Seite 1 von 5
General data protection policy
1. Name and contact details of the responsible person
Fiduciaire comptable Tibolt s.à r.l.
25a, rue de la montagne
The data protection officer of the firm can be reached under the above-mentioned
address and under the e-mail address stibolt[at]pt[dot]lu
2. Scope and purpose of the processing of personal data
2.1 Calling the website
When accessing this website www.tibolt.lu, the internet browser used by the visitor automatically
sends data to the server of this website and stores it for a limited time in a log file. Until
the automatic deletion, the following data is stored without further input by the visitor:
- IP address of the visitor's terminal,
- date and time of access by the visitor,
- Name and URL of the page accessed by the visitor,
- website from which the visitor accesses the website (so-called referrer URL),
- Browser and operating system of the visitor's terminal and the name of the access
provider used by the visitor.
The processing of these personal data is governed by Art. 6 (1) lit. f GDPR justified. The firm
has a legitimate interest in the processing of data for the purpose of
- build up the connection to the website of the company quickly,
- to enable a user-friendly application of the website,
- to identify and ensure the safety and stability of the systems and
- to facilitate and improve the administration of the website.
The processing is expressly not for the purpose of gaining knowledge about the person of
the visitor of the website.
2.2 Contact form
Visitors can submit messages to the firm via an online contact form on the website. In order
to be able to receive a reply, at least the specification of a valid e-mail address is required.
Seite 2 von 5
All further information can be given voluntarily by the requesting person. By submitting the
message via the contact form, the visitor consents to the processing of the transferred personal
data. The data processing takes place exclusively for the purpose of processing and
answering inquiries via the contact form. This is done on the basis of the voluntarily granted
consent acc. Article 6 (1) (1) (a) GDPR. The personal data collected for the use of the contact
form will be automatically deleted as soon as the request has been completed and there
are no reasons for further storage.
3. Disclosure of data
Personal data will be transmitted to third parties, in following cases:
- Express approval by the data subject under Article 6 (1) (1) (a) GDPR,
- Disclosure under Art. 6 (1) (1) (f) GDPR is required to assert, exercise or defend legal
claims and there is no reason to believe that the data subject has an overriding interest
in not disclosing their rights Has data,
- for the transmission of data according to Art. 6 (1) sentence 1 letter c) GDPR a legal
obligation exists, and / or
- this is required under Article 6 (1) (1) (b) GDPR to fulfill a contractual relationship with
the data subject.
In other cases, personal data will not be disclosed to third parties.
Cookies are used on the website. These are data packets that are exchanged between the
server of the firm's website and the visitor's browser. These are stored when visiting the
website of the devices used in each case (PC, notebook, tablet, smartphone, etc.). Cookies
can not cause any damage on the used devices. In particular, they contain no viruses or other
harmful software. In the cookies, information is stored, each resulting in connection with
the specific terminal used. The company cannot in any way obtain direct knowledge of the
identity of the visitor to the website.
Cookies are largely accepted according to the basic settings of the browser. The browser
settings can be set up so that cookies are either not accepted on the devices used, or that a
special notice is given before a new cookie is created. It should be noted, however, that the
deactivation of cookies may result in not all the features of the website being used in the best
For example, session cookies can be used to track whether the visitor has already visited
individual pages on the website. After leaving the website, these session cookies are automatically
To improve usability, temporary cookies are used. They are stored on the visitor's device for
a temporary period. Upon re-visiting the website, it is automatically recognized that the visitor
has visited the site at an earlier time and what inputs and settings have been made in order
not to have to repeat them.
Seite 3 von 5
Cookies are also used to analyze website views for statistical purposes and for the purpose
of improving the offer. These cookies make it possible to automatically recognize on a new
visit that the website has already been accessed by the visitor. An automatic deletion of
cookies takes place here after a specified time.
The data processed by cookies are for the above mentioned purposes of safeguarding the
legitimate interests of the firm under Article 6 (1) (1) (f) GDPR.
5. Your rights as a concerned person
As far as your personal data are processed during the visit of our website, you have the following
rights as "data subject" within the meaning of the GDPR:
You can ask us for information about whether personal data is processed by us. No right of
access exists if the granting of the coveted information is against the duty of confidentiality
and would violate the information for other reasons, in particular because of a predominant
legitimate interest of a third party that must be kept secret. Deviating from this, there may be
an obligation to provide the information if your interests outweigh the interest in maintaining
secrecy, in particular considering any imminent damage. The right of access is also excluded
if the data are stored only because they may not be deleted due to statutory or statutory retention
periods or serve exclusively for purposes of data protection or data protection control,
if the disclosure of information would require a disproportionate effort and processing for other
purposes is excluded by appropriate technical and organizational measures. If in your
case the right to information is not excluded and your personal data are processed by us,
you can ask us for information about the following information:
- purposes of processing,
- categories of personal data that you process,
- recipients or categories of recipients to whom your personal data are disclosed, in
particular for beneficiaries in third countries,
- if possible, the planned duration for which your personal data will be stored or, if this
is not possible, the criteria for the determination of the storage duration,
- the right of rectification or erasure or restriction of the processing of personal data
concerning you or a right of opposition to such processing,
- the existence of a right of appeal to a data protection supervisory authority,
- if the personal data have not been collected from you as the data subject, the information
available on the origin of the data,
- the existence of automated decision-making, including profiling and meaningful information
on the logic involved, as well as the scope and intended impact of automated
decision-making, where appropriate;
- if applicable, in the case of transmission to recipients in third countries, unless there is
a decision by the EU Commission on the adequacy of the protection level under Art. 45
Seite 4 von 5
(3) GDPR, information on which suitable guarantees pursuant to Art. Art. 46 para. 2
GDPR for the protection of personal data.
5.2 Correction and completion
If you discover that we have inaccurate personal information, you may require us to promptly
correct this incorrect information. In the case of incomplete personal data concerning you,
you can request the completion.
They are entitled to be deleted ("right to be forgotten"), unless the processing is necessary
for the exercise of the right to freedom of expression, the right to information or to fulfill a legal
obligation or to perform a task of public interest and one of the following is true:
- The personal data are no longer necessary for the purposes for which they were processed.
- The justification for processing was only your consent, which you have revoked.
- You have objected to the processing of your personal data that we have made public.
- You have objected to the processing of personal data not disclosed to us and there
are no legitimate reasons for the processing.
- Your personal data has been processed unlawfully.
- The deletion of personal data is required to fulfill a legal obligation to which we are
There is no entitlement to cancellation if, in the case of legitimate non-automated data processing,
deletion is not possible or only possible with disproportionately high outlay due to
the special nature of the storage and your interest in deletion is low. In this case, the deletion
is replaced by the restriction of processing.
5.4 Limitation of processing
You may require us to restrict processing if any of the following applies:
- You deny the accuracy of your personal data. The restriction may be required in this
case for the duration that allows us to verify the accuracy of the data.
- The processing is unlawful, and you require instead of deletion the restriction of the
use of your personal data.
- Your personal information is no longer needed by us for the purposes of processing,
but you need to assert, exercise or defend legal claims.
- You have contradiction gem. Art. 21 para. 1 DSGVO. The limitation of processing
may be required if it is not certain that our justified reasons outweigh your reasons.
Restriction of processing means that the personal data will be processed only with your consent
or to assert, exercise or defend legal claims or to protect the rights of another natural or
Seite 5 von 5
legal person or for reasons of important public interest. Before we lift the restriction, we have
a duty to inform you.
5.5 Data portability
You have the right of data transferability if the processing is based on your consent (Article 6
(1) sentence 1 (a) or Article 9 (2) (a) GDPR) or on a contract to which you are a party and the
processing is done using automated procedures. The right to data portability in this case includes
the following rights, if this does not affect the rights and freedoms of others: You may
require us to provide the personal information you provide to us in a structured, common and
machine-readable format to obtain. You have the right to transmit this data to another person
without hindrance on our part. As far as technically feasible, you may require that we transfer
your personal data directly to another person in charge.