Last updated: 2 August 2026
This policy applies to composery.io and the hosted Composery Cloud service. David Sloiko, trading as Composery in Ireland, is the data controller for Composery Cloud. A person or organisation running the open-source software themselves is responsible for their own deployment and is a separate controller.
- Account data: your Clerk user identifier, email address, authentication and security information, and account settings.
- Billing data: Polar customer, checkout, and subscription identifiers, payment status, and transaction records. Composery does not receive your full card number.
- Service data: box name, server and network identifiers, location and type, lifecycle history, snapshots, operational errors, and sampled CPU, disk, and network metrics.
- Security data: IP address and request information may appear in provider security logs. Password breach checks send only the first five characters of a SHA-1 hash to Have I Been Pwned. Box passwords are hashed on the box; Composery Cloud receives and stores only the one-way hash.
- Website measurements: Vercel Web Analytics and Speed Insights provide cookieless, anonymized traffic and performance information, including page, referrer, browser, device, country, and web-vital data. Web Analytics derives a visitor hash that resets daily.
We process account, billing, and service data because it is necessary to enter into and perform our contract with you: authenticating you, creating and operating boxes, taking payment, providing support, and deleting the service. We use operational, security, abuse-prevention, and aggregated measurement data for our legitimate interests in keeping the service secure, reliable, and understandable. We keep tax, accounting, and compliance records where required by law.
We disclose only the data needed to Clerk (identity), Convex (application backend), Polar (merchant of record and billing), Hetzner (European cloud infrastructure and snapshots), Cloudflare (DNS and network services), Vercel (website hosting and cookieless measurements), Resend (security and operational alerts, service notices about your own boxes, and legal notices about your account), and Have I Been Pwned (k-anonymous password checks). These providers process data under their own terms and/or our processor agreements. Where data leaves the EEA or UK, we rely on an adequacy decision or appropriate contractual safeguards supplied by the provider.
- While a box is active, we retain the account, service, billing, and operational data needed to provide it. Raw metrics are kept for two days and hourly metric summaries for 30 days.
- When a box is deleted, its server, DNS records, snapshots, password hash, temporary authorization records, infrastructure identifiers, and metrics are removed. We retain a minimized box record, lifecycle timestamps, operation and event summaries, and abuse flags for 180 days for support, abuse prevention, security investigation, and the establishment or defence of legal claims. The record is then automatically purged.
- Unpaid checkout records are removed after 30 days. Records needed to support billing, tax, refunds, or transaction disputes are retained for six years after the related box ends. A record may be retained longer only while a specific legal hold, audit, or dispute requires it.
- Staff-only operational alert records, including their delivery state and incident context, are removed after 180 days.
- When we send you a legal notice - a change to these documents or the service, or a personal data breach - we keep a record of which notice, the address it was sent to, when, and whether it was delivered, for six years. That record is how we show a notice we were required to give you was actually given. Deleting your account replaces the address in it with a non-identifying value and keeps the rest.
- Deleting your account immediately revokes its subscriptions and starts the same box deletion process. We remove checkout secrets and URLs, replace the email and external identity with non-identifying internal values, and pseudonymize retained box and event records. The pseudonymous account record is removed after the six-year billing retention period once no retained records refer to it.
- Providers may retain limited backups, fraud, transaction, and statutory records for their applicable retention periods.
Depending on where you live, you may ask for access, correction, deletion, restriction, portability, or an objection to processing. You may complain to the Irish Data Protection Commission or your local supervisory authority. Email to exercise a right. We may need to check your identity. You can also manage or delete your account from the Clerk user menu.
See our Cookie Notice. We will update this notice when our processing changes and show the new date above. Where a change materially affects an active account we will email you about it rather than rely on you re-reading this page. If a personal data breach is likely to result in a high risk to your rights and freedoms, we will contact you directly and without undue delay.