This Privacy Policy explains how personal data is processed when you visit our websites, contact us, use Dinio DNS, or work with us on software development and hosting projects. It is written to meet the requirements of the EU General Data Protection Regulation (GDPR) and the data protection law of Bosnia and Herzegovina.
1. Who we are
Controller: Marcel Bandić (Bitelex), Gornji Vakuf-Uskoplje, Bosnia and Herzegovina.
Privacy contact: privacy@bitelex.com
We intend to transfer the Services to a company. When that happens, the company will become the controller, and we will tell you in advance.
EU representative (Art. 27 GDPR): Marko Mihaljević, Vroedschapstraat 27, 6441 EL Brunssum, the Netherlands, eu-representative@bitelex.com. You can contact our representative about any matter relating to the processing of your personal data, instead of or in addition to contacting us.
2. Our role: controller or processor
Whether we decide how your data is used depends on the context:
| Context | Our role | Who to contact about your data |
|---|---|---|
| Our websites, contact requests, Bitelex accounts, customer relationships, security and audit logs | Controller | Us |
| Our public DNS resolver, used without an account | Controller | Us |
| DNS Filtering set up by a customer for other people’s devices or networks (employees, family, guests) | Processor for the customer | The customer who set up filtering (we forward requests we receive) |
| Personal data a customer places in DNS records, or in applications we host for them | Processor for the customer | That customer |
Where we act as a processor, we process data only on the customer’s instructions. This Policy still describes how the Services work technically, so you can understand what happens to the data.
3. What we process, why, and for how long
3.1 Visiting our websites
- Server logs: IP address, date and time, requested URL, referrer, user agent and status code, processed by our web servers to deliver the site and protect it against abuse. Legal basis: legitimate interests (Art. 6(1)(f) GDPR) in operating a secure website. Retention: 7 days.
- Cookie choice: your choice is stored in your browser’s local storage
(
bitelex-cookie-consent). It is not sent to us. - Analytics: only if you accept, we use Google Analytics to understand how the site is used.
Google processes your IP address, device and browser data, pages visited and interactions, and
sets cookies (
_ga,_ga_<ID>). Legal basis: consent (Art. 6(1)(a)). You can withdraw it at any time with the “Cookie settings” link in the footer. Retention: 14 months.
3.2 Contacting us
- Data: name, email address, the content of your message, and any other information you choose to give us. The contact form is delivered through our own serverless function and an email delivery provider.
- Purpose and legal basis: to answer your request and, where you are interested in our services, to take steps before entering into a contract (Art. 6(1)(b)); otherwise our legitimate interest in responding to messages (Art. 6(1)(f)).
- Retention: 24 months after our last exchange, unless the conversation leads to a project (then see 3.7).
3.3 Bitelex account
Your Bitelex account is the sign-in you use for Dinio and, in the future, for other Bitelex products.
- Data: email address, name (if provided), authentication identifiers, sign-in method (for example a social login provider), account role, and the time your account was created and updated. Sign-in is provided by Clerk, Inc., which also processes device and session data to secure sign-in, and sets strictly necessary cookies in the dashboard to keep you signed in. These cookies do not require consent.
- API keys: we store only a cryptographic hash of each API key. The key itself is shown to you once and is not retained.
- Purpose and legal basis: to provide your account and the Services (Art. 6(1)(b)).
- Retention: for as long as your account exists. You can ask us to delete your data for a single product (for example Dinio) or your whole account; we then delete it within 30 days, except data we must keep by law.
3.4 Security and audit logs
- Data: for each action in the Dinio API and dashboard: who performed it (user, API key type, email address as a readable label), the IP address it came from, the action, the resource concerned, the outcome, and the time. We do not log the content of your requests or any secrets.
- Purpose and legal basis: security, abuse prevention, troubleshooting and accountability (legitimate interests, Art. 6(1)(f)).
- Location: European Union.
- Retention: 30 days, then automatically deleted.
3.5 Dinio DNS Hosting (authoritative DNS)
When anyone on the internet looks up a domain hosted on Dinio, the query usually reaches our edge network from a DNS resolver (for example an internet provider’s or a public resolver), and in some cases directly from a device.
- Data: the source IP address of the query, the queried name and type, and the response. We may map the IP address to an approximate country to apply geo routing and geo bans configured by the zone owner.
- What we keep: we do not keep a log of individual queries. The edge network computes aggregated statistics (counts per zone, name, record type, response code and country) and a bounded list of the most active source IP addresses, used for abuse detection and operations. These statistics are sent to our statistics database every 10 minutes.
- Purpose and legal basis: answering DNS queries, providing statistics to zone owners, and detecting and mitigating attacks (legitimate interests, Art. 6(1)(f); for zone owners, Art. 6(1)(b)).
- Location: queries are processed by the edge node that receives them (see section 5); statistics are stored in the European Union.
- Retention: 90 days, then automatically deleted.
- Health checks send probe requests to targets configured by the zone owner. Certificates issued for redirects are requested from Let’s Encrypt; the domain names in a certificate are published permanently in public Certificate Transparency logs.
3.6 Dinio DNS Filtering (resolver)
When a device uses Dinio as its resolver, Dinio receives every DNS lookup from that device, which can reveal which websites and services it uses. We treat this data as sensitive and keep as little of it as possible.
- Data: the client’s source IP address, or the DNS-over-TLS hostname or DNS-over-HTTPS path that identifies the client; the queried name and type; and whether it was answered or blocked by the lists linked to that client.
- What we keep: we do not keep a log of individual lookups. For each client identity we keep aggregated counts (by outcome and response code) and a bounded list of the most frequently blocked domain names, so the customer can see what filtering is doing. Across the platform we keep aggregated counts, an estimate of the number of distinct clients, and bounded lists of the most queried domain names and most active source IP addresses, for capacity planning and abuse detection.
- Who can see it: per-client statistics are visible to the customer who owns the client identity, and to us for support, security and operations.
- Purpose and legal basis: providing the filtering service and its statistics on behalf of the customer (processor role, section 2; for our own customers, Art. 6(1)(b)); network security and abuse prevention (Art. 6(1)(f)).
- Location: lookups are processed by the edge node that receives them (see section 5); statistics are stored in the European Union.
- Retention: 90 days, then automatically deleted.
- Your lists: sinkhole lists and rules you create are your content. If you share a list, other users can see that it exists and its name, but not its rules.
3.6a Public resolver
Anyone can use our public resolver without an account, with one of the filtering profiles we operate. The same principles apply as in 3.6:
- Data: the source IP address, the queried name and type, the filtering profile used, and whether the lookup was answered or blocked.
- What we keep: no log of individual lookups. Only platform-wide aggregated counts, an estimate of the number of distinct clients, and bounded lists of the most queried and most blocked domain names and the most active source IP addresses. We do not link this data to any person or account.
- Purpose and legal basis: providing the resolver you chose to use, improving the filtering profiles, and protecting the service against abuse (legitimate interests, Art. 6(1)(f)).
- Location: lookups are processed by the edge node that receives them (see section 5); statistics are stored in the European Union.
- Retention: 90 days, then automatically deleted.
3.7 Clients of software development and hosting
- Data: names, business contact details and communications of client representatives; offers, contracts and invoices; project materials.
- Purpose and legal basis: performing the contract (Art. 6(1)(b)), keeping records required by accounting and tax law (Art. 6(1)(c)), and managing the business relationship (Art. 6(1)(f)).
- Retention: for the duration of the contract, and afterwards for as long as accounting and tax law requires and legal claims can still be made.
- Hosted applications: data stored in applications we host for clients is processed on the client’s behalf (section 2).
3.8 Support, abuse and legal requests
When you write to hello@, abuse@ or privacy@bitelex.com, we process your contact details and the content of your message to handle the request (Art. 6(1)(b) or (f)), and for abuse reports and legal requests to comply with legal obligations (Art. 6(1)(c)). Retention: 24 months after the case is closed, or longer where needed for legal claims.
4. Who receives your data
We do not sell personal data, and we do not use it for advertising. We share it only with:
| Recipient | Purpose | Location |
|---|---|---|
| Clerk, Inc. | Sign-in for Bitelex accounts | USA |
| Google Ireland Ltd. / Google LLC | Website analytics, only with your consent | EU / USA |
| Mailjet SAS | Delivery of contact form messages | EU (France) |
| Internet Security Research Group (Let’s Encrypt) | Certificates for Dinio redirects (domain names only) | USA |
| Hosting and cloud providers | Data centres and servers for Dinio and hosted applications | Canada / USA, EU, Singapore |
| Professional advisers | Legal and accounting services | Bound by confidentiality |
| Authorities and courts | Only where we are legally required to disclose | — |
| A company taking over the Services | See section 1 | — |
5. Where your data is processed
Dinio is a globally distributed DNS platform. It runs in three regions: Canada / USA, the European Union, and Singapore.
- DNS queries are processed by the edge node in the region that receives them, usually the one closest to the requester. Edge nodes hold a copy of the DNS configuration and process query data in memory to answer it.
- Account data and Dinio configuration (zones, records, client identities, lists) are stored in a database replicated across all three regions, so that the Service keeps working if one region fails.
- Statistics and audit logs are stored in the European Union.
Canada is recognised by the European Commission as providing adequate protection. For other countries, including the USA and Singapore, we rely on contractual safeguards with our providers, such as the European Commission’s Standard Contractual Clauses, or on the EU–US Data Privacy Framework where the provider is certified. You can ask for details at privacy@bitelex.com.
6. Security
We protect personal data with measures appropriate to the risk, including encryption in transit (TLS, DNS-over-TLS, DNS-over-HTTPS), hashed API keys, role-based access control, scoped API keys, audit logging, replication across regions, statistics based on aggregates instead of query logs, and automatic deletion at the end of retention periods. No system is completely secure; if a breach affects your data, we will notify you and the competent authority as required by law.
7. Your rights
You have the right to:
- access your personal data and receive a copy;
- rectify inaccurate data;
- erase your data;
- restrict processing;
- data portability for data you provided to us under a contract or consent;
- object to processing based on legitimate interests, on grounds relating to your particular situation;
- withdraw consent at any time, without affecting processing before the withdrawal.
To exercise your rights, write to privacy@bitelex.com, if possible from the email address on your account. We respond within one month; for complex requests this can be extended by two further months, and we will tell you if so. We may need to verify your identity first. Where we are a processor (section 2), we forward your request to the relevant customer.
You can also lodge a complaint with a data protection authority: in Bosnia and Herzegovina, the Personal Data Protection Agency (Agencija za zaštitu ličnih/osobnih podataka u BiH); if you live in the EU, the authority in your country.
8. Automated decision-making
We do not make decisions producing legal or similarly significant effects based solely on automated processing. DNS Filtering blocks domains according to lists and rules chosen by the customer, and geo routing selects DNS answers based on approximate location. Neither is a decision about you as a person.
9. Children
Our Services are not directed at children, and accounts require the holder to be an adult. Where a parent or guardian uses DNS Filtering for a household, the parent or guardian decides how filtering is applied.
10. Changes to this Policy
We update this Policy when our processing changes. We notify account holders of material changes by email or in the dashboard before they take effect. Previous versions are available on request.
11. Contact
Marcel Bandić (Bitelex), Gornji Vakuf-Uskoplje, Bosnia and Herzegovina
privacy@bitelex.com · hello@bitelex.com · abuse@bitelex.com