VPS Hosting Privacy Addendum

This Privacy Addendum supplements the CrossTrade Privacy Policy and describes additional data collection, usage, and retention practices specific to VPS Hosting Services.

Effective Date: December 1, 2025  |  Last Updated: March 28, 2026

This addendum is governed by and should be read in conjunction with the CrossTrade Privacy Policy, VPS Terms of Service, and VPS Acceptable Use Policy. In the event of a conflict between this addendum and the main Privacy Policy regarding VPS-specific data practices, this addendum shall control.

1. Data Collection for VPS Services

In addition to data collected as described in our Privacy Policy, CrossTrade collects the following information specific to VPS Services:

Infrastructure Monitoring Data: CPU usage metrics, RAM consumption, disk space utilization and I/O operations, network bandwidth usage and traffic patterns, IP addresses accessing your VPS via RDP or other protocols, connection timestamps and duration, and operating system type and version.

Access and Security Logs: Failed login attempts and source IP addresses, successful authentication events, Remote Desktop Protocol (RDP) connection logs, administrative actions performed by CrossTrade staff on your VPS, and firewall and security event logs at the infrastructure level.

Billing and Account Data: Your VPS plan and resource allocation, billing history and payment information, support tickets and communications related to VPS Services, and VPS creation, modification, and termination dates.


2. What We Do NOT Monitor

CrossTrade does NOT monitor, access, or collect:

  • The content of files stored on your VPS
  • Application data, databases, or user-generated content on your VPS
  • Communications sent or received through applications on your VPS (such as email or chat)
  • Your trading activity, strategies, or trading platform data
  • Keystrokes, screenshots, or user activity within your VPS
Exception: CrossTrade may access your VPS content only when required to investigate abuse complaints or Terms of Service violations, when necessary to diagnose technical issues at your explicit request, when legally required by court order, subpoena, or law enforcement request, or when necessary to prevent imminent harm to CrossTrade's infrastructure or other customers.

3. How We Use VPS Data

CrossTrade uses VPS-related data for the following purposes:

  • Service Delivery: Provisioning, maintaining, and operating VPS infrastructure
  • Resource Management: Monitoring usage to ensure fair allocation and prevent abuse
  • Security: Detecting and preventing malicious activity, unauthorized access, and policy violations
  • Billing: Calculating usage-based charges and managing subscriptions
  • Support: Responding to technical issues and customer inquiries
  • Infrastructure Improvement: Analyzing aggregate performance metrics to optimize service quality
  • Compliance: Meeting legal obligations and responding to valid legal requests

4. Data Retention

Active VPS Instances

  • Infrastructure monitoring data: Retained for 90 days
  • Access logs: Retained for 60 days
  • Security event logs: Retained for 180 days
  • Billing records: Retained for 7 years as required by law

Terminated VPS Instances

  • All VPS data (files, applications, configurations): Deleted within 7 days of termination
  • Billing records: Retained for 7 years as required by law
  • Access logs and monitoring data: Retained for 60 days after termination, then deleted
  • Abuse complaints and DMCA notices: Retained indefinitely for legal protection purposes
Important: When your VPS is terminated — whether voluntarily or involuntarily — all data on your VPS is permanently deleted using secure deletion methods. CrossTrade does not maintain backups of your VPS data after termination, and data deletion is irreversible. VPS instances suspended for non-payment for 14 or more days may be terminated and all data permanently deleted, as described in the VPS Terms of Service.

Account Inactivity

CrossTrade reserves the right to suspend or delete accounts that have remained inactive for twelve (12) or more consecutive months, as described in our Terms of Service. VPS instances tied to inactive accounts may be subject to suspension and eventual termination. Prior to any action, CrossTrade will make a reasonable effort to notify the user via the email address on file.


5. Data Sharing

CrossTrade does not sell or rent VPS-related data to third parties. However, we may share VPS data in certain limited circumstances:

Service Providers: Data center and infrastructure providers who host our VPS servers, payment processors for billing purposes, and analytics providers for aggregate performance metrics (anonymized data only).

Legal Obligations: Providing information to law enforcement agencies pursuant to valid legal process such as subpoenas, warrants, or court orders, responding to DMCA takedown notices or abuse complaints, and complying with applicable laws, regulations, or legal proceedings.

Business Transfers: In the event of a merger, acquisition, or sale of all or part of CrossTrade's business, your data may be transferred as part of that transaction.

Abuse and Security: Providing information to abuse complaint sources (such as spam databases or blacklist operators) when investigating complaints, or to other customers if your VPS is attacking or harming their services.


6. Data Security

CrossTrade's Responsibilities

CrossTrade implements reasonable technical and organizational measures to protect VPS infrastructure. These measures include:

  • Encrypted connections for administrative access
  • Network firewalls and intrusion detection systems
  • Regular security updates to host infrastructure
  • Access controls limiting employee access to VPS systems
  • Physical security at data center facilities

Your Responsibilities

You bear significant responsibility for securing your VPS. You are responsible for:

  • Maintaining strong passwords and authentication methods
  • Installing operating system and software security updates
  • Configuring firewalls and security settings within your VPS
  • Encrypting sensitive data stored on your VPS

CrossTrade cannot guarantee the security of data you store on your VPS. You acknowledge that no system is completely secure and accept the risks associated with storing data on remote servers.

Breach Notification

In the event of a confirmed data breach affecting VPS infrastructure or your personal data held by CrossTrade, the breach notification procedures described in Section 6.4 of the Privacy Policy apply. CrossTrade will notify affected users via email within seventy-two (72) hours of confirming the breach, or as otherwise required by applicable law, and will provide details regarding the nature of the breach, categories of data affected, and measures taken to mitigate its effects.

This notification obligation applies to breaches of CrossTrade's infrastructure. CrossTrade is not responsible for detecting or notifying you of security breaches that occur within your VPS environment due to your own configurations, software, or access controls.


7. Data Subject Rights (GDPR/CCPA)

If you are located in the European Economic Area (EEA) or California, you have certain rights regarding your personal data:

  • Right to Access: Request a copy of personal data CrossTrade holds about you
  • Right to Correction: Request correction of inaccurate personal data
  • Right to Deletion: Request deletion of your personal data (subject to legal retention requirements)
  • Right to Restriction: Request limitation of processing in certain circumstances
  • Right to Data Portability: Receive your data in a structured, machine-readable format (where feasible)
  • Right to Object: Object to certain types of processing
Important Limitation: These rights apply to CrossTrade's data about you (account information, logs, billing records). They do NOT apply to data you store on your VPS. You control and are responsible for data stored on your VPS.

To exercise these rights, contact us at [email protected].


8. International Data Transfers

CrossTrade VPS servers are located in the United States. By using VPS Services, you acknowledge that your data may be transferred to, stored, and processed in countries outside your country of residence, including countries that may have different data protection laws than your country.


9. Cookies and Tracking

The VPS Hosting service itself does not use cookies or tracking technologies. However, the CrossTrade website and customer portal use cookies as described in our Cookie Policy. The Cookie Policy applies when you access your account, manage your VPS, or use the CrossTrade website.


10. Children's Privacy

VPS Services are not directed to individuals under 18 years of age. CrossTrade does not knowingly collect personal information from children. If you believe a child has provided personal information to CrossTrade, please contact us immediately at [email protected].


11. Changes to This Privacy Addendum

CrossTrade may update this Privacy Addendum at any time. We will notify you of material changes via email to the address associated with your account. Your continued use of VPS Services after changes are posted constitutes acceptance of the updated Privacy Addendum.


12. Contact Information

For more information about our privacy practices, if you have questions, concerns, or requests regarding this Privacy Addendum or our data practices, or if you would like to make a complaint, please contact us:

Email: [email protected]
Mail:
CrossTrade LLC
1309 Coffeen Ave, STE 1200
Sheridan, WY 82801
United States