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Privacy Policy

Last updated: October 14, 2026

1. Introduction

Boxmarshall Ltd, a company registered in Nigeria (RC 1557325) with its office in Lagos ("we", "us", "our"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use the Reoclo platform ("the Platform"). It is written to meet the Nigeria Data Protection Act 2023 (NDPA). We also keep the rights and complaint routes available to people in the European Union (GDPR) and the United Kingdom (UK GDPR).

2. Data Controller

Boxmarshall Ltd (RC 1557325), Lagos, Nigeria, is the data controller for personal data processed through the Platform. For questions or requests regarding your data, contact our data protection team at [email protected].

3. Data We Collect

We collect and process the following categories of personal data:

Account Information

Email address, name, username, avatar, timezone and preferences, the time your email address was verified, the time and version of the terms you accepted, and your organization memberships and roles. You provide this when you sign up, accept an invitation, or edit your profile.

Billing and Payment

The billing contact's name and email address, the organization's details, invoices, and payment records. Online payments are handled by Bachs Technologies Limited (bachs.io), which collects card or bank details on its own page and tells us only whether the payment succeeded and for how much. We never see or store card numbers.

Authentication Data

One-time sign-in codes are stored only as keyed hashes (HMAC-SHA256) and sign-in link tokens as SHA-256 hashes; both expire, and the records are deleted about one day after creation. We store the public credentials of your passkeys and security keys, authenticator app secrets in encrypted form, and backup codes in hashed form. Session records include your IP address, browser and operating system (user agent), and last activity.

Security Monitoring

Sign-in history from the last 90 days, used to recognize new devices and to send security alert emails. For new-device alerts, the sign-in IP address is sent to ipwho.is to look up an approximate location (city and country).

Bot Protection

Sign-in and sign-up forms are protected by Cloudflare Turnstile. Turnstile processes browser and device signals and your IP address to distinguish people from automated bots.

GitHub Account

When you link or sign in with GitHub, we receive your GitHub account ID, username, and email address.

Email

We send transactional and security emails, such as sign-in codes, invitations, and security alerts, through a transactional email provider.

Infrastructure Configuration

Server connection details (hostnames, IP addresses), application configurations, domain names, and deployment settings you provide to the Platform.

Encrypted Secrets

Environment variables, SSH keys, and registry credentials. These are encrypted at rest using AES-256-GCM envelope encryption and are only decrypted in isolated worker processes during deployment operations.

Audit Logs

Records of actions taken within the Platform, including who performed the action, what changed, and when. Sensitive field values are excluded from audit output.

Operational Logs

Container logs and system journal logs from your servers, when you use our log management features. These logs originate from and belong to your infrastructure.

Usage Data

Platform usage patterns such as login timestamps, feature usage, and API request metadata. We do not use third-party analytics or advertising tools.

4. How We Use Your Data

We process your personal data for the following purposes:

  • Service delivery: To operate the Platform, deploy your applications, manage your servers, and provide the features you use.
  • Authentication and security: To verify your identity, manage sessions, protect sign-in and sign-up forms from automated abuse, recognize new devices, and protect your account from unauthorized access.
  • Billing: To issue invoices, record payments, and manage the billing relationship with your organization.
  • Audit and compliance: To maintain audit trails of actions taken within the Platform for accountability and security purposes.
  • Communication: To send sign-in codes and invitations, and to notify you of service changes, security events, or incidents affecting your infrastructure.
  • Platform improvement: To understand usage patterns and improve the Platform. We do not sell your data or use it for advertising.

5. Legal Basis for Processing

We process your data under the lawful bases set out in the NDPA and, for people in the EU and UK, GDPR Article 6:

  • Contractual necessity: Processing required to provide the Platform services you or your organization have contracted for.
  • Legitimate interest: Security monitoring, fraud and abuse prevention (including bot protection), and Platform improvement, balanced against your privacy rights.
  • Legal obligation: Where we are required to retain data by law.

6. Data Storage and Security

We implement the following technical measures to protect your data:

  • Encryption at rest: All secrets (environment variables, SSH keys, registry credentials) are encrypted using AES-256-GCM with an envelope encryption pattern (KEK/DEK).
  • Encryption in transit: All connections to the Platform use TLS. WebSocket connections for terminal access and real-time updates are encrypted.
  • Sign-in credential storage: Sign-in codes are stored as keyed hashes, sign-in link tokens as SHA-256 hashes, backup codes in hashed form, and authenticator app secrets in encrypted form. A code is invalidated after five wrong entries and is valid for 10 minutes.
  • Tenant isolation: Data is logically isolated between tenants at the database level. Cross-tenant data access is prevented by design.
  • Minimal privilege: Secrets are only decrypted in isolated worker processes during the specific operations that require them.

7. Data Breaches

If a breach puts personal data at risk, we report it to the Nigeria Data Protection Commission within 72 hours of becoming aware of it, and we tell affected people without undue delay.

8. BYOS Model and Your Data

Reoclo operates on a Bring Your Own Server model. Your applications, application data, and container workloads run entirely on infrastructure you own and control. We do not have access to your application databases, user data, or business data unless you explicitly configure the Platform to collect logs from those systems.

When you use browser terminal access, commands are relayed through the Platform but are not logged or stored by us. The terminal session exists only for the duration of your connection.

9. Data Sharing

We do not sell, rent, or trade your personal data. We may share data only in the following circumstances:

  • Within your organization: Tenant administrators can view team member accounts and audit logs within their tenant.
  • Hetzner Online (Germany): Operates the servers that run the Platform (not your servers).
  • MongoDB, Inc.: Hosts the Platform's database on MongoDB Atlas in Germany. Hetzner and MongoDB process data under our instructions and data processing agreements.
  • Prawnwire: Boxmarshall's own email platform, which sends our transactional and security emails.
  • Bachs Technologies Limited (Nigeria): Our payment provider. It collects card or bank details on its own page and tells us only whether a payment succeeded and for how much. It handles those details under its own privacy policy (https://bachs.io/privacy).
  • Cloudflare: Serves and protects our websites. Cloudflare Turnstile receives browser and device signals and your IP address on the sign-in and sign-up forms to detect automated abuse.
  • ipwho.is: The IP address of a sign-in is sent to ipwho.is to look up an approximate location for new-device security alerts.
  • GitHub: If you link or sign in with GitHub, we exchange data with GitHub as part of that sign-in.
  • Legal requirements: If required by law, court order, or regulatory authority, we may disclose data as necessary to comply.

10. Data Retention

We keep personal data only as long as we need it:

  • Account and organization data: While your account and organization exist.
  • Sign-in code and link records: Deleted about one day after they are created.
  • Sign-in sessions: Kept while your account exists. New-device alerts compare each sign-in with the previous 90 days.
  • Audit logs: 90 days.
  • Application logs collected from your servers: 30 days.
  • Deployment logs: 90 days.
  • Server metrics: Daily summaries for 365 days.
  • Invoices and payment records: As long as Nigerian tax and company law requires.

After your agreement with us ends, you have 30 days to export your Platform data. After this period, the data is deleted, and backup copies age out within 90 days, except where retention is required by law.

11. Your Rights

Under the NDPA and, for people in the EU and UK, the GDPR and UK GDPR, you have the following rights:

  • Access: Request a copy of the personal data we hold about you.
  • Rectification: Request correction of inaccurate personal data.
  • Erasure: Request deletion of your personal data, subject to legal retention requirements.
  • Portability: Receive your data in a structured, machine-readable format.
  • Restriction: Request that we limit how we process your data in certain circumstances.
  • Objection: Object to processing based on legitimate interest.
  • Withdrawal of consent: Where we rely on your consent, withdraw it at any time.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

12. Cookies and Local Storage

The Platform uses httpOnly cookies for authentication session management. We use browser local storage for user preferences such as theme selection. Cloudflare Turnstile may use cookies or local storage on its challenge domain to distinguish people from bots. We do not use advertising cookies, third-party tracking cookies, or analytics cookies.

13. International Data Transfers

We are based in Nigeria. The Platform runs on servers operated by Hetzner Online in Germany, its database is hosted on MongoDB Atlas, also in Germany, and our websites are served through Cloudflare's global network. Emails are sent through Prawnwire, Boxmarshall's own email platform, which runs on Hetzner servers in Germany and Finland. Storing data in these places moves it out of Nigeria. For these transfers we rely on the safeguards the Nigeria Data Protection Act allows: the data protection law of the European Union, which applies in Germany and Finland, and our agreements with these providers. Where data moves from the European Economic Area or the UK to a country without an adequacy decision, we use appropriate safeguards such as Standard Contractual Clauses.

14. Children

You must be 18 or older to create an account. We do not knowingly collect children's data.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you via the Platform dashboard or email at least 14 days before the changes take effect. The "Last updated" date at the top of this page reflects the most recent revision.

16. Supervisory Authorities

If you believe we have not adequately addressed your data protection concerns, you have the right to lodge a complaint with the Nigeria Data Protection Commission (https://ndpc.gov.ng/). If you are located in the European Economic Area or the UK, you may also complain to your local data protection supervisory authority.

17. Contact

For any questions about this Privacy Policy or your personal data, contact us at [email protected].