of OCSiAl Europe S.à r.l. available at http://tuball.com (the “Policy”)
Effective date: 12 May 2023
OCSiAl Europe S.à r.l. (a limited liability company registered and operating under the laws of the Grand Duchy of Luxembourg, registered with the Luxembourg Registre de Commerce et des Sociétés under number B204589, having its registered office at 1, rue de la Poudrerie, L-3364 Leudelange, Luxembourg) (referred to as “us”, “we”, “our”, “Company”) operates the following websites: http://tuball.com (the "Site").
This Policy defines how we act while collecting, processing, use, and/or disclosing information and personal data relating to identified or identifiable natural persons (any of them is referred to as “you” or “data subject”) collected from time to time from data subjects or third parties thorough the Site and/or from other publicly available sources.
By using the Site (including the “Contact us” form by leaving a message and filling the fields of the form), you, as the data subject, agree to the collection, processing, use, and possible disclosure of information in accordance with this Policy.
For the purpose of this Policy, the Company is the data controller on its behalf and on behalf of its affiliates who are other companies of the OCSiAl group of companies.
Types of Data Collected from Data Subject
We collect several different types of information for various purposes (as described below) to allow your use of the Site.
While using our Site and/or sending a message to us via the “Contact us” form, you may be asked to provide us with certain personally identifiable information ("Personal Data") which may include, but is not necessarily limited to:
- Email address;
- First name, Second Name, and Last name; and
- Phone number.
We may also collect information how the Site is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
Personal Data and Usage Data are collectively referred to as the “Data”.
Use of Data
Data provided by you to us may be used by us for the following purposes:
- To manage the Site;
- To monitor the usage of the Site;
- To notify you about changes to our Site and/or Policy;
- To provide support and assistance in connection with the Site;
- To provide analysis or valuable information so that we can improve the Site;
- To allow you to participate in interactive features of our Site when you choose to do so;
- To manage risks and litigations;
- To identify you;
- To analyze, structure, and prepare statistic on the classification of the users of the Site, such as determination of geographical allocation of the users, counting number of users by type of question, etc.;
- To process your message(-s) and/or requests sent to us;
- To provide you with reply(-ies) to message(-s) sent to us;
- To contact you, including by means of sending you email and/or call you by the phone number you provide to us;
- To provide you with news related to the Company;
- To ask you for the provision of feedback in respect of the Site, the Company, or related matters
- To comply with a legal obligation;
- To protect and defend the rights or property of the Company;
- To prevent or investigate possible wrongdoing in connection with the Site;
- To protect the personal safety of users of the Site or the public; and
- To protect against legal liability.
Disclosure of Data
The Company may disclose and transfer your Data to the following categories of recipients:
- subcontractors, business partners and professional advisors (e.g. auditors);
- other companies of OCSiAl Group (affiliates of the Company);
- supervisory bodies or public authorities.
By agreeing with this Policy you provide us with an unconditional and unequivocal consent to any possible disclosure and transfer of your Data to the recipients as described above and such consent shall be deemed sufficient for the purpose of our compliance with General Data Protection Regulation of the European Union (if applicable to you).
Transfer of Data Outside the European Union
Your Data may be transferred to — and maintained on — computers located outside of your country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction, including the situations when the data processing may occur out of a territory of a Member State of the European Union or another signatory state to the EEA Treaty (if applicable to you).
If you are located in any Member State of the European Union or another signatory state to the EEA Treaty and provide Data to us, please note that we may transfer the Data, including, for the avoidance of doubt, Personal Data, to the territories which are outside of the territory of the European Union or another signatory state to the EEA Treaty and process it there.
Your consent to this Policy followed by your submission of such information represents your agreement to that transfer. Additionally, in case applicable to you, you hereby grant to us an unconditional and unequivocal consent and you hereby unconditionally and unequivocally agree that the Data may be transferred, processed, and used in the jurisdiction other than a Member State of the European Union or another signatory state to the EEA Treaty and such consent shall be sufficient for the purpose of our compliance with General Data Protection Regulation of the European Union.
If you are using Tuball.cn (or any other .cn website), your personal data will be stored on servers located in China and in accordance with P.R.C. law.
Security of Data
We securely store your data at Company-managed virtual servers in the European Union, hosted by Microsoft Azure (https://azure.microsoft.com/en-us/support/legal/).
The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Data, we cannot guarantee its absolute security.
The Company will take steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Policy; and no transfer of your Data will take place to an organization or a country unless there are adequate controls in place ensuring the security of your Data.
Your Rights in Connection with the Data
To the extent permitted by the applicable laws, you, as the data subject, are entitled to:
- request from us the information about the content of your Data which we have in our disposal, the conditions of handling your Data, and compliance with the applicable laws;
- request us to discontinue the processing and use of and to erase your Data;
- request us to rectify (correct) any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
- object the processing of the Data.
To exercise your rights specified above you shall send us a respective request via registered mail or email, which request should demonstrate your identity and contain description of your request. If you make a request, we have one month to respond to you.
Additionally, note that, in case you believe your rights as the data subject are violated, you are entitled to file a complaint with the competent authority, which competent authority in Luxembourg is the National Commission for Data Protection (Commission Nationale de Protection des Données). Its contact details are:
Address: 15, Boulevard du Jazz, L-4370 Belvaux
Tel.: (+352) 26 10 60 -1
Without prejudice to any provision of this Policy, including any of your right as the data subject, the Data will remain kept by the Company and processed where it is required to comply with the applicable laws and regulations.
Completeness of Data
You must inform the us immediately and fully, if you are or become aware (e.g. upon receipt of the information about the content of your Data from us) of any errors or incompleteness of your Data collected, processed, and used by us.
Term of the Processing
Your Data will be stored and used by us in the form which permits identification of the data subject for a period of time which is not longer than is necessary for the purpose for which the Data has been collected, without prejudice to any automatic backups of Data and our obligations arising out of applicable laws and regulations.
Links to Other Sites
Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Our Site does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Data, please contact us. If we become aware that we have collected Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes to This Policy
We may update our Policy from time to time in order to comply with applicable laws and/or in order to have this Policy in compliance with the actual way of processing Data used by the Company.
You shall review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.
If you have any questions about this Policy or identify any misuse of your Data and/or any violation in respect of the Data provided to us, please contact us:
By email: firstname.lastname@example.org
By phone number: +352 2 088 1464
Address: 1, rue de la Poudrerie, L-3364 Leudelange, Luxembourg