We, Tubach L.L.C-FZ, thank you for visiting our homepage. As an IT company, the secure handling of your data is particularly important to us. Therefore, we would like to inform you in detail about the use of your data when visiting our website.

1. Begriffsbestimmungen

The privacy policy of Tubach L.L.C-FZ is based on the terms used by the European legislator for directives and regulations when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for both the public and our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy, we use, among others, the following terms:

- Personal Data: Personal data are all information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

- Data Subject: A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

- Processing: Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

- Restriction of Processing: Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

- Profiling: Profiling is any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

- Pseudonymization: Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

- Controller or Controller Responsible for the Processing: The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

- Processor: A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

- Recipient: A recipient is a natural or legal person, public authority, agency or other body to which personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

- Third Party: A third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

- Consent: Consent is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Data Collection

The website of Tubach L.L.C-FZ collects a series of general data and information each time a data subject or an automated system calls up the website. This general data and information are stored in the server's log files. The following can be collected:

a) the browser types and versions used,

b) the operating system used by the accessing system,

c) the website from which an accessing system arrives at our website (so-called referrer),

d) the sub-websites that are accessed via an accessing system on our website,

e) the date and time of access to the website,

f) an Internet protocol address (IP address),

g) the Internet service provider of the accessing system, and

h) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using this general data and information, Tubach L.L.C-FZ does not draw any conclusions about the data subject. Rather, this information is needed to

a) deliver the content of our website correctly,

b) optimize the content of our website as well as the advertising for it,

c) ensure the permanent functionality of our information technology systems and the technology of our website, and

d) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack.

Therefore, Tubach L.L.C-FZ statistically analyzes these anonymously collected data and information with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

3. Legal or Contractual Requirements for the Provision of Personal Data; Necessity for Contract Conclusion; Obligation of the Data Subject to Provide Personal Data; Possible Consequences of Non-Provision

We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., details about the contractual partner). Sometimes it may be necessary for a data subject to provide us with personal data which must subsequently be processed by us in order to conclude a contract. For example, the data subject is obliged to provide us with personal data if our company enters into a contract with them. Failure to provide the personal data would result in the contract with the data subject not being concluded. Before providing personal data, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.

4. Contact Possibility via the Website

The website of Tubach L.L.C-FZ contains information required by law that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address of so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

5. Use of Google (Universal) Analytics for Web Analysis

This website uses Google (Universal) Analytics, a web analysis service provided by Google Inc. (www.google.de). Google (Universal) Analytics uses methods that enable an analysis of your use of the website, such as so-called "cookies," text files that are stored on your computer. The information generated about your use of this website is generally transmitted to a Google server in the USA and stored there. By activating IP anonymization on this website, the IP address is truncated before transmission within the member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. The anonymized IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

You can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://wbs.is/rom89.

6. Notification of Changes

Changes in the law or changes in our internal processes may make it necessary to adapt this privacy policy.

In the event of such a change, we will notify you no later than six weeks before it takes effect. You generally have the right to revoke your given consents at any time (see section 6).

Please note that the current version of the privacy policy is the valid one, provided you do not exercise your right of revocation.

7. Updating/Deleting Your Personal Data

You have the opportunity to review, change, or delete the personal data provided to us at any time by sending an email to support@tubach-solutions.de. If you are a member, you can also exclude the receipt of further information for the future.

You also have the right to revoke consents given once with effect for the future at any time.

The deletion of stored personal data occurs when you revoke your consent to storage.

The controller processes and stores personal data of the data subject only for the period necessary to achieve the storage purpose or as provided by the European directives and regulations or another legislator in laws or regulations to which the controller is subject.

If the storage purpose ceases to apply or a storage period prescribed by the European directives and regulations or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

8. Rights of Data Subjects

Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they may, at any time, contact our data protection officer or another employee of the controller.

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain free information about their stored personal data and a copy of this information at any time from the controller. Furthermore, the European legislator has granted the data subject access to the following information:

- the purposes of the processing

- the categories of personal data being processed

- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations

- if possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period

- the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing

- the existence of the right to lodge a complaint with a supervisory authority

- where the personal data are not collected from the data subject, any available information as to their source

- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, they may, at any time, contact our data protection officer or another employee of the controller.

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right of rectification, they may, at any time, contact our data protection officer or another employee of the controller.

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, provided that one of the following grounds applies and insofar as the processing is not necessary:

- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

- The data subject withdraws consent on which the processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and where there is no other legal ground for the processing.

- The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.

- The personal data have been unlawfully processed.

- The erasure of personal data is necessary for compliance with a legal obligation in Union or Member State law to which the controller is subject.

- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Tubach L.L.C-FZ, they may, at any time, contact our data protection officer or another employee of the controller. The data protection officer of Tubach L.L.C-FZ or another employee will promptly ensure that the erasure request is complied with immediately.

Where Tubach L.L.C-FZ has made personal data public and is obliged pursuant to Article 17(1) GDPR to erase the personal data, Tubach L.L.C-FZ, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, insofar as processing is not required. The data protection officer of Tubach L.L.C-FZ or another employee will arrange the necessary measures in individual cases.

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

- The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.

- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.

- The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Tubach L.L.C-FZ, they may, at any time, contact our data protection officer or another employee of the controller. The data protection officer of Tubach L.L.C-FZ or another employee will arrange the restriction of the processing.

Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which was provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data were provided, as long as the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may at any time contact the data protection officer designated by Tubach L.L.C-FZ or another employee.

Every data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to the processing of personal data concerning them, which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

Tubach L.L.C-FZ shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If Tubach L.L.C-FZ processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Tubach L.L.C-FZ to the processing for direct marketing purposes, Tubach L.L.C-FZ will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them, which is done by Tubach L.L.C-FZ for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may directly contact the data protection officer of Tubach L.L.C-FZ or another employee. The data subject is also free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use their right to object by automated means using technical specifications.

Every data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, as long as the decision

a) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or

b) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or

c) is based on the data subject's explicit consent.

If the decision

a) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or

b) it is based on the data subject's explicit consent, Tubach L.L.C-FZ shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, they may, at any time, contact our data protection officer or another employee of the controller.

Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of their personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, they may, at any time, contact our data protection officer or another employee of the controller.

9. Legal Basis for Processing

Article 6(1)(a) GDPR serves as the legal basis for our company for processing operations where we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third party. Then the processing would be based on Article 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations that are not covered by any of the above-mentioned legal grounds if the processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47, Sentence 2 GDPR).

10. Legitimate Interests in the Processing Pursued by the Controller or a Third Party

If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to carry out our business activities for the well-being of all our employees and our shareholders.

11. The Controller or Your Contact Person

If you have any questions about the collection, processing, or use of your personal data, for information, correction, blocking, or deletion of data, as well as the revocation of consents given or objection to a specific use of data, please contact:

Tobias Tubach
Tubach L.L.C-FZ
Email: hello@tubach.io