Data Protection
We attach great importance to data protection. The collection and processing of your personal data is carried out in compliance with the applicable data protection regulations, in particular the EU General Data Protection Regulation (DSGVO). We collect and process your personal data in order to offer you our website and our services. Pursuant to Art. 13 DSGVO, we describe in this declaration which data is used by us in which way and for which purpose and to what extent and which choices and rights you have in connection with the use of your personal data.
1. Data controller & data protection officer
Turnbull Holding GmbH, Schaarsteinwegsbrücke 2, 20459 Hamburg, Germany, represented by the Managing Director Jens Borchers, is responsible for data protection compliance on our site.
We will be happy to answer any questions you may have regarding data protection. For this purpose, you have the following contact options:
E-mail address:
(1) The company has appointed an external data protection officer. You can reach him under the following contact details:
RA Hans Georg Bauer
HGB Rechtsanwaltsgesellschaft mbH
Am Kaiserkai 56
20457 Hamburg
Tel. (040) 5530 2235
(2) The Data Protection Officer shall monitor compliance with the DS-GVO as well as other legal requirements, including the requirements of this and other Company policies on data protection. The Data Protection Officer advises and informs the company management with regard to existing data protection obligations and is responsible for communicating with supervisory authorities. Selected processes are checked by him for data protection compliance on a random, risk-oriented basis and at appropriate intervals.
(3) The data protection officer shall perform his duties free from instructions and using his specialist knowledge. He shall report directly to the management.
(4) The company or its employees shall support the data protection officer in the performance of his duties.
2. Data collection on our website
Insofar as you access our website, information is automatically transmitted by your browser to the server of our website.
This includes the following data:
  • Your IP address,
  • Date and time of the call
  • Name and URL of the file you accessed
  • Website from which the call is made (referrer URL)
  • Information about the browser you are using as well as operating system
  • Name of your access provider.
This data is used for the purpose of ensuring a smooth connection setup and comfortable use of our website as well as for evaluating system security and stability.
The legal basis for data processing results from Art. 6 para. 1 p. 1 lit. f DSGVO. as we have a legitimate interest to collect data from the aforementioned purposes. In addition, a legal basis arises likewise from Art. 6 para. 1 lit. b DSGVO for the processing of data for the performance of a contract or pre-contractual measures.
The data will not be used to draw conclusions about your person.
Processing of customer and contract data
When initiating business, concluding a contract and fulfilling a contract, we use your personal data required for this purpose in accordance with Art. 6 (1) lit. b DSGVO.
Data is only transferred to third parties if and insofar as this is necessary for contractual fulfillment, e.g. if a company has been commissioned for production or transport services or a credit institution for payment processing.
The deletion of this personal data takes place after the expiry of the statutory warranty periods or after the end of statutory retention periods.
Email communication
You can write to us directly by e-mail. If you write to us by e-mail, we will at least receive your e-mail address. All other data provided is optional. The data is collected for the purpose of initiating or executing contractual relationships pursuant to Art. 6 (1) lit. b DSGVO Insofar as your inquiry is not directed to initiating or executing a contract, we nevertheless have a legitimate interest in processing and responding to your inquiry. To this extent, the use of personal data for this purpose is based on Art. 6 para. 1 lit. f DSGVO.
We use the data you provide exclusively to process your inquiry. Insofar as your inquiry is directed towards the initiation or implementation of business, we delete your data according to our internally defined deletion periods.
Insofar as your inquiry is related to another purpose, we delete your data after processing, insofar as no other legal basis for data storage exists.
We offer potential employees the opportunity to apply to us online. For this purpose, we use your the necessary personal data for this purpose pursuant to Art. 6 para. 1 lit. b DSGVO.
Data will only be transferred to third parties if and insofar as this is necessary for contractual fulfillment. The deletion of this personal data takes place after 6 months, insofar as no contractual relationship arises.
On our website there is the possibility to subscribe to a free newsletter for the purpose of direct advertising. When you register for the newsletter, your name and e-mail address from the input mask are transmitted to us. In addition, your IP address and the date and time of registration are used. The collection of other personal data during the registration process serves to prevent misuse of the services or the e-mail address used.
For the processing of data, your consent is obtained as part of the registration process and reference is made to this privacy policy. The legal basis for the processing of the data after registration to the newsletter by the user is, if the user has given his consent, Art. 6 para. 1 lit. a DSGVO.
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. Accordingly, the e-mail address of the user is stored as long as the subscription to the newsletter is active.
If you have entered into a contractual relationship with us on our website and in doing so have deposited your e-mail address, this may subsequently be used by us to send a newsletter for the purpose of direct advertising. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter. The legal basis for sending the newsletter as a result of the sale of goods or services is Section 7 (3) UWG.
Our website contains cookies. Cookies are small text files that are stored on your terminal device. They help us to facilitate your navigation through our offer and enable the correct display of the website. They are intended to support the user-friendliness of the website and are, of course, completely harmless to your end device. Information is temporarily collected in connection with the terminal device you use and the software you use. Conclusions about your identity are not drawn from this.
We use, for example, so-called „session cookies“. These cookies are automatically deleted after your visit. We also use cookies that are stored on your terminal device, for example, to make it easier for you to use our site on a subsequent visit and to recognize your browser on your next visit („permanent cookies“). These cookies can, of course, be manually deleted by you at any time.
We also use cookies to statistically record and evaluate the use of our website. This is done for the purpose of further optimizing our offer for you.
We also use cookies for pseudonymized range measurement. You will be further informed about this below.
The cookies that are absolutely necessary for the operation of our website, i.e. without which, our website cannot be displayed, we use for this purpose to protect our legitimate interests according to Art. 6 para. 1 p. 1 lit. f DSGVO. These are automatically deleted after a defined time in each case.
The cookies that are necessary for the processing of contracts or for the contractually agreed use of our website, we use of Art. 6 para. 1 p. 1 lit. b DSGVO. These are automatically deleted after a respectively defined time.
The use of cookies that are not necessary as described above is based on your consent pursuant to Art. 6 para. 1 lit. a DSGVO. Your consent can be revoked at any time with immediate effect. To do this, go to the settings of the browser you are using and select „Delete browser data“ here you must have selected „Cookies and other website data“ and then remove them.
Of course, you can also view our website without cookies. To do this, you must prevent cookies from being stored on your hard drive by selecting „do not accept cookies“ in your browser settings. For a more detailed description, please consult the instructions of your browser manufacturer. You can also visit the Network Advertising Initiative's disable page ( and additionally the U.S. website ( or the European website ( to disable cookies. If you do not accept cookies, this may result in functional limitations on our website.
Matomo (Open Source Software)
We use Matomo (operated by InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand, NZBN 6106769; formerly „Piwik“), hereafter named Matomo, for web analytics using cookie technology.
The protection of your data is important to us, which is why we have additionally configured Matomo in such a way that your IP address is not recorded, but instead Matomo automatically generates a new IP address, which only provides information about the country from which you logged in. We therefore process your personal usage data anonymously. It is not possible for us to draw conclusions about your person.
For more information on Matomo's terms of use and data protection regulations, see:
3. Data Sharing
As a matter of principle, your personal data will not be transferred to third parties. However, data may exceptionally be transmitted for the following reasons:
  • Insofar as you have given your express consent, Art. 6 para. 1 p. 1 lit. a DSGVO
  • Insofar as the disclosure is necessary according to Art. 6 para. 1 p. 1 lit. f DSGVO and there is no overriding interest worthy of protection in not disclosing your data
  • Insofar as we are legally obliged to disclose the data, Art. 6 (1) p. 1 lit. c DSGVO
  • Insofar as a transfer is permissible and necessary according to Art. 6 para. 1 p. 1 lit. b DSGVO for the processing of contractual relationships with you
Insofar as processing of your data, e.g. in the case of external hosting, is carried out by means of third parties commissioned by us, this is done on the basis of Art. 28 DSGVO by means of a commissioning contract.
4. Transfers to third countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or do so in the context of using third-party services or disclosing, or transferring, data to third parties, we do so only if it is done to fulfill our (pre)contractual obligations, based on your consent, based on a legal obligation, or based on our legitimate interests. Subject to legal or contractual authorizations, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. DSGVO are met. I.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU or compliance with officially recognized special contractual obligations (so-called „standard contractual clauses“).
A transfer of your data collected on this website takes place in the USA by Google and Twilio: By accepting further cookies, you consent according to Art. 49 para. 1 p. 1 lit. a DSGVO to your data being processed by Google in the USA. By subscribing to a newsletter, you consent according to Art. 49 para. 1 p. 1 lit. a DSGVO to your data being processed by Twilio in the USA.
5. Data subject rights
Right of access Art. 15 DSGVO
You have the right to request confirmation from us as to whether we are processing personal data about you. If this is the case, you can request information about this personal data and about the following information:
  • The purposes of processing
  • The categories of personal data processed
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations
  • If possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
  • The existence of a right to rectify or erase the personal data concerning you or to restrict processing or to object to such processing
  • The existence of a right of appeal to a supervisory authority
  • If the personal data are not collected from you, any available information about the origin of the data
  • The existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject
Right of rectification Art. 16 GDPR
You may without undue delay request the rectification of inaccurate or incomplete personal data stored by us.
Right to erasure (right to be forgotten) of your data, Art. 17 DSGVO
You can immediately request the correction of inaccurate or completion of your personal data stored by us.
  • The personal data are not necessary for the purposes for which they were collected or otherwise processed or are no longer necessary
  • You withdraw your consent on which the processing is based pursuant to Article 6(1)(a) DSGVO or Article 9(2)(a) DSGVO and there is subsequently no other legal basis for the processing
  • You object to the processing pursuant to Article 21(1) DSGVO and there are no overriding legitimate grounds for the processing or you object to the processing pursuant to Article 21(2) DSGVO
  • The personal data have been unlawfully processed
  • The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which you are subject
  • The personal data have been collected in relation to information society services offered in accordance with Article 8(1) of the GDPR
We are obliged to erase upon presentation of the conditions, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims.
Right to restriction of processing, Art. 17 DSGVO
You have the right to obtain from us the restriction of processing insofar as
  • The accuracy of the personal data is contested by you, but only for the period that allows us to verify the accuracy of the data
  • The processing is unlawful and you do not immediately want the erasure of your personal data, but instead request the restriction of the use of the personal data
  • We no longer need the personal data for the purposes of processing, but you need it for the assertion, exercise or defense of legal claims; or
  • You have objected to the processing pursuant to Article 21(1) DSGVO, as long as it has not yet been determined whether the legitimate grounds on our part override yours.
    To the extent that processing is restricted, we may process your personal data - apart from storing them - only with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.
    Before the restriction is lifted, you will be informed again. Right to data portability Art. 20 DSGVO
    You have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transferred to another controller.
    Right to object Art. 21 DSGVO
    You have the right, pursuant to Art. 21 DSGVO, to object to the processing of your personal data if it is processed on the basis of legitimate interest pursuant to Art. 6 (1) p. 1 lit. f DSGVO. However, this only applies if there are grounds arising from your particular situation or if the objection is directed against direct marketing.
    Right of withdrawal Art. 7 para. 3 DSGVO
    You have the right to revoke your consent granted pursuant to Art. 6 para. 1 p. 1 lit. a DSGVO at any time vis-à-vis us. This revocation applies exclusively to future use.
    Right to complain to supervisory authorities
    Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or our registered office, if you consider that the processing of personal data relating to you infringes the GDPR.
    To the extent that you wish to exercise your data subject rights, you may also submit this by E Mail to the above-mentioned e-mail address.
    6. Data Security
    This page uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as requests that you send to us as the page operator. you can recognize this by the fact that the address line of the browser changes from "http://" to "https://". In addition, a lock symbol can be seen in the browser line.
    If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
    In addition, we have taken precautions in the form of technical and organizational measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties.
    7. Updating and amending this privacy policy
    This privacy policy is currently valid and has a status of May 11, 2022.
    In order to ensure that our data protection declaration always complies with the current legal requirements, we reserve the right to make changes at any time. This also applies in the event that the data protection declaration has to be adapted due to new or revised services, for example new services. The new data protection declaration will then take effect during your next visit to our offer.
    Our data protection declaration is available to you on our site at any time for viewing and printing.
    8. Complaints and warnings
    If you feel that your rights have been violated or that you have otherwise been disadvantaged, we ask you to inform us of this yourself. You will then receive a personal, individual response. Within the scope of your duty to minimize damages, we would like to point out that we will not assume the costs of a lawyer commissioned by you out of court without prior contact. It is expressly not our intention that you instruct a lawyer to issue a cease-and-desist demand and/or a declaration to cease and desist with a penalty clause. Consequently, a presumed will cannot be relied upon.