Privacy policy

The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise we never sell your data: never have, never will.

This policy is split into sections. For your convenience, links to each of those sections is as follows:

This policy applies to all products built and maintained by Bartels Software Studio OÜ including Turbocache.

This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Bartels Software Studio OÜ). We refer collectively to these categories of individuals as "you" throughout this policy.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity & access

When you sign up for a Bartels Software Studio OÜ product, we ask for identifying information such as your name, email address, and maybe a company name. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We sometimes also give you the option to add a profile picture that displays in our products.

We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

If you sign up for a paid Bartels Software Studio OÜ product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit Bartels Software Studio OÜ servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.

Product interactions

We store on our servers the content that you upload or receive or maintain in your Bartels Software Studio OÜ product accounts. This is so you can use our products as intended. We keep this content as long as your account is active. If you delete your account, we’ll delete the content within 60 days.

General Geolocation data

For most of our products, we log the full IP address used to sign up a product account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active.

Website interactions

We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, which web pages you visited and how long they took to load, and which website referred you to us. The web analytics we use is cookie free and anonymous.

Anti-bot assessments

We use CAPTCHA (opens in a new tab) across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your Bartels Software Studio OÜ accounts and when you fill in certain forms in Turbocache, the CAPTCHA service evaluates various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides Bartels Software Studio OÜ with the spam score results; we do not have access to the evaluated information.

Voluntary correspondence

When you email Bartels Software Studio OÜ with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.

We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

When we access or disclose your information

To provide products or services you’ve requested. We use some third-party subprocessors to help run our applications and provide the Services to you. You can view the third-party subprocessors we use below. We also use third-party processors for other business functions such as managing newsletter subscriptions, sending customer surveys, and providing our company storefront.

We may disclose your information at your direction if you integrate a third-party service into your use of our products.

No Bartels Software Studio OÜ human looks at your content except for limited purposes with your express permission, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see "When required under applicable law" below).

To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.

To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.

Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.

When required under applicable law. Bartels Software Studio OÜ is a company based in Estonia.

  • Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request.

  • If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.

Finally, if Bartels Software Studio OÜ is acquired by or merges with another company — we don’t plan on that, but if it happens — we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.

Third party subprocessors

We use third party subprocessors, such as cloud computing providers and customer support software, to run Turbocache (the service). We establish GDPR-compliant data processing agreements with each subprocessor, everywhere personal data is processed.

Your rights with respect to your information

At Bartels Software Studio OÜ, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:

  • Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Correction. You have the right to request correction of your personal information.
  • Right to Erasure / “To Be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfillment of some data deletion requests may prevent you from using Bartels Software OÜ services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of your personal information. (Again: we never have and never will sell your personal data.)
  • Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
  • Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
  • Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.

In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at [email protected]. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.

How we secure your data

All data is encrypted via SSL/TLS (opens in a new tab) when transmitted from our servers to your browser. The most important step is that we keep the collection of personal data to a minimum.

What happens when you delete content in your product accounts

If you choose to cancel your account, your content will become immediately inaccessible and should be purged from our systems in full within 60 days. This applies both for cases when an account owner directly cancels and for auto-canceled accounts.

Data retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.

Location of site and data

Our products and other web properties are operated by third party cloud vendors. If you are located in the European Union, UK, or elsewhere outside of the United States, please be aware that any information you provide to us can be transferred to and stored in the United States. By using our websites or Services and/or providing us with your personal information, you consent to this transfer. However we try to choose EU based locations where possible.

Changes & questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the bottom of this page and take any other appropriate steps to notify users.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at [email protected] and we’ll be happy to try to answer them!



Adapted from the Basecamp open-source policies (opens in a new tab) / CC BY 4.0 (opens in a new tab)