Privacy Policy

We are very pleased about your interest in our company. Data protection is of particularly high importance to Tulimoa. Using the Tulimoa websites is generally possible without providing any personal data. However, if a data subject wants to make use of specific services of our company through our website, processing of personal data may become necessary. Where processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and the country-specific data-protection rules applicable to Tulimoa. By means of this Privacy Policy our company informs the public about the type, scope and purpose of personal data we collect, use and process. Further, data subjects are informed of the rights they are entitled to.

Tulimoa, as the controller, has implemented numerous technical and organisational measures to ensure the most complete protection possible of personal data processed through this website. Nevertheless, internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The Tulimoa Privacy Policy is based on the terms used by the European legislator when adopting the GDPR. Our Privacy Policy should be easy to read and understandable both for the public and for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms, among others, in this Privacy Policy:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person («data subject»). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

c) Processing

Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing means marking stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member-State law, the controller or the specific criteria for its nomination may be provided for by Union or Member-State law.

h) Processor

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient means a natural or legal person, public authority, agency or other body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member-State law are not regarded as recipients.

j) Third party

Third party means a natural or legal person, public authority, agency or other body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

2. Name and address of the controller

Controller for the purposes of the GDPR, other data-protection laws applicable in Member States of the European Union and other provisions of a data-protection nature is:

3. Collection of general data and information; hosting

The Tulimoa website collects a series of general data and information whenever a data subject or an automated system accesses the website. This general data and information is stored in the server log files. The following may be collected: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information used to prevent security threats in the event of attacks on our information-technology systems.

When using this general data and information, Tulimoa draws no conclusions about the data subject. Rather, this information is required to (1) correctly deliver the contents of our website, (2) optimise the content of our website and the advertising for it, (3) ensure the lasting functionality of our information-technology systems and the technology of our website, and (4) provide law-enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Tulimoa on the one hand statistically, and further with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from all personal data provided by a data subject.

Our website is hosted on the infrastructure of Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. For users from the European Economic Area, Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich, Germany, is responsible. Cloudflare processes the server log files described above on our behalf and additionally provides our website over a global Content Delivery Network (CDN). In doing so, IP addresses and connection data are also used to ward off attacks (e.g. DDoS attacks) and to speed up delivery of our website. In the course of this processing, personal data may be transferred to the USA. The legal basis for the use of Cloudflare is Art. 6 (1) (f) GDPR; our legitimate interest lies in the secure, performant and highly-available provision of our website. A data-processing agreement under Art. 28 GDPR is in place with Cloudflare. Data transfers to the USA are based on the EU-US Data Privacy Framework and, additionally, on EU Standard Contractual Clauses. Further information can be found in Cloudflare’s privacy policy at https://www.cloudflare.com/privacypolicy/.

4. Account and SaaS listings

When you create a Tulimoa account, we store your email address (used for magic-link login), your name, your display name and your language preference. These data are stored for the duration of your account. Legal basis: Art. 6 (1) (b) GDPR (performance of contract). You can delete your account at any time yourself.

When you submit a SaaS listing, we store the data you enter (product name, URL, description, country, tags, optional logo and gallery images, optional video URL, chosen tier). Published listings are visible to anyone visiting the directory. You can edit or delete your listings from your profile at any time.

Authentication (magic-link emails) and storage run on Supabase (Supabase, Inc., USA). The Supabase project with your data is hosted in the EU (eu-central-1, Frankfurt). A data-processing agreement under Art. 28 GDPR is in place with Supabase.

a) Sign in with Google

As an alternative to magic-link sign-in, we offer sign-in with Google. If you choose this option, you will be redirected to a Google sign-in page. After successful authentication, Google transmits the following data to Tulimoa: email address, name, profile picture URL and a unique Google account ID. We use these data exclusively to create your Tulimoa account and to enable login. We do not request any further permissions.

Provider of this authentication is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (for users within the EEA), or Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (for users outside the EEA). As part of sign-in, your data may be transferred to the USA. This transfer is based on the EU-US Data Privacy Framework (Google is a certified participant) and additionally on EU Standard Contractual Clauses. Legal basis is Art. 6 (1) (b) GDPR (performance of contract: provision of the Tulimoa account) and your consent under Art. 6 (1) (a) GDPR when you click the «Sign in with Google» button and consent in the Google dialog.

You can unlink the Google connection at any time in your Tulimoa profile under «Account → Connections», provided that you have additionally configured a magic-link sign-in. Further information on data processing by Google can be found in Google’s Privacy Policy.

Retention:The data transmitted via «Sign in with Google» (email address, name, profile picture URL, Google account ID) is stored for the duration of your Tulimoa account. When you delete your account (via your profile or by emailing hello@tulimoa.com), all linked Google sign-in data is removed from our systems within 30 days. Statutory retention obligations (e.g. invoicing data once paid tiers launch) remain unaffected.

Access to your data: Access to personal data stored at Tulimoa is restricted to the operator (Florian Baraz) for the purposes of operating the directory, providing support and reviewing listings. Tulimoa is currently operated as a single person; no further employees or third parties have access. Our processors (see below) process data exclusively on our behalf on the basis of executed data-processing agreements under Art. 28 GDPR, and only for the specific processing purpose concerned.

b) Sending transactional emails (Resend)

Magic-link codes, sign-in confirmations and other transactional emails (e.g. notifications of the activation of your listing) are sent via Resend (Resend, Inc., 2261 Market Street #5039, San Francisco, CA 94114, USA). Sending takes place from our EU region (eu-west-1, Ireland). Transmitted are your email address and the content of the respective email. Legal basis is Art. 6 (1) (b) GDPR. A data-processing agreement under Art. 28 GDPR is in place with Resend; data transfers to the USA are based on the EU-US Data Privacy Framework and EU Standard Contractual Clauses. More at resend.com/legal/privacy-policy.

5. Payments via Stripe

Paid subscriptions (Basic, Pro) are processed via Stripe, Inc. (USA) and Stripe Payments Europe, Ltd. (Ireland). We do not store credit-card data on our servers; Stripe processes all payment information directly. We only store the Stripe customer ID, subscription ID, status and current billing-period end in order to manage your subscription status. Legal basis: Art. 6 (1) (b) GDPR. A data-processing agreement under Art. 28 GDPR is in place with Stripe. Data transfers to the USA are based on the EU-US Data Privacy Framework and, additionally, on EU Standard Contractual Clauses. More at stripe.com/en/privacy.

Phase 1 note: In the current phase, only the free Free tier is active. Data processing via Stripe takes place only once the paid tiers Basic and Pro have been activated.

6. Newsletter and waitlist sign-ups via MailerLite

If you sign up for one of our waitlists or for our newsletter (e.g. via the corresponding form on the home page or in your profile under «Newsletter»), we process your email address, optionally your name, and the sign-up group you selected. Sending and management are carried out via MailerLite(UAB «MailerLite», J. Basanavičiaus 15, LT-03108 Vilnius, Lithuania). MailerLite is based in the EU; a transfer to a third country generally does not take place when managing the newsletter.

Legal basis for sending the newsletter is your consent under Art. 6 (1) (a) GDPR. You can unsubscribe from the newsletter at any time via the unsubscribe link in any of our newsletter emails or by a short message to hello@tulimoa.com; the lawfulness of the processing carried out until the withdrawal remains unaffected by the withdrawal. A data-processing agreement under Art. 28 GDPR is in place with MailerLite. More at mailerlite.com/legal/privacy-policy.

7. Cookies and similar technologies

Tulimoa uses only strictly necessary cookies that are required to operate the website (in particular session cookies for sign-in and a cookie for the language setting). No tracking cookies, advertising cookies or cookies for cross-platform profiling are set. Legal basis for the use of strictly necessary cookies is § 25 (2) (2) TDDDG and our legitimate interest in a functional web offering under Art. 6 (1) (f) GDPR.

8. Reach measurement and tracking

We do not currently use any web-analytics service, tracking pixels, advertising trackers or cross-site profiling tools on the Tulimoa website. The only information collected when you visit our pages are the server log entries described in section 3, which are processed by Cloudflare as our hosting provider for security and operations purposes only.

Should we introduce a privacy-friendly analytics tool in the future, this Privacy Policy will be updated before any such tool is activated.

9. Routine erasure and blocking of personal data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage, or where this has been provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage ceases to apply or a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with statutory provisions.

10. Rights of the data subject

a) Right of confirmation

Every data subject has the right, granted by the European legislator, to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to make use of this right of confirmation, they may at any time contact an employee of the controller.

b) Right of access

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain at any time from the controller free information about the personal data stored about them and a copy of that information. Furthermore, the European legislator has granted the data subject access to the following information:

• the purposes of the processing;
• the categories of personal data being processed;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of the personal data, or restriction of processing concerning the data subject, or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject: any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Furthermore, the data subject has the right of access as to whether personal data are transferred to a third country or to an international organisation. If this is the case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to make use of this right of access, they may at any time contact an employee of the controller.

c) Right to rectification

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain without undue delay the rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement, taking into account the purposes of the processing.

If a data subject wishes to make use of this right of rectification, they may at any time contact an employee of the controller.

d) Right to erasure (right to be forgotten)

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller the erasure of personal data concerning them without undue delay where one of the following grounds applies, as long as the processing is not necessary:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• The data subject withdraws consent on which the processing was based according to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased to comply with a legal obligation under Union or Member-State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information-society services referred to in Art. 8 (1) GDPR.

If one of the above grounds applies and a data subject wishes to request the erasure of personal data stored at Tulimoa, they may at any time contact an employee of the controller. The Tulimoa employee will arrange for the request for erasure to be complied with without undue delay.

e) Right to restriction of processing

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
• The data subject has objected to processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored at Tulimoa, they may at any time contact an employee of the controller.

f) Right to data portability

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided, as long as the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising their right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where this does not adversely affect the rights and freedoms of others.

Signed-in users can download their personal data as a JSON file at any time themselves. The button can be found under «My profile → Account → Export my data». The export contains profile data, submitted SaaS listings, favourites, subscription status (tier / period / status, without Stripe-internal IDs), audit-log entries for own actions, and submitted support messages.

g) Right to object

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Art. 6 (1) (e) or (f) GDPR. This also applies to profiling based on these provisions.

Tulimoa will no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or where the processing serves the establishment, exercise or defence of legal claims.

If Tulimoa processes personal data for direct-marketing purposes, the data subject has the right to object at any time to the processing of personal data for the purposes of such marketing. This also applies to profiling, to the extent that it is related to such direct marketing. If the data subject objects to Tulimoa processing for direct-marketing purposes, Tulimoa will no longer process the personal data for those purposes.

h) Automated individual decision-making, including profiling

Every data subject affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into or performing a contract between the data subject and the controller, (2) is authorised by Union or Member-State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

i) Right to withdraw a data-protection consent

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, they may at any time contact an employee of the controller.

11. Right to lodge a complaint

If you are of the opinion that the processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a data-protection supervisory authority. The supervisory authority competent for us is the State Commissioner for Data Protection of Lower Saxony.

12. Social-media presences and external links

We maintain public profiles on various social-media platforms and link to these profiles on our website. The icons embedded are pure hyperlinks; no social-media plug-ins, tracking pixels, iFrames or platform buttons that would transfer data to the platforms on mere page load are embedded. A data transfer to the respective platform operator only takes place when you actively click a link and thereby visit the external platform.

If you click such a link, you leave our website and are redirected to the external platform. Processing of your data is then subject exclusively to the privacy provisions of the respective provider. If you are logged in to the respective platform at the time of the click, the provider may attribute the page visit to your account. We have no influence on the scope of data collected by the platforms. Insofar as personal data is processed when visiting our profiles (e.g. statistical reach analyses by the platform operator), the respective platform operators are jointly responsible under data-protection law.

Legal basis for linking our social-media profiles is Art. 6 (1) (f) GDPR. Our legitimate interest lies in external presentation, communication with interested parties and customers, and customer acquisition.

We have a presence on the following platforms:

• Instagram: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Privacy policy: https://privacycenter.instagram.com/policy
• X (formerly Twitter): X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Privacy policy: https://x.com/en/privacy

For platforms based in the USA or for transfers to third countries, it cannot be ruled out that data is transferred to countries outside the European Economic Area in which no level of protection comparable to the European one exists. Please refer to the linked privacy policies of the respective providers for details.

13. Legal basis for processing

Art. 6 (1) (a) GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the supply of goods or the provision of any other service or consideration, the processing is based on Art. 6 (1) (b) GDPR. The same applies to processing operations necessary for carrying out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation that requires processing of personal data, such as fulfilling tax obligations, the processing is based on Art. 6 (1) (c) GDPR. Finally, processing operations could be based on Art. 6 (1) (f) GDPR. On this legal basis are based processing operations not covered by any of the aforementioned legal bases, if the processing is necessary to safeguard a legitimate interest of our company or of a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overriding.

14. Legitimate interests pursued in the processing

Where the processing of personal data is based on Art. 6 (1) (f) GDPR, our legitimate interest is the conduct of our business in favour of the well-being of all our employees, shareholders and our users and business partners.

15. Duration for which the personal data are stored

The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data are routinely erased, provided that they are no longer necessary for the performance or initiation of a contract.

16. Statutory or contractual requirements to provide the personal data

We clarify that the provision of personal data is partly required by law (e.g. tax provisions) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary, for the conclusion of a contract, that a data subject provides us with personal data, which must subsequently be processed by us. For example, the data subject is obligated to provide us with personal data when our company concludes a contract with them. A failure to provide the personal data would have the consequence that the contract with the data subject could not be concluded.

17. Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

18. Security of data transmission

Transmission takes place encrypted via TLS (HTTPS). Only we and our commissioned processors have access to account and listing data, currently:

• Supabase, Inc. (USA, data region EU eu-central-1 Frankfurt): database and authentication
• Cloudflare, Inc. / Cloudflare Germany GmbH: hosting and CDN
• Google Ireland Limited/ Google LLC: only when actively using «Sign in with Google»
• Resend, Inc. (USA, EU region eu-west-1): sending of transactional emails
• UAB «MailerLite» (Lithuania): only with active newsletter or waitlist sign-up
• Stripe, Inc. / Stripe Payments Europe, Ltd.: only for paid subscriptions (still inactive in Phase 1)

Data-processing agreements under Art. 28 GDPR are in place with all processors. All processors are contractually obligated to confidentiality.

19. Changes to this Privacy Policy

We adapt the Privacy Policy if data flows change (e.g. new services, new processors, changes in the legal environment). The current version is always available at this URL. Last updated: see above.

Language versions

This Privacy Policy exists in English and German. Both versions carry the same content. In the event of discrepancies between the two versions, the version in the language in which the user accesses the Service prevails for the respective user; for users contracting under German law, the German version prevails.