Privacy Policy

1. Who We Are

We are Shikanoko Networks LTD, a company registered in England and Wales (Company Number: 17131877). We provide RIPE NCC ASN sponsorship services.

As a UK-based company serving customers in the EU, we comply with both the UK GDPR (as enacted by the Data Protection Act 2018) and the EU GDPR (Regulation (EU) 2016/679). References to "GDPR" in this policy cover both regimes unless otherwise specified.

Registered address: 128 City Road, London, United Kingdom, EC1V 2NX

Contact: admin@shikanoko-networks.com

2. What Data We Collect

We collect the following personal data:

• Company name and registration details
• Contact person name, email address, and phone number
• Identification documents (e.g., company registration certificate, proof of address)
• Order and payment information (processed by Stripe — we do not store full payment card details)
• Technical data incidentally processed by our hosting infrastructure when you visit our website: IP address, browser type and version, device information, and session identifiers. This data is not actively collected or stored by us — it is processed transiently by our infrastructure providers (Next.js hosting, Stripe, Cloudflare) solely for security, service delivery, and website functionality. No tracking or profiling is performed.

3. Legal Basis for Processing

We process your personal data on the following legal bases:

Contractual necessity (Article 6(1)(b) GDPR): The data listed in Section 2 is required to fulfill our service contract — to prepare and submit your sponsored ASN and related Internet number resource request to RIPE NCC. RIPE NCC requires appropriate identification and registration documents for its review. Without this data, we cannot provide the service.

Legal obligation (Article 6(1)(c) GDPR): Certain data (including payment records) is retained to comply with tax, accounting, and regulatory obligations under UK law.

We also rely on legitimate interest (Article 6(1)(f) GDPR) to verify applicant identity and prevent fraudulent applications. You have the right to object to processing based on legitimate interest — see Section 7.

4. How We Use Your Data

• To prepare and submit your sponsored ASN and related Internet number resource request to RIPE NCC
• To communicate with you about your order status
• To comply with legal and regulatory obligations
• To send service-related emails (order confirmation, status updates)
• To verify your identity and eligibility as required by RIPE NCC policy

5. Data Sharing

We share your data with:

We do not sell your personal data to third parties.

6. Data Retention

• Service data (application documents, correspondence): Retained for the duration of your active sponsorship plus 3 years after termination.
• Payment and tax records: Retained for 6 years as required by UK tax law (HMRC).
• Data submitted to RIPE NCC: Subject to RIPE NCC's own retention policies.

7. Your Rights

Under the GDPR, you have the right to:

• Access your personal data
• Rectify inaccurate or incomplete data
• Request deletion of your data (subject to legal retention obligations)
• Restrict or object to processing
• Data portability
• Withdraw consent (where processing is based on consent — our core processing relies on contractual necessity, not consent)

To exercise these rights, contact us at admin@shikanoko-networks.com. We will respond within one month of receiving your request (as defined by GDPR Article 12(3)). There is no fee unless the request is manifestly unfounded or excessive.

8. Cookies

We use only essential cookies required for security and the core functionality of our website (e.g., session management, Stripe Checkout). No tracking, analytics, or advertising cookies are used.

A cookie notice is displayed on your first visit explaining which essential cookies are set, their purpose, and their duration. No cookies are placed until you acknowledge this notice. You can manage cookie preferences at any time through your browser settings.

9. International Data Transfers

We are based in the United Kingdom. Where personal data is transferred outside the UK or EEA, we ensure appropriate safeguards are in place, including: storage in EU/UK data center regions where available; European Commission-approved Standard Contractual Clauses (SCCs); the UK International Data Transfer Addendum (IDTA) for UK-originating data transfers; and Data Processing Agreements (DPAs) with all processors.

10. Data Protection & DSA Legal Representative

We have appointed DataRep (Data Protection Representative Limited, a company registered in Ireland under number 616588, with registered office at 77 Camden Street Lower, Dublin, D02 XE80, Ireland) as our representative for the following jurisdictions and legal frameworks:

• European Union / European Economic Area — pursuant to Article 27 of the General Data Protection Regulation (EU) 2016/679 (GDPR), and pursuant to Article 13 of Regulation (EU) 2022/2065 (Digital Services Act)
• United Kingdom — pursuant to the UK GDPR (as enacted by the Data Protection Act 2018)
• Switzerland — pursuant to the Swiss Federal Act on Data Protection (FADP, AS 2022 491)

Data Protection Inquiries (GDPR / UK GDPR / FADP)

If SHIKANOKO NETWORKS LTD has processed your personal data and you wish to exercise your rights under the GDPR, UK GDPR, or FADP, you may contact DataRep via any of the following:

Email: datarequest@datarep.com (please quote "SHIKANOKO NETWORKS LTD" in the subject line)
Web: www.datarep.com/data-request

DataRep maintains local addresses in all EU member states, the UK, Norway, Iceland, and Switzerland. For a full list of contact addresses in your country, please visit www.datarep.com. When mailing inquiries, please mark your letters for "DataRep" (not "SHIKANOKO NETWORKS LTD") to ensure delivery.

Digital Services Act (DSA) — Legal Representative

Pursuant to Article 13 of Regulation (EU) 2022/2065 (Digital Services Act), our legal representative for matters relating to the delivery of digital services in the European Union is:

Name: DataRep (Data Protection Representative Limited)
Address: DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
Email: digitalrequest@datarep.com (please quote "SHIKANOKO NETWORKS LTD" in the subject line)
Phone: +353 (1) 919 8899
Web: www.datarep.com/data-request

When mailing DSA inquiries, please mark your letters for "DataRep" (not "SHIKANOKO NETWORKS LTD") to ensure delivery. DataRep's privacy notice is available at www.datarep.com/privacy-policy.

You may also contact us directly at admin@shikanoko-networks.com for all data protection and DSA matters.

11. Data Breach Notification

In the event of a personal data breach, we will notify the relevant supervisory authority (the UK ICO) within 72 hours of becoming aware of the breach, where required under applicable law. If the breach is likely to result in a high risk to the rights and freedoms of natural persons, we will also notify the affected individuals without undue delay.

All staff and contractors are required to report any suspected or actual data breaches immediately to admin@shikanoko-networks.com. We maintain an internal breach register documenting all incidents, their effects, and the remedial actions taken.

12. Complaints

If you have concerns about how we handle your data, please contact us at admin@shikanoko-networks.com — we take these matters seriously and will do our best to resolve them.

You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO). If you are based in the EU, you may contact your local data protection authority.

13. Company Information

Shikanoko Networks LTD is a company registered in England and Wales.

Company Number: 17131877

Registered Office: 128 City Road, London, United Kingdom, EC1V 2NX

Contact: admin@shikanoko-networks.com