User policy and Cookies policy

SELL.SYSTEMS LIMITED (Hong Kong CR 3314044 / BR 75668716) operates this platform and hosts all data on Hetzner data centers in Finland. Payments are processed via PayPal for fiat and Heleket for cryptocurrency, and every purchase results in a legal invoice.

We only collect account, learning/VPS usage, technical and payment confirmation data to deliver the service, secure the infrastructure, satisfy legal duties, and honor your GDPR/PDPO rights. No analytics or advertising cookies are used beyond the essential MoodleSession and MOODLEID cookies.

Introduction

Welcome to SELL.SYSTEMS (the “Site”). SELL.SYSTEMS LIMITED (“we”, “us”, “our”) is committed to protecting your privacy. This Privacy & Cookie Policy explains how we collect, use, and safeguard personal data when you use our Moodle-based learning platform and VPS hosting services. By continuing to use the Site, you acknowledge that you have read and agree to this Policy. If you do not agree, please discontinue use of the Site.

Contact: privacy@sell.systems

Who We Are

SELL.SYSTEMS LIMITED is registered in Hong Kong (CR No. 3314044, BR No. 75668716) with its office at Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong. We provide remote education and automation services globally. All production infrastructure is hosted on Hetzner Online GmbH’s data centers in Finland (EU).

Personal Data We Collect

  • Account data: name, email, username, hashed password, optional profile fields.
  • Learning & VPS data: enrollments, course progress, forum posts, assignments, VPS plan metadata, service logs.
  • Technical data: IP address, browser/device info, timestamps, essential cookies.
  • Payment confirmations: transaction ID, amount, currency, wallet address or email returned by PayPal or Heleket; we never store full card numbers or private keys.
  • Support communications: messages you send to us.

We do not collect sensitive data unless strictly necessary and consented, and we do not knowingly collect data from children under 16.

How We Use Personal Data

  • Provide and improve services (account management, course delivery, VPS provisioning, troubleshooting).
  • Communicate about service status, policy changes, reminders, and support responses.
  • Process payments and issue invoices (including crypto invoices via Heleket).
  • Secure the platform, enforce terms, prevent fraud/abuse.
  • Comply with legal obligations (tax, accounting, PDPO/GDPR requests).
  • Perform aggregate, non-identifying analytics to understand feature usage.
  • Other purposes only with your consent.

Legal Bases (EU/EEA)

We rely on contractual necessity, legitimate interests, legal obligations, and consent (for optional processing). You may withdraw consent at any time without affecting prior processing.

How We Share Data

  • Authorized SELL.SYSTEMS personnel and contractors under confidentiality.
  • Hetzner Online GmbH (Finland) as our infrastructure provider.
  • PayPal (fiat) and Heleket (crypto) for payment processing confirmations.
  • Email/SMS providers for transactional communications.
  • Regulators or law enforcement when legally required.
  • Successors in case of merger/acquisition, with notice.
  • Only with your consent for any other sharing.

We do not sell personal data or share it with advertisers.

International Transfers & Storage

Data is stored on Hetzner servers in Finland and accessed by our Hong Kong team under appropriate safeguards (e.g., SCCs). Remote collaborators access data only when necessary and under contract. By using the Site you consent to these transfers, and we protect your data regardless of location.

Retention

  • Active accounts: retained while services are used.
  • Inactive accounts: deleted or anonymized after a reasonable period.
  • Course/VPS artifacts: kept while needed for delivery or certification; VPS content is removed upon cancellation (users should back up their own data).
  • Invoices/transaction records: retained at least 7 years per Hong Kong law.
  • Backups: rolled over periodically; deleted data may persist until backups cycle out.

Cookies

We only use two essential first-party cookies:

  • MoodleSession – maintains your login session (deleted when you log out or close the browser).
  • MOODLEID – remembers your username for convenience (optional; can be refused).

No analytics, advertising, or third-party cookies are set. You may disable cookies via your browser, but the site may not function without MoodleSession.

Your Rights

You have the right to access, correct, delete, restrict, or port your personal data, object to processing, and withdraw consent. Contact privacy@sell.systems to exercise these rights. We may need to verify your identity and will reply within statutory deadlines.

Complaints

Contact us first. You may also lodge complaints with the Hong Kong Privacy Commissioner for Personal Data (PCPD) or your local Data Protection Authority (e.g., EU DPAs, UK ICO).

Security

We use HTTPS, hashed passwords, access controls, firewalls, monitoring, timely patching, and vendor DPAs. Incident response plans are in place, and affected users/regulators will be notified if breaches occur.

Changes

Last updated February 6, 2026. We will post updates here and notify users of significant changes. Continued use after changes constitutes acceptance.

Contact

SELL.SYSTEMS LIMITED, Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong. Email: privacy@sell.systems.

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