tupevo
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Privacy Policy

Last updated: February 2026

1. Controller Information

The controller responsible for data processing on this website is:

tupevo S.àr.l.-S
12, Rue du Château d'Eau
L-3364 Leudelange, Luxembourg
Email: [email protected]

2. What Data We Process

a) Server Logs

When you visit our website, our hosting provider automatically collects and stores information in server log files that your browser transmits. This includes your IP address, browser type and version, operating system, referring URL, pages visited, and the date and time of your visit. This data is collected by the hosting provider for the purpose of ensuring the security and stability of the service and is retained according to the hosting provider's own policies.

b) Analytics

We use Umami, a privacy-friendly, cookieless analytics tool. Umami collects anonymized, aggregated page view statistics and events. It does not use cookies, does not collect personal data, and does not track individual visitors across sessions. Our Umami instance is self-hosted, meaning no analytics data is shared with third parties.

c) Voluntary Contact

If you contact us by email at [email protected], we process the personal data you provide (such as your name and email address) solely to respond to your inquiry.

3. Legal Basis for Processing

We process personal data on the following legal bases under the General Data Protection Regulation (GDPR):

  • Article 6(1)(f) -- Legitimate interests: Server log data is processed to ensure the secure and stable operation of our website. Umami analytics data is processed to understand how our website is used and to improve its content. Since Umami collects only anonymized, aggregated data, the impact on your privacy is minimal.
  • Article 6(1)(b) -- Performance of a contract or pre-contractual measures: If you contact us with an inquiry about our products or services, we process your data to respond to your request.

4. Data Recipients and Transfers

Your data may be processed by the following categories of recipients:

  • Hosting provider: Our website is hosted within the European Union. The hosting provider processes server log data on our behalf.
  • Analytics: Umami is self-hosted. No analytics data is shared with any third party.

We do not sell, trade, or otherwise transfer your personal data to third parties. We do not transfer personal data outside the European Economic Area (EEA).

5. Data Retention

  • Server logs: Retained by the hosting provider in accordance with their data retention policies.
  • Analytics data: Umami data is aggregated and anonymized. It does not constitute personal data and may be retained indefinitely.
  • Email correspondence: Retained for as long as necessary to address your inquiry and for any follow-up communication, or as required by law.

6. Your Rights Under GDPR

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

  • Right of access (Article 15) -- You have the right to obtain information about the personal data we process about you.
  • Right to rectification (Article 16) -- You may request the correction of inaccurate personal data.
  • Right to erasure (Article 17) -- You may request the deletion of your personal data, subject to legal retention obligations.
  • Right to restriction of processing (Article 18) -- You may request that we restrict the processing of your data under certain conditions.
  • Right to data portability (Article 20) -- You have the right to receive your personal data in a structured, commonly used, machine-readable format.
  • Right to object (Article 21) -- You may object to the processing of your personal data based on legitimate interests at any time.

To exercise any of these rights, please contact us at [email protected].

7. Right to Lodge a Complaint

If you believe that the processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority. The competent supervisory authority for Luxembourg is:

Commission Nationale pour la Protection des Donnees (CNPD)
15, Boulevard du Jazz
L-4370 Belvaux, Luxembourg
Website: https://cnpd.public.lu

8. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable legal requirements. The updated version will be indicated by the "Last updated" date at the top of this page. We encourage you to review this page periodically.