Privacy Policy

Last Update: 2022-08-10 // v.0.1

Introduction and Summary

This is the privacy policy for boscola.com. It describes how and why we collect, store, use, share and disclose (let's summarize it as "process") information about you when you use the website, its functions or even just consume its content (our "services"). Boscola.com is a website under construction.

So who is we? We are Codepals OÜ and we are responsible for the mentioned services. We are the owner and data controller of the personal data that is collected when you use the website. If you want to get in touch with us, you will find below some ways to do so.


Codepals OÜ
Sepapaja tn 6
15551 Tallinn
[email protected]

Services, Collected Data, Legal Background

Service: Website & Content Delivery

In this chapter we explain the more general functions of this website. The website is delivering content like this data privacy policy to you. Before you have read this propably you were on the main landing page. So we will explain what happens with data in such scenarios.

Data we are not processing

Actually in order to make this website work there is no data required that you have to input manually. So there is nothing special to mention here. We could have omitted this secion, but in order to stick to a certain structure that helps you to understand our structure, we decided to at least write something here.

Data we (and our infrastructure provider) process

No matter if you are consuming the landing page or you are just reading this privacy policy: Before you see something from our website, your browser sends requests to the server to get such content. Doing so it is also transferring meta data to the server, such as:

  • IP address
  • Browser type and version
  • Operating system type and version
  • The language used
  • The referral source

The IP address is considered as personal data and and can be used to identify you. E.g. if you would visit this website again in the next few hours it would be possible to see that it is the same person coming back to it. It would be possible to use this data for marketing purposes, but right now we are using it to make sure that our services are working as expected in a safe way. E.g. if there are a lot of requests to the server with the same IP address so that it looks like a hacker is trying to hack our website, we will block the request with help of this IP address. This is a security feature.

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Our service runs on infrastructure provided by Cloudflare

The whole infrastructure needed for our services runs on a platform provided by Cloudflare, Inc., a company based in the USA with headquarters in San Francisco. Cloudflare is a global leader in Internet security and privacy. They make sure that users from all over the world can access our services. In order to do so they use the IP address to deliver our content to you from the nearest server / node in their network and in order to make sure that hackers cannot access our services, by blocking certain IP addresses that are known for being used by hackers as we explained before.

You can find out more about Cloudflares privacy policy at: https://www.cloudflare.com/privacypolicy/.

Out of the IP address it is possible to derive the approximate location of the user (e.g. country, city, region). It is not possible to derive the exact location of the user, so you do not have to worry about this. We use the data aswell to improve our services. E.g. if we see that there are a lot of people using this service in a region where people speek different languages than English, we could offer different language versions of this service.

Especially as a startup it helps a lot to know where the users are coming from also in terms of marketing. Collecting this data in a way that is not related to personal data is therefore more or less required for us to make our services better and have a chance for long term success as a company.

Data Deletion / Data Retention

Your IP address is deleted in most cases directly on the same day from the server logs of Cloudflare. In case of troubleshooting / errors / hackerattacks an IP address might be stored longer. If you are a normal user and you face an issue it is very likely that it has nothing to do with Cloudflare but with a bug in our provided services. In such case we do not store anything and rely currently on feedback via email or other channels. In case that Cloudflare logs your IP for analyzing errors in their infrastructure they keep it for 1 week But they state in their website that

By default, Cloudflare does not retain your HTTP request logs. Cloudflare Documentation

Data transfers to third countries

Cloudflare operates its data centers worldwide to ensure fast delivery of our services to you. As mentioned before they process meta data and especially the IP address of your network device just for the purpose of operating the service and most data is deleted as described. As they are headquartered in the United States, they are bound also by the United States privacy and data protection laws which includes the Patriot Act. Therefore they have to cooperate with the US Government. As a result it would be possible that US authorities would be able to access the data mentioned above.

Service: Get in touch with us

We offer certain ways to get in touch with us: you can send us a mail, an email, call us on the phone. Doing so you also transfer data to us and over third party providers. So we will list most relevant here (and omit what we don't know, e.g. your own email provider, your countries post delivery, etc.):

Data we (and our third party providers) process

If you get in touch with us it is you who sends data to us and you therefore are in full control of what this data is. In order to process this data we store it, read it and delete it if we do not need it anymore.

Data Deletion / Data Retention

We delete your data if it is not needed anymore. This depends on the purpose that is more or less up to you when you contact us. In some cases there might be the need to contact you to inform you about something. E.g. if we answered an email but it turns out that half a year later this answer needs some refinement we assume that you would be interested in that. For direct marketing (e.g. we have a new feature that is especially useful for you) we would use your provided data (E-Mail address) for that purpose too. If you want us to delete your emails and related data (e.g. the address) you can refer to the next chapter.

Your Rights

Deletion of Data on Request

We have explained to you what data we process and how we use it and what measures we take to protect your data. One measure is to keep data not longer than needed. If in some case you want us anyway to delete your data before you can contact us for this purpose. This is especially the case if you want us to delete your mail or email data. The other data is anyway deleted before we would be able to do this manually.

Exporting / Transferring your Data

As we don't store data, there is no way of exporting it.

Find out what data is stored about you

You have the right to find out what data is stored about you. However we don't have anything personally identifiable about you. We only process the IP address of your network device for a very small period of time so that propably you ask us about it we already deleted it.

Withdraw Consent

You have the right to withdraw your consent to our use of your data. As mentioned before right now there is nothing much where we would need a consent anyway. If we ever need to use your data for a purpose that requires your consent we will ask you for it.

Correcting Data

You have the right to correct your data. However the only personal data that we process is the IP address of your network device. This makes no sense here but we thought it might be a good idea to inform you about this right anyway.

Lodge a complaint

You have the right to complain to a data protection authority. You can find out where to complain to by following this link.


We are not using cookies right now as we don't think it is necessary for this service at this stage. However we might add cookies later. If you want to be updated in case we use some special sort of cookies, e.g. for tracking your behaviour in a way not described before you will be notified anyway when you visit our website. At this moment we don't think it makes sense to annoy users by giving consent by a cookie banner first. We want to stand out by beeing simple. So we designed everything in such a way to not make use of cookies.

Web Beacons

Web beacons are small pieces of code that are embedded in web pages. Web beacons are used to track the behavior of visitors to a website. We are making use of a script that is provided by our mentioned provider Cloudflare. As you can read here those analytics are not related to your personal data such as IP address. We are using the web beacon to see how visitors interact with our website and to collect statistics e.g. where users are coming from (Country). We have a legitimate interest in this data and we use it to improve our website.

Data Security

We put a lot of effort into protecting your data... no! We actually make protecting your data a breeze by clever design decisions of our software. You can be assured after reading this privacy policy that we design our services with privacy and security in mind. In the few areas where necessary we work together with selected third party providers that share these values with us.

Others things to mention: When you are browsing on our website you can see that it is using https as protocol and that there is an TSL/SSL certificate by a trusted authority. This means that your telecommunication data is encrypted and that you can be sure that your data is not being accessed by a third party, e.g. your telecommunication provider or wifi hotspot.