- The IP address that initiated the scan, the country derived from that IP, the User-Agent string, and the timestamp.
- The computed grades (A–F per control family + overall) and the count of findings.
- The industry label you optionally select for benchmarking comparison.
Scan log entries are retained for 90 days. After 90 days, we keep only the aggregated, anonymised industry-benchmark statistics (the rolling average grade per industry) — never the domain, IP or user-agent. See Data Processing for the full pipeline.
2.3 Administrator authentication
- Staff email + bcrypt password hash.
- Optional WebAuthn passkey credentials (public key + sign counter — never the private key, which stays on the device).
- Optional TOTP (Authenticator app) secret, stored encrypted; single-use recovery codes stored as bcrypt hashes.
- HttpOnly authentication cookie (24h expiry), brute-force-attempt audit, immutable audit log of admin actions (12 months).
2.4 Visitor analytics (first-party only)
- We do not embed Google Analytics, Facebook Pixel, LinkedIn Insight Tag, Hotjar or any third-party tracker.
- We record a privacy-preserving first-party visit row per page view: timestamp, country (derived from IP at request time, IP not stored long-term in the visit row), the page path and referrer.
- Visit rows are retained for 12 months on a TTL index and automatically deleted.
3. Why we collect it (legal basis under GDPR Art. 6)
- Consent — Art. 6(1)(a): for contact-form submissions and PDF report requests. The consent text shown is recorded with a server timestamp. You can withdraw consent at any time by emailing hello@cloudvoro.com.
- Legitimate interests — Art. 6(1)(f): to operate the CMS, to log scans for abuse-prevention and aggregate benchmarking, to record admin actions for audit, and to deter brute-force login attempts. We've balanced this against your reasonable expectations — see Data Processing.
- Contract — Art. 6(1)(b): once you become a paying client, processing necessary to deliver the engagement.
- Legal obligation — Art. 6(1)(c): where Irish or UK tax, anti-fraud or law-enforcement legislation requires us to retain or disclose information.
4. Retention periods
- Contact-form / lead enquiries: 24 months from last contact, then deleted.
- Free-scan raw log (domain, IP, UA, grades): 90 days, then deleted; anonymised aggregate persists.
- Visitor analytics rows: 12 months, auto-deleted by TTL index.
- Authentication cookies: 24 hours.
- Admin audit log: 12 months.
- Brute-force login attempts: 30 days, then auto-purged.
- Paying-client engagement records: 6 years per Irish & UK tax and statutory limitation requirements.
5. Your rights (GDPR Arts. 15–22)
- Access — request a copy of personal data we hold about you.
- Rectification — correct inaccurate data.
- Erasure ("right to be forgotten") — request deletion. We will action this within 30 days unless we have an over-riding legal obligation.
- Restriction — limit how we process your data.
- Data portability — receive your data in a structured, machine-readable format.
- Object — to processing based on legitimate interests, including profiling.
- Withdraw consent at any time, without prejudice to processing already carried out lawfully.
- Lodge a complaint with the Irish Data Protection Commission (dataprotection.ie) or the UK Information Commissioner's Office (ico.org.uk).
To exercise any of these rights, email hello@cloudvoro.com. We respond within the 30-day window required by Art. 12(3) — usually within 5 working days. We do not charge for routine requests.
6. Cookies & similar technologies
This site uses a minimal set of strictly-necessary first-party cookies. We do not set advertising or analytics cookies without your explicit consent. See the dedicated Cookie Policy for the full inventory (name, purpose, expiry, controller).
7. Sub-processors & third-party services
We use a small, deliberately-scoped set of sub-processors for hosting, email delivery and edge protection. The full list — name, role, jurisdiction, transfer mechanism, contractual basis — is published on the Subprocessors page and updated whenever we change a vendor.
8. International transfers
Personal data is hosted in EU jurisdiction (Ireland or other EU member state) for Cloudvoro and in the UK for Intellix. Where a sub-processor or vendor sits outside the EU/UK (a small minority of our stack), transfers are protected by Standard Contractual Clauses (SCCs) under EU Commission Decision 2021/914 and the UK International Data Transfer Addendum. The subprocessor page indicates this per vendor.
9. Security
Designed against ISO/IEC 27001:2022. We do not currently hold a formal ISO 27001 certification. Specific controls in place:
- All data encrypted in transit (TLS 1.3) and at rest (AES-256 at the storage layer).
- Passwords stored as bcrypt hashes with current work-factor; never reversible.
- Multi-factor authentication required for every staff account (WebAuthn passkeys or TOTP).
- Brute-force login attempts rate-limited and locked out; every admin action is logged immutably.
- Public OpenAPI schema is suppressed in production to reduce information disclosure.
- Edge protection via Cloudflare; security headers (CSP, HSTS, frame-ancestors, Referrer-Policy) enforced site-wide.
- Quarterly access review of every staff credential.
- Vulnerability disclosure policy at /.well-known/security.txt — researchers can report safely without legal risk.
10. Children's data
This site is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has submitted information through this site, email hello@cloudvoro.com and we will delete it.
11. Automated decision-making
The free attack-surface scan produces an automated A–F grade. The grade is informational, does not produce a legal or similarly-significant effect on you, and is not used to make decisions about access to services. You are not subject to Art. 22 automated decision-making.
12. Changes to this notice
We will update this notice when our practices change. Material changes are dated at the top. If you have an active engagement with us, we will email you when a material change affects you.
13. How to contact us
Postal address (EU controller): Cloudvoro Ltd, 1 Emmett St, Thurles, Co. Tipperary, E41 YH05, Ireland.
Postal address (UK controller): Intellix IT Solutions Limited, 82A James Carter Rd, Mildenhall, Bury Saint Edmunds, IP28 7DE, United Kingdom.
