Home/Privacy Policy

Privacy Policy

Data Protection Information in accordance with GDPR (EU/Germany) and Swiss Federal Act on Data Protection (FADP)

Last updated: January 2025

Introduction

TULA Capital ("we", "us", or "our") takes the protection of your personal data seriously. This privacy policy explains how we collect, use, process, and protect your personal information when you visit our website or use our services.

This policy applies to all users of our website and services, regardless of their location. We comply with the General Data Protection Regulation (GDPR) for users in the European Union and Germany, and the Swiss Federal Act on Data Protection (FADP / Datenschutzgesetz) for users in Switzerland.

Data Controller

The data controllers responsible for processing your personal data are the independent operators of TULA Capital network:

Germany / EU Operations

Robert Nachama

Rheinsberger Straße 42

10435 Berlin, Germany

Email: rn@tulacap.com

Switzerland Operations

Dominik Loroff

[Address]

Zurich, Switzerland

Email: dl@tulacap.com

For general data protection inquiries: team@tulacap.com

Personal Data We Collect

1. Website Usage Data (Automatically Collected)

When you visit our website, certain information is automatically collected by our web server and analytics services:

  • IP address (anonymized)
  • Browser type and version
  • Operating system
  • Referring website (if applicable)
  • Pages visited and time spent on pages
  • Date and time of access
  • Device information (desktop, mobile, tablet)
  • Approximate geographic location (country/region level)

Legal Basis: Legitimate interest (GDPR Art. 6(1)(f)) for website operation, security, and improvement. Swiss FADP Art. 13.

2. Contact Form Data (Voluntarily Provided)

When you submit a contact form or email us, we collect:

  • Name
  • Email address
  • Company name (if provided)
  • Message content
  • Any other information you choose to provide

Legal Basis: Contract initiation or your consent (GDPR Art. 6(1)(b) or (a)). Swiss FADP Art. 13.

3. Cookies and Similar Technologies

We use cookies and similar technologies for analytics and website functionality. See the "Cookies" section below for details.

How We Use Your Data

We process your personal data for the following purposes:

  • Website Operation: To provide, maintain, and secure our website
  • Communication: To respond to inquiries and provide information about our services
  • Analytics: To understand how visitors use our website and improve user experience
  • Security: To detect, prevent, and address technical issues and security threats
  • Legal Compliance: To comply with applicable laws and regulations

Third-Party Services & Data Processors

Hosting & Infrastructure

Domain Hosting: IONOS

Provider: IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany

Purpose: Domain management and DNS services

Data transferred: Technical DNS data

Location: Germany (EU)

Privacy Policy: IONOS Privacy Policy

Website Deployment: Vercel

Provider: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA

Purpose: Website hosting and content delivery

Data transferred: Website usage data, IP addresses (anonymized)

Location: USA and global CDN (Standard Contractual Clauses for EU/Swiss data transfers)

Privacy Policy: Vercel Privacy Policy

Analytics & Monitoring

Google Analytics 4

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Purpose: Website usage analytics and performance monitoring

Data transferred: Anonymized IP addresses, user behavior, device data

IP Anonymization: Enabled (last octet removed)

Data Retention: 14 months

Location: EU and USA (Standard Contractual Clauses)

Privacy Policy: Google Privacy Policy

You can opt-out: Google Analytics Opt-out

Google Search Console

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Purpose: Search performance monitoring and website optimization

Data transferred: Search queries, click data, website performance metrics

Location: EU and USA (Standard Contractual Clauses)

Privacy Policy: Google Privacy Policy

Cookies and Similar Technologies

Cookies are small text files stored on your device when you visit our website. We use cookies and similar technologies for analytics and website functionality.

Essential Cookies

Necessary for basic website functionality. These cannot be disabled.

Duration: Session or up to 1 year

Analytics Cookies (Google Analytics)

Used to understand how visitors interact with our website.

Duration: Up to 14 months

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality. Most browsers allow you to:

  • View and delete cookies
  • Block third-party cookies
  • Block all cookies
  • Clear cookies when closing the browser

Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

  • Website logs: Up to 90 days
  • Analytics data: 14 months (anonymized)
  • Contact form submissions: Duration of business relationship or until you request deletion
  • Legal obligations: As required by law (typically 6-10 years for business records)

International Data Transfers

Some of our service providers (notably Vercel and Google) are based in the United States or process data globally. We ensure that any transfers of personal data outside the EU/EEA or Switzerland comply with applicable data protection laws through:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions where applicable
  • Additional technical and organizational measures

For Switzerland, we comply with the Swiss Federal Act on Data Protection regarding international data transfers.

Your Data Protection Rights

Under GDPR (for EU/German users) and Swiss FADP (for Swiss users), you have the following rights:

Right of Access

Request a copy of personal data we hold about you

Right to Rectification

Request correction of inaccurate or incomplete data

Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data (subject to legal obligations)

Right to Restriction of Processing

Request limitation of how we use your data

Right to Data Portability

Receive your data in a structured, commonly used format

Right to Object

Object to processing based on legitimate interests

Right to Withdraw Consent

Withdraw consent at any time (where processing is based on consent)

To exercise these rights, contact us at team@tulacap.com. We will respond within 30 days.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe we have violated your data protection rights:

Germany / EU

Berlin Commissioner for Data Protection and Freedom of Information

Friedrichstr. 219, 10969 Berlin

www.datenschutz-berlin.de

Switzerland

Federal Data Protection and Information Commissioner (FDPIC)

Feldeggweg 1, 3003 Bern

www.edoeb.admin.ch

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include:

  • SSL/TLS encryption for data transmission
  • Secure hosting infrastructure with regular security updates
  • Access controls and authentication
  • Regular security assessments
  • Staff training on data protection

However, no internet transmission is completely secure. While we strive to protect your data, we cannot guarantee absolute security.

Children's Privacy

Our website and services are not directed to individuals under 16 years of age. We do not knowingly collect personal data from children. If you become aware that a child has provided us with personal data, please contact us, and we will delete such information.

Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on this page with a new "Last updated" date.

Contact Us

If you have any questions about this privacy policy or our data processing practices, please contact us:

Email: team@tulacap.com

For detailed contact information, see our Legal Notice.