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General data protection policy

1. Name and contact details of the responsible person

This privacy policy informs about the processing of personal data on the website of

Fiduciaire comptable Tibolt s.à r.l.

25a, rue de la montagne


RCSL: B55589

Authorization: 80489/C

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, 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.

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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.

4. Cookies

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

possible way.

The use of cookies serves to make the use of the website of the company more comfortable.

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.

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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:

5.1 Information

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

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(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.

5.3 Deletion

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

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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.




Bob  Efiscalie

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