Privacy Policy
Your privacy matters to us. This Privacy Policy explains how TREMO GmbH ("TREMO," "we," "us," or "our"), with registered office at Neue Mainzer Straße 75, 60311 Frankfurt am Main, Germany, collects, uses, protects, and discloses your personal information when you visit our website, use our platform, or interact with our services. We are committed to handling your personal data responsibly and in full compliance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and other applicable privacy laws.
1. Information We Collect
We collect different types of information to provide and improve our services. The categories of personal data we process include:
Personal Identification Information
- Account Data: Name, email address, company name, job title, phone number, and password when you register for a TREMO account.
- Communication Data: Information you provide when contacting support, participating in surveys, or requesting information.
- Payment Information: Billing address, payment method details (processed securely by our payment partners — we do not store full credit card numbers).
Connection & Integration Data
- Facebook Ads Data: When you connect your Facebook ad accounts, we access ad account details, campaign performance metrics, spend data, and audience insights solely to provide the service.
- CRM Data: When you connect your CRM system, we access lead information, deal stages, and customer data to enable end-to-end analytics.
Technical & Usage Data
- Device Information: IP address, browser type, operating system, device identifiers, and time zone settings.
- Usage Data: Pages visited, features used, time spent on the platform, and interaction patterns to improve our service.
- Cookies & Tracking Technologies: We use cookies and similar technologies to enhance functionality, analyze usage, and personalize content (see Section 3).
2. Legal Basis for Processing (GDPR)
Under the GDPR, we process your personal data based on the following legal grounds:
- Contract Performance (Art. 6(1)(b)): To provide our services, manage your account, and fulfill our contractual obligations.
- Legitimate Interests (Art. 6(1)(f)): To improve our platform, ensure security, prevent fraud, and communicate important updates.
- Consent (Art. 6(1)(a)): For marketing communications, optional cookies, and certain data processing activities where you have given explicit consent.
- Legal Obligation (Art. 6(1)(c)): To comply with tax, accounting, and regulatory requirements.
3. How We Use Your Information
We use your personal data for the following purposes:
- Providing Services: To create and manage your account, sync Facebook Ads and CRM data, generate analytics, and deliver the features you request.
- Customer Support: To respond to your inquiries, troubleshoot issues, and provide technical assistance.
- Service Improvement: To analyze usage patterns, optimize performance, and develop new features.
- Communication: To send service updates, security alerts, billing information, and (with your consent) marketing communications.
- Security & Fraud Prevention: To detect and prevent unauthorized access, abuse, or fraudulent activity.
- Legal Compliance: To comply with applicable laws, regulations, and court orders.
4. Cookies & Tracking Technologies
Our website uses cookies, web beacons, and similar tracking technologies to enhance your experience and collect analytical data. Cookies are small text files stored on your device that help us remember preferences, understand how you interact with our site, and improve functionality.
Types of cookies we use:
- Essential Cookies: Required for basic website functionality (e.g., login, security).
- Analytics Cookies: Help us understand how visitors use our site (e.g., Google Analytics).
- Preference Cookies: Remember your settings and preferences.
- Marketing Cookies: Used to deliver relevant advertisements (only with your consent).
You can manage or disable cookies through your browser settings. However, disabling certain cookies may affect your ability to use some features of our website.
5. How We Protect Your Information
We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These measures include:
- Encryption of data in transit (TLS/SSL) and at rest (AES-256).
- Regular security assessments and penetration testing.
- Access controls restricted to authorized personnel only.
- Secure data centers located in the EU (Frankfurt region).
- Employee training on data protection and privacy best practices.
While we strive to protect your information, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but continuously work to enhance our safeguards.
6. Sharing Your Information
We do not sell, rent, or trade your personal information to third parties. We may share your data in the following limited circumstances:
Service Providers
We engage trusted third-party service providers to assist with hosting, payment processing, analytics, customer support, and infrastructure. These providers are contractually obligated to protect your data and use it only for the purposes specified by TREMO.
Integration Partners
When you connect Facebook Ads or your CRM, data is shared with those platforms as necessary to provide the service. Their use of your data is governed by their own privacy policies.
Legal Compliance
We may disclose your information to comply with applicable laws, respond to lawful requests from public authorities (including German and EU regulatory bodies), or protect our rights, property, or safety.
Business Transfers
In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of the transaction. We will notify you of any such change and ensure continued protection of your data.
7. International Data Transfers
As a company based in Frankfurt, Germany, your data is primarily stored and processed within the European Economic Area (EEA). If we transfer data to countries outside the EEA, we ensure appropriate safeguards are in place, such as EU Standard Contractual Clauses (SCCs) or adequacy decisions by the European Commission.
8. Data Retention
We retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law (e.g., tax or accounting records).
- Account Data: Retained for the duration of your active account and for a reasonable period thereafter to comply with legal obligations or resolve disputes.
- Usage & Analytics Data: Retained for up to 26 months unless aggregated or anonymized.
- Marketing Data: Retained until you withdraw consent.
Upon account termination, we will delete or anonymize your personal data unless legal obligations require retention.
9. Your Rights and Choices (GDPR)
Under the GDPR, you have the following rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Correct inaccurate or incomplete information.
- Right to Erasure ("Right to be Forgotten"): Request deletion of your data, subject to legal exceptions.
- Right to Restriction of Processing: Limit how we use your data in certain circumstances.
- Right to Data Portability: Receive your data in a structured, machine-readable format.
- Right to Object: Object to processing based on legitimate interests or direct marketing.
- Right to Withdraw Consent: Withdraw previously given consent at any time.
To exercise any of these rights, contact us at [email protected]. We will respond within one month as required by law. You also have the right to lodge a complaint with the supervisory authority — in Hesse, Germany, the Hessian Commissioner for Data Protection and Freedom of Information.
TREMO GmbH — Data Protection Officer
Neue Mainzer Straße 75, 60311 Frankfurt am Main, Germany
Email: [email protected]
10. Marketing Communications & Opt-Out
With your consent, we may send you promotional emails about new features, special offers, or relevant content. You can opt out at any time by clicking the "unsubscribe" link in any marketing email or by contacting [email protected]. Please note that service-related communications (e.g., account verification, security updates) are not subject to opt-out.
11. Third-Party Links
Our website and platform may contain links to third-party websites, including Facebook, CRM providers, and analytics tools. We are not responsible for the privacy practices or content of these external sites. We encourage you to review their privacy policies before providing any personal information.
12. Children's Privacy
Our services are not intended for individuals under the age of 16. We do not knowingly collect personal information from children. If we learn that we have inadvertently collected personal data from a child, we will delete it promptly. If you believe a child has provided us with personal information, please contact us.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any modifications will be posted on this page with an updated "Last updated" date. Material changes will be communicated via email or prominent notice on our website. We encourage you to review this policy periodically.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact us:
- Email (General): [email protected]
- Email (Privacy / DPO): [email protected]
- Mail: TREMO GmbH, Neue Mainzer Straße 75, 60311 Frankfurt am Main, Germany