Privacy policy for the Trubient application

1. Introduction

This Privacy Policy applies to the Trubient application. esgwize S.A. who is the major shareholder of Trubient ("esgwize", "we", "us", or "our"), headquartered in Luxembourg, is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, and safeguard information when you use the Trubient application.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable Luxembourg data protection laws.

2. Data Controller

The data controller responsible for processing your personal data is:

3. Data We Collect

We maintain a minimal data collection approach. The only personal data we automatically collect when you use the Trubient application is:

IP Address
Your Internet Protocol (IP) address is automatically transmitted when you access our application. This is a technical necessity for delivering application content to your device.

We do not use cookies for tracking purposes. We do not use third-party analytics services. We do not collect browsing behavior, device fingerprints, or any other form of tracking data beyond the IP address necessary for application functionality.

4. Purpose and Legal Basis

We process your IP address for the following purposes:

Application Delivery

Technical necessity to deliver application content to your browser

Security

Protection against malicious attacks and fraud prevention

Error Diagnosis

Troubleshooting technical issues to maintain service quality

Legal Basis

Processing based on legitimate interests (Article 6(1)(f) GDPR)

5. Data Retention

IP addresses are retained in our server logs for a maximum period of 30 days. After this period, the data is automatically and permanently deleted. We do not archive, aggregate, or use IP address data for any purpose beyond those stated in this policy.

6. Your Rights Under GDPR

Under the GDPR, you have the following rights regarding your personal data:

Right of Access

Request confirmation of processing and a copy of your data

Right to Rectification

Request correction of inaccurate personal data

Right to Erasure

Request deletion of your personal data ("right to be forgotten")

Right to Restrict Processing

Request limitation of how we use your data

Right to Object

Object to processing based on legitimate interests

Right to Lodge a Complaint

File a complaint with a supervisory authority

To exercise any of these rights, please contact us at contact@esgwize.com. We will respond to your request within 30 days.

7. Supervisory Authority

If you believe that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the competent supervisory authority. For Luxembourg, this is:

8. Data Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including encryption of data in transit (TLS/SSL), secure server infrastructure, access controls, and regular security assessments. Our application is hosted on Google Cloud Platform infrastructure within the European Union.

9. International Data Transfers

Your IP address data is processed and stored exclusively within the European Economic Area (EEA). We do not transfer personal data to third countries or international organizations outside the EEA.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us: