Effective 26 August 2026. Reviewed at least annually and on any change to how we handle personal information.
1. Who we are
Toonlead limited, Dimitrakopoulou 3, 1090, Nicosia, Cyprus, is the controller of the personal information described in this policy. In this policy: “the Company”, “we”, “us”.
This policy covers our websites, and specifically this website at https://tram-pararam.com (in this policy: “the Websites”).
By using the Websites you acknowledge that you have read and understood this policy. It forms part of our Terms of Service.
2. What we collect
| What | When |
|---|---|
| Email address, username, password | when you subscribe and an account is created for you |
| Name, postal address, card details | when you subscribe, collected by our payment provider |
| Subscription and transaction records | when you pay, renew, cancel or are refunded |
| Comment text and the name you post under | when you leave a comment |
| Support correspondence | when you write to us |
| IP address, browser and device information, pages visited | automatically, when you visit |
| Cookie identifiers | automatically, subject to section 7 |
We do not collect card numbers ourselves. Card details are entered on the payment provider’s own systems and are not stored by us.
3. Why we process it and on what basis
| Purpose | Lawful basis |
|---|---|
| Creating and running your account, giving you access | performance of our contract with you |
| Taking payment, renewing, cancelling and refunding | performance of our contract with you |
| Keeping accounting and tax records | legal obligation |
| Answering support requests and complaints | performance of our contract, and our legitimate interest in running the service |
| Moderating comments and content | our legitimate interest in keeping the service lawful and safe |
| Preventing fraud and abuse, keeping the site secure | our legitimate interest in protecting the service and our users |
| Diagnosing errors and technical faults | our legitimate interest in keeping the service working |
| Traffic and usage analysis | our legitimate interest in understanding how the Websites are used |
| Sending you promotional email | your consent, which you may withdraw at any time |
Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights, and you may object as set out in section 9.
4. How long we keep it
| What | How long |
|---|---|
| Account details | while the account is open, and for 12 months after it is closed |
| Subscription and transaction records | 6 years, as required by Cyprus accounting and tax law |
| Support correspondence | 24 months from the last message |
| Complaints about content | 24 months from resolution |
| Comments | while published; deleted when the comment is removed |
| Server and access logs | 90 days |
| Marketing consent records | until consent is withdrawn, and for 24 months after |
Where a period above has passed but the information is still needed to defend a legal claim, we keep it until that claim is resolved.
5. Who we share it with
We do not sell, rent or trade your personal information. We share it only with service providers who process it on our behalf, and only so far as they need it:
- payment providers, who take payment, handle renewals and process refunds;
- hosting and infrastructure providers, who run the servers the Websites sit on;
- error monitoring providers, who receive technical error reports that may include the page being viewed and the account concerned at the time of the error;
- email delivery providers, who send account and support email on our behalf.
Each of these is bound to process the information only on our instructions and to keep it secure.
We may also disclose personal information where we are required to do so by law, court order or a lawful demand from a government or law enforcement authority, or where we believe in good faith that disclosure is necessary to identify or bring action against someone causing injury to, or interfering with the rights or property of, the Company, another user or anyone else.
6. International transfers
Some of our service providers are located outside the European Economic Area, including in the United States, Canada and the United Kingdom.
This means your personal information may be transferred to, and stored in, countries whose data protection law differs from that of your own country. We choose providers that offer appropriate protection for the information they handle.
If you would like to know where your information is held, write to us at the address in section 14.
7. Cookies
The Websites use cookies to make navigation work, to make features function correctly and to analyse how the Websites are used. Cookies are small pieces of information stored by your browser.
- Cookies are set when you arrive on the Websites. The banner shown on your first visit tells you that we use them; it does not ask you to choose between categories of cookie.
- You can block or delete cookies at any time in your browser settings. Some parts of the Websites will not work if you do.
- You must allow cookies in order to purchase access to the Websites, because the purchase process cannot be completed without them.
We do not extract information about individual users or their computers through this process beyond what is described in this policy.
8. Comments and public areas
Some parts of the Websites allow you to leave comments.
Anything you write in a comment is public and can be read by anyone. Please do not include personal information about yourself or about anyone else in a comment.
We moderate comments and may edit or delete any of them. Deleting a comment removes it from the Websites.
9. Your rights
Wherever you live, you may ask us to:
- give you a copy of the personal information we hold about you;
- correct information that is inaccurate or incomplete;
- delete information we hold about you, where the law allows;
- restrict how we process it, in certain circumstances;
- transfer it to you or to another organisation in a usable format, in certain circumstances;
- stop processing it where we rely on legitimate interests, or stop using it for direct marketing;
- withdraw your consent at any time where we rely on consent, which does not affect processing carried out before you withdrew it;
- not be subject to a decision based solely on automated processing that produces legal effects for you.
To exercise any of these, write to support@dcnetservice.com with your account details and say which right you wish to exercise. We may need to verify your identity first.
We answer within one month, free of charge, unless the request is manifestly unfounded or excessive, in which case we will tell you why.
10. Complaints to a supervisory authority
If you are not satisfied with how we have handled your personal information, you have the right to complain to a data protection supervisory authority.
Our supervisory authority is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus, https://www.dataprotection.gov.cy.
If you live elsewhere in the European Economic Area or in the United Kingdom, you may also complain to the authority in your own country.
We would ask you to raise the matter with us first at support@dcnetservice.com, but you are not required to.
11. Region-specific rights
European Economic Area and United Kingdom
The rights in section 9 are the rights given by the General Data Protection Regulation and, in the United Kingdom, by the UK GDPR and the Data Protection Act 2018. Section 10 sets out your right to complain to a supervisory authority.
California
Under the California Consumer Privacy Act, if you are a California resident you have the rights in section 9, and in addition:
- the right to opt out of the sale of your personal information. We do not sell personal information, and have not done so in the preceding 12 months.
- the right to equal service and pricing, so that exercising any of your rights does not result in a worse service or a different price.
We respond within 45 days, and California law allows you to exercise these rights once a year free of charge.
Nevada
Under Nevada law, if you are a Nevada resident you may withdraw consent where we rely on it, and may opt out of the sale of your personal information. We do not sell personal information.
Canada
We respect the Personal Information Protection and Electronic Documents Act and the provincial privacy laws of Quebec, British Columbia and Alberta. We use your personal information only for the purposes set out in this policy unless you consent to another purpose.
Residents of Canada are notified that the personal information they give us may be stored outside Canada and may be subject to disclosure to authorised law enforcement or government agencies under the law of the country where it is stored.
Australia
We respect the Privacy Act 1988. We use your personal information only for the purposes set out in this policy unless you consent to another purpose.
12. Security
We have measures in place to protect against loss, misuse and alteration of the personal information under our control. Payment pages and account pages are served over TLS. Account information is stored behind a firewall with limited administrative access.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach occurs that is likely to result in a high risk to your rights, we will tell you.
13. Changes to this policy
We may change this policy. The current version is always the one published on this page, and the date at the top shows when it last changed.
Where a change materially affects how we use your personal information, we will tell you before it takes effect.
14. Contact details
Toonlead limited
Dimitrakopoulou 3, 1090, Nicosia, Cyprus
- Personal information, data rights, account and billing: support@dcnetservice.com
- Content complaints and unlawful material: abuse@dcnetservice.com
- Telephone: +44 1315165521
