Privacy Policy
We value your privacy and recognize the sensitivity of your personal information. We are committed to protecting your personal information and using it only as appropriate to provide you with the best possible service, products, and opportunities, as described in this Privacy Policy.
This Privacy Policy explains the online information practices of TrogX Solutions Ltd. (collectively, “Company,” “TrogX,” “TrogX Solutions,” “we,” “us,” or “our”) We think it is important to explain what information we collect, what we do with it and to describe the rights you will have with respect to the data.
Please note that when visiting the website, this Privacy Policy should be read in conjunction with our Terms of Use. By accessing website, you acknowledge that the Privacy Policy and the Terms of Use govern your use of the website.
The controller of your personal information is TrogX Solutions Ltd.
Privacy and personal data protection principles vary from one country to another. When you access or visit a third party website, you are subject to the privacy policy of that website. Please read the third party’s privacy policy to determine the privacy practices that apply to information or data maintained by the website or application.
I. What Information We Collect And How It Is Used
We may collect and hold personal information related to you that is necessary for the purpose of conducting our business, including (without limitation) to deliver products, services or information, improve our services to offer better experience, and to fulfill our regulatory obligations. We will tell you when we ask for your information whether it is a statutory or contractual requirement to give us the information and the consequences of not providing the information.
To undertake above the goals, we may collect the following personal information related to our users:
Contact Profile: We may collect information that you submit when you contact the customer support, or otherwise submit information to the Company, including email address, and other information submitted during your use of the application.
Cookies: Cookies are small files which enable the website to provide certain features and functionality. We and our service providers use cookies to automatically collect information, measure and analyze which of our pages you click on and how you use the application, enhance your experience using the application, improve our services. Cookies may include information such as user preferences, time spent on a website and pages visited. We may also use third-party tracking technology to record similar information regarding you and your activity on the application. Google Analytics may collect your IP address, data related to the device/browser, or other information about your use of the application and may do so using cookies. Google Analytics’ data practices are governed by the Google Privacy Policy, as it may be amended from time to time. By using the application, you consent to our use of Cookies.
Consent with Borlabs Cookie: Our website uses Borlabs Cookie Consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document this in accordance with data protection law. The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter Borlabs).
When you enter our website, a Borlabs cookie is stored in your browser, which stores the consents you have given or revoked. This data is not shared with the provider of Borlabs Cookie.
The collected data will be stored until you request us to delete it or delete the Borlabs cookie yourself, or until the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details about the data processing of Borlabs Cookie can be found at
https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/
The use of Borlabs cookie consent technology is done in order to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.
Analysis tools
Google Tag Manager: We use the Google Tag Manager. Anbieter ist die Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland. Google Tag Manager is a tool that allows us to embed tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create user profiles, does not store cookies and does not perform any independent analyses. It is only used for the administration and playout of the tools integrated via it. However, Google Tag Manager collects your IP address, which may also be transferred to Google’s parent company in the United States. The use of the Google Tag Manager is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on its website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 Para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
Google Analytics: This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics enables the website operator to analyse the behaviour of website visitors. In this context, the website operator receives various usage data, such as page impressions, duration of visit, operating systems used and origin of the user. This data is assigned to the respective end device of the user. There is no assignment to a device ID. Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Furthermore, Google Analytics uses various modeling approaches to augment the data sets it collects and employs machine learning technologies in its data analysis. Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there. The use of this service is based on your consent according to Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG. The consent can be revoked at any time. Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://privacy.google.com/businesses/controllerterms/mccs/
Browser Plugin: You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link:
https://tools.google.com/dlpage/gaoptout?hl=de
For more information on how Google Analytics handles user data, please see Google’s privacy policy:
https://support.google.com/analytics/answer/6004245?hl=de
Job processing: We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
II. How Information Is Used
| Purpose | Legal Basis |
| To provide support and to respond to your requests and enquiries | We have a legitimate interest to respond to your requests and inquiries for ongoing business administration |
| To personalize your visits to the website and to assist you while you use the website | We have a legitimate interest in providing and improving the application |
| To deliver the website‘s services | |
| To improve the website by helping us understand who uses the website and how it is being used | |
| To share data with our service providers, such as those that host data for us, including Amazon Web Service | We have a legitimate interest in using vendors to provide business services |
| We have a legitimate interest in improving our services | |
| To respond to law enforcement organization, or other government officials where we have a legal obligation, including complying with legal demands and complying with production and court orders. We will notify user of the information request or submission as, and if, allowed. | We have a legitimate interest in complying with applicable legal or regulatory obligations |
| The day to day running and management of the business including to monitor, maintain and improve the processes, information and data, technology and communications solutions and services we use; protect our legal rights and interests; and share such personal information with third parties that acquire or are interested in acquiring all or part of our assets or shares, or that succeeds us in carrying on our business; | We have a legitimate interest to manage our business including to maintain ongoing operations and to improve and strengthen our operations |
III. Your Right to Object – Please note that you have a right to object to processing of your personal information where that processing is carried out for our legitimate interest.
IV. Data Retention
We retain your personal information for as long as it is necessary and relevant for our business. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the personal information (e.g. data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).
V. Data Rights
You have the right (subject to certain limitations) to: (i) request access to personal information we hold about you; (ii) the correction of your personal information when incorrect, out of date or incomplete; (iii) request that we delete your personal information; (iv) opt-out of any marketing communications that we may send to you and to object to us using / holding your personal information if we have no legitimate reason to do so; and (v) the portability of personal information i.e., ask for a copy of your personal information to be provided to you, or a third party, in a digital format. Where we are relying on your consent to handle your personal information, you have the right to withdraw your consent to this use at any time. We do not sell personal information to third parties for their own business/commercial uses.
All such requests should be made using the contact details set out below. Please note that if you request that your personal information be deleted, you may no longer be able to access or use certain parts of the service. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request. For more details in relation to your rights, including how to exercise them, please contact us using the contact details below.
You also have the right to log a complaint about the handling of your personal information with an EU data protection authority or other relevant regulator.
California residents may request certain information about our disclosure of personal data during the prior calendar year to third parties for their direct marketing purposes. We do not share your personal data with third parties or corporate affiliates for their direct marketing purposes.
VI. Security
We maintain security standards and procedures designed to prevent unauthorized access to your data by anyone, including our staff. We use commercially reasonable means such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your personal information. The Company and our staff and any third parties hired to provide support services will be required to observe our privacy standards and to allow us to audit them for compliance. However, no information security defenses are impenetrable, and we cannot guarantee the security of our applications, servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.
VII. International Audience
The website is hosted in Germany. Therefore, personal information collected from you, including via the website, will be transferred to Germany. Such transfer may not provide a similar level of protection to that provided by countries in foreign jurisdictions. As discussed above, we have a legitimate interest in utilizing service providers in Germany to provide you with the services.
Please do not use the website if you do not agree to the transfer and processing of your personal information in Germany or if it is illegal to do so in your home country.
VIII. Children’s Privacy
We do not knowingly collect personal information from children, under the age of 18, and in the event that we learn that a child under the age of 18 has provided information on our website, we will delete that information as soon as possible.
IX. Changes
This Privacy Policy sets out our current policies and demonstrates our commitment to your privacy. We may change the content or services found on the application at any time, and consequently our Privacy Policy may change at any time in the future and will be updated from time to time. Whenever we make changes to this Privacy Policy that are important for you to know about, we will post the updated Privacy Policy at this link.
X. Email Provider
We use MailerLite to manage our email marketing subscriber list and send emails to our subscribers. MailerLite is a third-party provider, which may collect and process your data using industry-standard technologies to help us monitor and improve our newsletter. MailerLite’s Privacy Policy is available at https://www.mailerlite.com/legal/privacy-policy. You can unsubscribe from our newsletter by clicking on the unsubscribe link provided at the end of each newsletter.
XI. Your Queries
If you have any questions regarding our privacy policy or if you wish to exercise your data rights as described above, email us for more information via info@trogx.eu. To ensure that we carry out your instructions accurately, to help us continually improve our service and in the interests of security, we may monitor and/or record your telephone calls with us.
Our contact information:
TrogX Solutions Ltd
Afroditis 3,
8522 Armou
Cyprus
Contact email: info@trogx.eu