Privacy Policy
Last updated: February 2026
1. Introduction
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 visit our website.
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 visit our website is:
IP Address
Your Internet Protocol (IP) address is automatically transmitted when you access our website. This is a technical necessity for delivering web 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 website functionality.
4. Purpose and Legal Basis
We process your IP address for the following purposes:
Website Delivery
Technical necessity to deliver website 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:
Commission Nationale pour la Protection des Données (CNPD)
15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg
Website: cnpd.public.lu
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 website 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:
www.trubient.com