What is considered personal data?

As per article 4 of the GDPR, personal data is 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, 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.

What personal data do we collect from you? (as part of our contractual obligation)

TCP may collect the following information about you:

Personal data we could obtain from third party sources

Any publicly available personal data that has been shared via a public platform such as Twitter, LinkedIn, etc. (i.e. employment details, contact details, etc.)

Your contact details

How do we collect the above information?

If you are a source of collection, we usually gather the data via:

If we have obtained your personal data from third parties, we usually gather the data via one or more of the following:

How we use your data / purposed of processing?

Sharing data with third parties


Following your request or with your written or tacit consent, we may share your personal data with some or all of the following:


As we do business internationally, we could share your information with any relevant country for business based on two considerations:

  1. In order to meet our statutory and legal obligations.
  2. In order to fulfil contractual obligations.

Under the GDPR, an international transfer of data may be made where:

Lawful basis of processing

If you are a person entering into a contract or terms of business with us by either;

We will be holding your personal data on the basis of ‘contract’. Under this basis, processing of your data is necessary either for the performance of the contract/terms of business to which you are party or to take steps at your request prior to entering into a contract.

Within the bounds of strict necessity and proportionality, in some cases we will process your personal data under the lawful basis of ‘legitimate interest’ where the processing is necessary for any or all of the following 1) keeping a relevant and appropriate relationship, 2) commercial interests, 3) exercise or defense of legal claims, 4) fraud prevention or 5) prevent cyberattacks, and 6)) to protect our rights or 3rd party rights.

If the purpose under which we process your data change, we may still be able to continue processing under the original lawful basis if our new purpose is compatible with the initial purpose (unless your original lawful basis was consent).

How long do we keep your data?

We do not retain any more of your personal information than we believe is necessary for any of the purposes outlined above and we do not retain your personal information for any longer than is reasonably necessary to do so for the purpose set out in this notice. We will retain your information for:

How do we protect your data?

TCP is committed to put in place security measures to ensure your data security:


When you visit TCP’S webpage, TCP may file information on your computer in the form of a cookie or similar technologies. Cookies are small text files which are sent by a web server to your browser or device and stored on the hard disk of your device.

Apart from the internet protocol address no personal data concerning the user is stored. We only use session cookies or other cookies that are required to provide a service requested by you. E.g. this information serves to recognize you automatically when you visit sub-websites or our website and to make navigation easier for you. For example, cookies allow us to adapt a website to your interests or – to the extent required – to save your language choices so that you do not need to enter it again each time.

You can view our website without cookies. If you do not want us to recognize your computer you can prevent cookies from being stored on your device by selecting “do not accept cookies” in your browser settings. Please see your browser manufacturer’s instructions for more details on how to do this. However, not accepting cookies may limit certain functions of our website.

Google analytics

Our website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics also uses so-called “cookies” (see already above), text files which are stored on your computer and enable an analysis of the use of the website. The information generated by the cookie on your use of this website is transmitted to a Google server in the USA and stored there. The information does not contain any personal data and will not be used to identify you. In particular, your IP address will not be saved completely but rather anonymized by deleting the last digits of the IP address. Google uses this information to analyze your use of the website in order to compile reports on website activities for us and provide further services connected with website and Internet use. Google will pass this information on to third parties if this is required by law or if third parties process this information on Google’s behalf. Under no circumstances will Google create a connection between your IP address and other data stored by Google. You can revoke your given consent into the use of Google Analytics with future effect and prohibit the future collection and storage of data at any time by either writing to us at the address above, deleting all cookies and deactivating the future saving of cookies by using the respective settings on the browser you are using or by using Google Analytics’s deactivation add-on if this is available for your browser.

Your rights

You have the following rights:

If you wish to exercise any of the above rights, please contact us using the contact form or the contact details above.

Our website is not intended for children nor is any communication and we do not knowingly collect data relating to children.

If you are dissatisfied with our advice, you have the right to lodge a complaint with the:

National Commission for Data Protection Grand-Duchy of Luxembourg: 1 Avenue due Rock’n’Roll, L-4361 Esch-sur-Alzette

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