I. Name and address of the processor

Turimbi UG (haftungsbeschränkt)
Im Mühlenpark 18
52355 Dueren
Germany
Tel. 02421/991803
Email: info@turimbi.com

Name and address of the data protection officer:

Erik Roeth Hauptstrasse 142
52379 Langerwehe
Germany
Tel.: +49 2423 6450
Email: datenschutzbeauftragter@turimbi.com

II. General information on data processing

Turimbi UG (haftungsbeschränkt) commits to protect your privacy and therefore uses technologies that enable an efficient and at the same time safe online use. This Privacy Policy pertains to the website of Turimbi UG (haftungsbeschränkt) and regulates the collection and use of your personal data.

By using the Turimbi UG (haftungsbeschränkt) website, you agree to accept procedures described below.

Collection of your personal data

Turimbi UG (haftungsbeschränkt) collects and stores the data of our customers only to the extent to which it is necessary for a regulated business operation, predominantly your ordering process in our web shop. This stored data include particularly all the information we are obliged to process and store due to legal regulations for accounting and bookkeeping purposes.

Turimbi UG (haftungsbeschränkt) stores personal data such as email address, name, address and telephone number. Your personal data will be stored by Turimbi UG (haftungsbeschränkt) only if you enter it voluntarily at registration as a customer on our website. Turimbi UG (haftungsbeschränkt) stores this data with your consent as your personal profile so that you can comfortably register with your user name and password for future visits at turimbi.com at any time. This has the advantage that you do not have to re-type your address every time you place an order.

In the following you can object to the utilization of this data and exclude such use for the future. In this case your personal data stored by Turimbi UG (haftungsbeschränkt) will be deleted. However, in this case, a new and complete registration is necessary before you can use the Turimbi UG (haftungsbeschränkt) Website again. According to the rules of the German Teleservices Act (“Telemediengesetz”) and German Federal Data Protection Act (“Bundesdatenschutzgesetz”) you have the right to obtain information regarding personal data stored by Turimbi UG (haftungsbeschränkt) on request and at no cost. Furthermore, you have the right to the correction, barring and/or deletion of your personal data stored by Turimbi UG (haftungsbeschränkt). If you have questions with regard to the content of this Privacy Policy and/or would like to exercise your legal rights to the correction, barring and deletion of this data, please contact our specialist at info@turimbi.com.

If you disclose your personal data to Turimbi UG (haftungsbeschränkt) only for the purpose of taking part in a competition, this data will only be stored and used for the proper execution of the concerned competition. We will not pass on this personal data, including the address and email address, to third parties without your consent except to logistics companies to whom we submit the required data in the case of a win. As soon as the competition is finished and all prizes are delivered, all data stored only for the purpose of participating in the competition, will be deleted. You can revoke the declaration of consent required to participate in competitions of Turimbi UG (haftungsbeschränkt) individually or entirely by sending a corresponding declaration to Turimbi UG (haftungsbeschränkt), Im Mühlenpark 18, 52355 Düren, GERMANY or by email to info(at)turimbi.com at any time with immediate effect in the future.

Turimbi UG (haftungsbeschränkt) also stores anonymous demographical information that is not clearly related to you such as postal code, age, gender, interests and favorites.

Some details about your computer hardware and software are collected automatically by Turimbi UG (haftungsbeschränkt), including your IP address, the type of your browser, your domain name, the access time and the pages of interest. These details are used by Turimbi UG (haftungsbeschränkt) in order to maintain the quality of service and to create general statistics concerning Turimbi UG (haftungsbeschränkt).

Persons under the age of 18 should not transmit personal data to Turimbi UG (haftungsbeschränkt) without the consent of their parents or legal guardians. We do not request, collect and pass on personal data from children and youths to third parties. The website https://turimbi.com does not offer any products for sale to minors.

Please keep in mind that personal data you publish in publicly accessible areas such as guest books etc. can be misused by other users.

Note: Turimbi UG (haftungsbeschränkt) does not read your private online communication. Turimbi UG (haftungsbeschränkt) requests you to check the Privacy Policy of the websites which Turimbi UG (haftungsbeschränkt) links to so that you understand how these websites store and use your personal data. Turimbi UG (haftungsbeschränkt) is not responsible for the Privacy Policy of other websites out of Turimbi UG (haftungsbeschränkt).

Using your personal data

Turimbi UG (haftungsbeschränkt) stores and uses your personal information in order to manage the Turimbi UG (haftungsbeschränkt) website and offer the desired level of services. Turimbi UG (haftungsbeschränkt) also uses your personal data in order to inform you about new products and services of Turimbi UG (haftungsbeschränkt). Turimbi UG (haftungsbeschränkt) may also contact you via surveys to conduct research about your opinion on current services and potential new upgrades.

Turimbi UG (haftungsbeschränkt) will neither sell its customer list to third parties nor rent it. Turimbi UG (haftungsbeschränkt) may occasionally inform you on behalf of other business partners about a specific offer that may be of interest to you. In such a case, your personal details including email address, name or telephone number are never released to a third party.

Additionally, Turimbi UG (haftungsbeschränkt) may share anonymous data with partners in order to do statistical analysis. All such third parties are prohibited from using your personal details except to provide these services to Turimbi UG (haftungsbeschränkt). We consider this to be an essential measure in maintaining your personal trust.

Turimbi UG (haftungsbeschränkt) will not disclose sensitive personal data such as race, religion or political attitude. Turimbi UG (haftungsbeschränkt) keeps track of your visit within the websites of Turimbi UG (haftungsbeschränkt) in order to determine what services are most popular. This data can be used to deliver customized content. This shall apply to visitors with a specific interest.

Disclosure of personal data

On presentation of a judicial order Turimbi UG (haftungsbeschränkt) will pass on your personal data to the investigating authorities without informing you. We also reserve the right to use your personal data for judicial arguments, should we see ourselves impelled to do so.

Use of cookies

Turimbi UG (haftungsbeschränkt) uses cookies to facilitate usability. A cookie is a text file which is stored by a server on your PC’s hard drive. Cookies cannot be used to run programs or spread viruses. Cookies are personally attributed to you and can only be read from a web server in the domain you have established. One of the main reasons for the use of cookies is to facilitate convenient use of the website and to save time. The purpose of a cookie is to tell the web server that you have returned to a specific page. This is, for instance, the case if you register at Turimbi UG (haftungsbeschränkt). The online cookie helps Turimbi UG (haftungsbeschränkt) to re-use specific data for future visits. This should help you in entering your personal data such as invoice and delivery address.

If you return to the same Turimbi UG (haftungsbeschränkt) website, the information you previously provided can be retrieved and is available. That way the properties of Turimbi UG (haftungsbeschränkt) can be customized. You have the option to accept or reject cookies. Most web browsers accept these cookies automatically, but you can configure your browser in such way as to store only the cookies of your preferred websites. Should you decide to reject the use of cookies, it may occur that your use of interactive offers at Turimbi UG (haftungsbeschränkt) is no longer possible.

Safety of your personal data

Turimbi UG (haftungsbeschränkt) protects your personal data from unauthorized access, use or disclosure. Turimbi UG (haftungsbeschränkt) secures the personal information you provide on the server in a controlled and secure environment protected from unauthorized access and disclosure. If safety-related personal data such as credit card numbers are transmitted to other websites, you will be protected by encryption “Secure Socket Layer” (SSL).

Changes of this Privacy Policy

Turimbi UG (haftungsbeschränkt) reserves the right to update the Privacy Policy if required in order to adapt it to customer feedback as well as to legal and social changes. Turimbi UG (haftungsbeschränkt) will inform you about these changes on the website or by email. The changes become valid provided that you do not submit a written appeal to Turimbi UG (haftungsbeschränkt) within four weeks.

Contact

Turimbi UG (haftungsbeschränkt) welcomes any feedback concerning this Privacy Policy. If you have any questions or suggestions, please contact info (at) turimbi.com. We will get in touch with you as soon as possible. You will find our address and telephone number for written or personal contact in the impressum of the website.

Note on Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (Google). Google Analytics uses “cookies” which are text files placed on your computer to help the website analyze how users use the website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United State of America. In case of activation of IP-anonymisation on this website, your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement to the European Economic Area. Only in exceptional cases the whole IP address will be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activities and providing other services relating to website and internet usage to the operator. The IP address that your browser conveys within the scope of Google Analytics will not be linked with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings in your browser, however please note that if you do so, you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and the related information on your use of the website to Google as well as the processing of this data by Google by downloading and installing the available browser plugin under the following link http://tools.google.com/dlpage/gaoptout?hl=de

Click here if you object to the data collection by Google Analytics and would like to leave the website turimbi.com.

III. Rights of data subjects

Provided your personal data is processed, you are considered the data subject as per GDPR and are entitled to the rights listed below with regard to the processor.

1. Right to be informed

You can demand a confirmation of whether personal data related to you is processed. Should this be the case, you can demand the following information:

• (1) The purposes for which the personal data is processed;
• (2) The categories of the personal data processed;
• (3) The recipients/categories of recipients receiving the personal data related to you;
• (4) The planned storage period for the personal data related to you or, if no concrete information is possible, criteria for determining the storage period;
• (5) Existence of a right to rectification or erasure of the personal data related to you, a right to restrict processing by the processor, or a right to object to this processing;
• (6) The existence of a right to appeal to the authorities.
• (7) All available information on the origin of the data if the personal data is not collected from the associated individual;
• (8) The existence of an automated decision making solution including profiling, as per Art. 22 Sec. 1 and 4 GDPR and – at least in these cases – meaningful information on the involved logic as well as the reach and target effect of such processing for the concerned individual.

You have the right to be informed of whether the personal data related to you is transmitted to a third country or an international organization. In this context, you can request to be informed of appropriate safeguards as per Art. 46 GDPR in conjunction with the transmission of your data.

2. Right to rectification

You have the right to rectification and/or completion provided the processed personal data related to you is incorrect or incomplete. The data processor must promptly rectify the issue.

3. Right to restrict processing

You can exercise your right to restrict processing of the personal data related to you provided the following conditions are met:

• (1) If you dispute the accuracy of the personal data related to you for a period that enables the processor to verify the accuracy of the data;
• (2) Processing is wrongful, and you reject the deletion of your personal data, instead exercising your right to restrict the use of your personal data;
• (3) The processor no longer requires the personal data for processing, but you need it to assert, exercise, or defend legal claims.
• (4) If you have exercised your right to object to processing as per Art. 21 Sec. 1 GDPR and it has not been determined whether the the legitimate interest of the processor outweigh your interest.

If processing of the personal data related to you has been restricted, this data may only be processed (besides storage) with your express consent or to assert, exercise, or defend legal claims, or to protect the rights of other natural or legal persons, or for reasons of an important public interest of the European Union or a member state.

 If restriction of processing was lifted based on the requirements above, you will be notified by the processor before this restriction is lifted.

4. Right to erasure

a) Obligation of erasure

You can demand the processor to delete any personal data related to you right away and the processor is required to delete this data provided one of the following reasons applies:

• (1) The personal data related to you is no longer needed for the purpose for which it was collected or processed in any other way.
• (2) You withdraw your consent for processing based on Art. 6 Sec. 1 a or Art. 9 Sec. 2 a GDPR and there is no other legal basis for processing.
• (3) As per Art. 21 Sec. 1 GDPR, you object to processing and there are no superior legitimate reasons for processing; or, you object to processing as per Art. 21 Sec. 2 GDPR.
• (4) The personal data related to you was processed unlawfully.
• (5) Deletion of the personal data related to you is required to fulfil a legal obligation in line with EU law or law of member states to which the processor is subject.
• (6) The personal data related to you was collected as per Art. 8 Sec. 1 GDPR with regard to the services offered by the information society.

b) Information to third parties

If the processor has published your personal data and is obligated to delete this data as per Art. 17 Sec. 1 GDPR, the processor shall take suitable measures taking into account the available technology and implementation costs, including those of a technical nature, to inform the processor responsible for processing the personal data that you as data subject have requested the deletion of all links to this personal data or of copies or replications of this personal data.

c) Exceptions

The right to erasure does not apply if processing is required

• (1) to exercise the right to free expression of opinion and information;
• (2) to meet a legal obligation requiring processing in accordance with the law of the European Union or a member state to which the processor is subject, or to carry out a duty in the public interest or in exercising official authority assigned to the processor;
• (3) for reasons of public interest in the area of public health as per Art. 9 Sec. 2 h as well as Art. 9 Sec. 3 GDPR;
• (4) for archiving purposes in the public interest, economic or historical research purposes, or for statistical purposes as per Art. 89 Sec. 1 GDPR provided that the right named in a) is not expected to render attainment of the objectives of this agreement impossible or have a serious negative effect, or
• (5) To assert, exercise, or defend legal claims.

5. Right to be informed

If you have exercised your right to rectification, erasure, or to restrict processing vis-à-vis the processor, the processor is obligated to notify all recipients to which your personal data was disclosed of rectification or deletion of the data, or restriction to its processing, unless this proves to be impossible or requires a disproportional amount of effort. You have the right to be informed of these recipients by the processor.

6. Right to data portability

You have the right to receive the personal data related to you that you have provided to the processor in a structured, commonly used, machine-readable format. In addition, you have the right to pass on this data to another processor without interference of the processor to which you have provided the personal data, provided

• (1) Processing is based on consent as per Art. 6 Sec. 1 a GDPR or Art. 9 Sec. 2 a GDPR, or on a contract as per Art. 6 Sec. 1 b GDPR and
• (2) Processing is carried out by automated processes.

In exercising this right, you also have the right to demand your personal data be transferred directly from one processor to another processor, provided this is technically feasible. This must not negatively affect the freedoms and rights of other individuals.

The right to data portability does not apply to processing of personal data required or to carry out a duty in the public interest or in exercising official authority assigned to the processor.

7. Right to object

You have the right to object to the processing of your personal data based on Art. 6 Sec. 1 e or f GDPR for reasons resulting from your particular situation at any time; this also applies to profiling based on these provisions.

•  The processor no longer processes your personal data unless the processor can provide compelling legitimate reasons that outweigh your interests, rights, and freedoms, or processing serves to assert, exercise, or defend legal claims.
•  If the personal data related to you is processed to carry out direct advertising, you have the right to object to the processing of your personal data for the purpose of such advertising at any time; this also applies to profiling provided directly related to such direct advertising.
•  If you object to processing for purposes of direct advertising, your personal data will no longer be processed for this purpose.

 You have the option to exercise your right to object by means of an automated process which uses technical specifications in connection with the use of services provided by the information society, directive 2002/58/EC notwithstanding.

8. Right to withdraw consent to use of data

You have the right to withdraw your consent to the use of your data at any time. Withdrawing your consent does not affect the lawfulness of the processing taking place based on your consent up to withdrawal.

9. Automated decision including profiling in individual cases

You have the right to not be subjected to a decision based solely on automated processing, including profiling, that has a legal effect on you or affects you significantly in a similar manner. This does not apply if the decision

• (1) Is required to conclude or fulfil a contract between you and the processor,
• (2) Is permissible based on legal provisions of the European Union or a member state to which the processor is subject and these legal provisions contain suitable measures to protect your rights and freedoms as well as your legitimate interests, or
• (3) Is carried out with your express permission.

However, these decisions shall not be based on special categories of personal data as per Art. 9 Sec. 1 GDPR provided Art. 9 Sec. 2 a GDPR applies and suitable measures have been taken to protect your rights and freedoms as well as your legitimate interests.

With regard to the cases named in (1) and (3), the processor shall take appropriate measures to ensure your rights and freedoms as well as your legitimate interests, including at least the right to request an individual on the side of the processor to intervene, to present your own position, and to contest the decision.

10. Right to appeal to the authorities

Notwithstanding any other administrative or judicial decision, you have the right to appeal to the authorities, especially in the member state where you are located, your workplace, or the location of the alleged violation if you believe that the processing of your personal data is in violation of GDPR.

The authority receiving the appeal shall inform the appealing party of the status and result of the appeal, including the option for a legal decision as per Art. 78 GDPR.

The Privacy Policy is a translation of the original German version "Datenschutzerklärung"" of Turimbi UG (haftungsbeschränkt). In case of doubt, the German-language version shall apply.