As of: November 27, 2024

1. Controller and Data Protection Officer

The controller for data processing is:
Turmitus.Tech
c/o orientas.digital
St. Niklausstrasse 8
CH-3425 Koppigen
Switzerland
Email: office@turmitus.tech

2. Data Collected and Purposes of Processing

a) When visiting the website (log files):

We collect IP address, browser type, operating system, referring website, visited pages and date/time of access. Legal basis is Art. 6(1)(f) GDPR (legitimate interest in operational security and optimization). Log files are deleted after 7 days.

b) When registering and using an account:

We process email address, username and password (encrypted). Legal basis is Art. 6(1)(b) GDPR (contract performance). Additionally, we process your ratings and comments to operate the ColdCase Intelligence Framework (calculation of S/R values).

c) Cookies and tracking:

We use technically necessary cookies to enable login. Legal basis is Art. 6(1)(f) GDPR.

We also use analytics cookies (e.g., Google Analytics) to understand and improve platform usage. These are only used with your consent (cookie banner) (Art. 6(1)(a) GDPR).

d) Embedding of third-party content (YouTube videos):

When playing an embedded video, data is transmitted to the provider (Google/YouTube). This only happens after your consent (Art. 6(1)(a) GDPR).

3. ColdCase Intelligence Framework (Special Processing)

At the core of our platform, we process your ratings and interactions to algorithmically calculate values for "Seriousness (S)" and "Relevance (R)" for users and content. This processing is based on our legitimate interest (Art. 6(1)(f) GDPR) in operating a high-quality and abuse-resistant platform.

You have the right to object to this processing at any time for reasons arising from your particular situation.

4. Data Transfer to Third Parties

Your personal data is only transferred to third parties:

To IT service providers (hosting providers) who are strictly bound as data processors according to Art. 28 GDPR
To advertising partners, but only in pseudonymized form
If we are legally obliged to do so by law or court order

5. International Data Transfers

Our servers are located in the EU. Through the use of services like Google Analytics or YouTube, data may be transferred to the USA (third country without adequacy decision). We only use these services if you have consented and appropriate safeguards according to Art. 46 GDPR (e.g., EU Commission Standard Contractual Clauses) are in place.

6. Storage Period

We store your personal data only as long as necessary for the fulfillment of the purposes or if statutory retention obligations (e.g., commercial law) exist. Account data will be deleted when you cancel your account.

7. Your Rights

You have the following rights regarding your personal data:

Right of access (Art. 15 GDPR)
Right to rectification (Art. 16 GDPR) or erasure (Art. 17 GDPR)
Right to restriction of processing (Art. 18 GDPR)
Right to data portability (Art. 20 GDPR)
Right to object to processing (Art. 21 GDPR)

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).

8. Special Notes for Users from Specific Regions

California (USA):

If you are a consumer residing in California, the California Consumer Privacy Act (CCPA/CPRA) grants you additional rights, such as the right to disclosure of the collected categories and specific personal data and the right to deletion. You can exercise your rights by contacting us. We do not sell personal data within the meaning of the CCPA.

United Kingdom (UK):

For users in the UK, the UK GDPR applies. The rights are comparable to those under the GDPR. The competent supervisory authority is the Information Commissioner's Office (ICO).

Canada & Australia:

These countries also have comprehensive data protection laws (PIPEDA in Canada, Privacy Act in Australia). This template is designed to comply with the principles of these laws (accountability, transparency, data subject rights) as well.

9. Changes to this Privacy Policy

We reserve the right to adjust this privacy policy to reflect changed legal situations or changes to our service.