Privacy Policy

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 never sell your data.

This policy applies to 28times.com.

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 Q-Success). 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 and access

When you sign up at 28times.com, 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’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 service on 28times.com, 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 Q-Success servers. We store a record of the payment transaction 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.

Product interactions

We store on our servers the content that you upload or receive or maintain in your 28times.com account. 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 one calendar month.

General Geolocation data

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 some of 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. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us.

Cookies

A cookie is a piece of text stored by your browser. We use session cookies to remember login information, which are needed to make our services possible. We do not use any other cookies. You can adjust cookie retention settings and accept or block cookies in your browser settings, although our service will not function properly if you turn cookies off.

Voluntary correspondence

When you email Q-Success 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.

When we access or disclose your information

  • To provide services you’ve requested.
    No member of our staff looks at your non-public content except for limited purposes, 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.

  • 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. Q-Success is an Austrian company with its main data infrastructure located in Europe.

    • 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. However, if Austrian law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside Austria if compelled by the Austrian government through procedures outlined in a mutual legal assistance treaty or agreement.
    • 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 28times.com 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.

Your rights with respect to your information

At Q-Success, 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 28times.com services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
  • Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.

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. 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. 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 when transmitted from our servers to your browser.

Most data are not encrypted while they live in our database, since they need to be ready to send to you when you need them.

What happens when you delete content in your product accounts

On 28times.com, we give you the option to trash content. The trashed content cannot be accessed via the application and we are not able to retrieve it for you. Copies of the trashed content may be held in backups of our application databases.

If you choose to cancel your account, your content will become immediately inaccessible. 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.

Location of site and data

Our products and web properties are housed in the European Union.

Changes and questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. If we make significant changes, we will refresh the date at the bottom of this page.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch.

Last Modification of this Page

April 30, 2026

These policies were adapted from the 37signals open-source policies under the CC BY 4.0 license. We have modified them to reflect our specific business practices.