Privacy Policy
Last updated: [DD Month YYYY]
1. Controller
The controller responsible for data processing on this website is:
[Company legal name]
[Street and number]
[Postal code, City, Country]
Email: ask@aptulo.com
Data Protection Officer (if appointed): [Name and contact details of the DPO]
2. Data we process
Server log files. When you visit our website, our hosting provider automatically collects technical information that your browser transmits, such as IP address, date and time of the request, requested page, referrer URL, browser type and operating system. This is necessary to deliver the website and to ensure its security (Art. 6(1)(f) GDPR – legitimate interest).
Contact requests. If you contact us by email or via the contact form, we process the data you provide (e.g. name, email address, message) to handle your request (Art. 6(1)(b) GDPR for pre-contractual enquiries, otherwise Art. 6(1)(f) GDPR).
Cookies and similar technologies. We use essential storage to remember your cookie choice (Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR, and § 25(2) TDDDG / Art. 5(3) ePrivacy Directive). Optional analytics and marketing cookies are only used with your consent (Art. 6(1)(a) GDPR). Details are given in our Cookie Policy.
3. Recipients and processors
Our website is hosted by Microsoft Azure (Azure Static Web Apps), Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, which acts as our processor under a data processing agreement (Art. 28 GDPR).
[List any further processors, e.g. email provider, analytics or marketing tools, once used]
4. Transfers to third countries
Where personal data is transferred outside the European Economic Area, we ensure an adequate level of protection, e.g. through an adequacy decision of the European Commission (such as the EU-U.S. Data Privacy Framework) or Standard Contractual Clauses (Art. 46(2)(c) GDPR).
5. Retention
We store personal data only for as long as necessary for the purposes described above or as required by statutory retention obligations. Your cookie choice is stored for 12 months, after which we ask you again. [Specify retention periods for server logs and contact requests]
6. Your rights
Under the GDPR you have the right to:
- access your personal data (Art. 15 GDPR);
- rectification of inaccurate data (Art. 16 GDPR);
- erasure (Art. 17 GDPR);
- restriction of processing (Art. 18 GDPR);
- data portability (Art. 20 GDPR);
- object to processing based on legitimate interests (Art. 21 GDPR);
- withdraw your consent at any time with effect for the future (Art. 7(3) GDPR).
To exercise your rights, please contact us at ask@aptulo.com. You can change or withdraw your cookie consent at any time via .
You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement (Art. 77 GDPR). [Name and address of the competent supervisory authority]
7. Automated decision-making
We do not use automated decision-making, including profiling, within the meaning of Art. 22 GDPR.
8. Changes to this policy
We may update this privacy policy to reflect changes in legal requirements or in our services. The current version is always available on this page.