TU VUELTO, Privacy Statement and Data Protection Declaration
Effective Date: 25th of May, 2018
Following the art. 13 of the Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, we have updated our Privacy Statement, which you can find below.
In the Company we are committed to making sure that absolutely everything we do is always Data-Privacy-Compliant by Design. That means that you don’t have to worry about us collecting, sharing, storing, or even worse, losing your personal data; we couldn’t even if we tried. Information that is not collected can’t be lost, stolen demanded, leaked or exposed.
We have made sure that the only information the Company saves can’t be linked back to you or anyone else. That information is very limited, non-personal and even obfuscated to make sure it can’t be associated with a particular individual. This information is for statistical purposes only. It helps us improve our service and products, without ever compromising you.
It is important that you understand what is defined by the GDPR as personal data, in order to fully comprehend exactly what we do. As defined in Article 4 of the GDPR, under Definitions:
“‘personal data’ means any information relating to an identified or identifiable natural person (‘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;”
(GDPR Art.4, https://gdpr-info.eu/art-4-gdpr/)
Collection and Processing:
When do we collect personal data about you?
We do not store your personal data.
Personal data of underage users?
We do not store the Personal Data of anyone, that includes underage users.
Why do we collect and use personal data?
We can’t say why we do it, as we don’t collect any personal data.
What type of personal data is collected?
There are a few exceptions where personal data may be collected, but never without your consent. This might happen through our Contact form, in our Social Media, by Google Analytics, if you send a Job Application, desire to work with us, or if you choose to perform direct sales activities where legitimate and mutual interest is established.
If you decide to contact us through the contact form in our website, we will ask you for your email and name to be able to get in contact with you. In case you do decide to contact us, we will delete your email address, name and all correspondence between the Company and you, in no longer than 30 days once the issue or question has been resolved. As is your right, if you want your information deleted at any time during the process, we will, in no longer than 30 days after the request.
However, due to the activation of IP anonymization (IP-Masking) on our website, your IP address will be truncated and thereby anonymised by Google within member states of the European Union or other parties to the Agreement on the European Economic Area.
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. The information may be transferred to third parties, if required by law or if third parties process this data in the order.
You can prevent the storage of cookies by a corresponding setting of your browser software; however, we point out that you may not be able to use all features of this website in full. In addition, you may prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and processing Google’s data by using the browser deactivation feature available at the following link. Download and install add-on: http://tools.google.com/dlpage/gaoptout?hl=en .
What are our processing methods?
Although the Company does not store, have access to, share, or use any of your personal data, we still use data to have statistically-relevant insights that helps us run our business. That means, that we do collect, process and store data, just not any personal data of yours. In each and every case where we collect data that might be considered personal data, we obfuscate that data to eliminate all possibilities of it being linked to an specific person. This process that is known, under the GDPR guidelines, as pseudonymisation, takes information such as your IP Address (which is personal data) and converts it into anonymous data that can only serve for statistical purposes. This process is done automatically, it is irreversible and allows us to work with data without compromising your privacy.
Links to other websites?
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question. We will immediately remove any links of this type upon being notified of such violations.
Storage and Security:
Do we retain your personal data?
We do not retain any of your personal data.
How long do we keep your personal data?
It is impossible to say, because we don’t store any of your personal data.
Do we share your personal data with anyone?
We would have to store it to share it. But we don’t. So we don’t.
Do we disclose or disseminate your personal data?
No, we do not disclose or disseminate your personal data.
How do we keep your personal data secure?
We keep your data secure by not collecting it.
Do we transfer personal data internationally?
No, we do not.
What are cookies?
Cookies are text files/pieces of information, where the story of your experience on a website is written. Cookies can collect data such as: number of page views, visitor browser types, operating systems, which links did you click in a website, among many others.
For what purpose?
The Company’s website exists so that you can find information about our products, services and be able to get in contact with us. That is all it is. We do not use our website for anything else. So there is no need for collecting any personal data about you.
The only cookies that we use are the ones that allow us to give you a comfortable browsing experience. These cookies tell us your language of preference (our website is set to English, Portuguese, Spanish, German and Russian) so that you can read the website with ease, and what device you are using so that the responsive design can adapt to the size of the browser appropriately. These cookies do not collect any personal data. We have them in place, so that the website can function optimally. Our cookies don’t track you, they are meant to make your browsing easier.
Regardless of the cookie type and our best intentions, you can always choose to opt-out. We wouldn’t hold that against you; our priority will always be to respect your privacy in every aspect. The easiest way to do it is by not accepting to receive cookies from our website when you enter for the first time. If you have already accepted you can disable them by sending an email to the Controller.
Data Subject’s rights:
Even though we don’t collect any personal data, we think it is important that you understand your rights in regards to your personal data. These are the rights that are stipulated under the GDPR, to which you are entitled to:
The right to be informed – all organisations must be completely transparent in how they are using personal data (personal data may include data such as a work email and work mobile if they are specific to an individual).
The right of access – individuals will have the right to know exactly what information is held about them and how it is processed.
The right of rectification – individuals will be entitled to have personal data rectified if it is inaccurate or incomplete.
The right to erasure – also known as ‘the right to be forgotten’, this refers to an individual’s right to having their personal data deleted or removed without the need for a specific reason as to why they wish to discontinue.
The right to restrict processing – an individual’s right to block or suppress processing of their personal data.
The right to data portability – this allows individuals to retain and reuse their personal data for their own purpose.
The right to object – in certain circumstances, individuals are entitled to object to their personal data being used. This includes, if a company uses personal data for the purpose of direct marketing, scientific and historical research, or for the performance of a task in the public interest.
Rights of automated decision making and profiling – the GDPR has put in place safeguards to protect individuals against the risk that a potentially damaging decision is made without human intervention. For example, individuals can choose not to be the subject of a decision where the consequence has a legal bearing on them, or is based on automated processing.
If you want to exercise any of these rights, or feel that we might be doing something against them, please contact the Controller, we will resolve any matter in less than 30 days.
Changes to this privacy statement: