Privacy policy

Our services are built with strict privacy principles.

This privacy policy applies to the Tuurio Identity and Authentication Service (hereinafter "service" or "portal"), unless otherwise stated.

A minimum age of 16 is required for independent use.

All servers on which we store primary user data are located in Germany and encrypted.

1. Name and address of the controller

Controller in the sense of GDPR is:

Tuurio GmbH
Muehlenstr. 8a
14167 Berlin
Email: info@tuurio.com
Website: www.tuurio.com

2. Information we collect

Information you provide

Automatically collected information

3. Payment processing via Mollie (Germany and Austria) and Paddle (other countries)

For paid subscriptions, Tuurio currently uses two billing routes. For organizations with billing country Germany (DE) or Austria (AT), payment method setup and recurring charges are processed via Mollie B.V. in the Netherlands. For organizations in other countries, we continue to use Paddle.com Market Ltd (Judd House, 18-29 Mora Street, London, EC1V 8BT, UK) as Merchant of Record.

For German (DE) and Austrian (AT) self-service subscriptions, Mollie receives the payment method data required to process recurring charges on our behalf. Tuurio remains the contractual provider, receives payment confirmations, and stores your organization ID plus billing references. Prices are defined net in EUR and statutory VAT is added based on the billing country. For subscriptions in other countries, Paddle collects payment and billing data directly as Merchant of Record and sends us the payment confirmation plus your email address and organization ID to unlock features.

Legal basis: Transfer and collection are required for contract performance under Art. 6 para. 1 lit. b GDPR. For Germany (DE) and Austria (AT), Mollie acts as payment service provider for Tuurio. Privacy information: https://www.mollie.com/legal/privacy. For organizations in other countries, Paddle acts as Merchant of Record. Privacy information: https://www.paddle.com/legal/privacy.

Other third-party services

Web analytics (PostHog), cookies and consent

We use PostHog (EU hosting) for web analytics to understand website usage and improve our public pages.

By default, analytics runs in a cookieless mode without persistent analytics cookies.

Only after active consent in the cookie banner we switch to persistent browser storage for analytics (for example localStorage and cookies).

You can change or revoke this consent at any time via cookie settings.

Legal bases are Art. 6 para. 1 lit. f GDPR (legitimate interest for cookieless measurement) and, after consent, Art. 6 para. 1 lit. a GDPR.

More details about the provider: https://posthog.com/privacy.

Complete list of sub-processors

A complete list of all sub-processors is available at /public/legal/sub-processors.

4. Your rights as a data subject

You have the following rights regarding your personal data:

You can send requests at any time to info@tuurio.com.

5. Retention and deletion

We store your data only as long as necessary to provide the service or required by legal retention periods (e.g. tax and billing records for Mollie or Paddle transactions). After account termination, identity data of your tenants is irreversibly deleted after a 30-day safety period unless legal obligations prevent deletion.

Passkey-only: purpose, retention and return to password login

Prepared operating-policy addition, 8 October 2026. This describes the intended contract for the approved rollout; it does not assert that the remaining functions are already available or grant legal, release or activation approval.

During passkey-only, existing native and imported password verifiers are blocked and retained solely for a possible return to password login. They remain in their original storage; no separate password archive is created. Retention is not an additional recovery method and never authorizes a password-only bypass.

The original recorded activation starts a 30-day period of exactly 720 hours. A bounded automatic deletion process removes the retained old verifiers from active storage from the end of that period only while the same activation remains enabled. Saving or retrying an enabled policy does not extend it. If an older activation has no evidenced start, its age is unknown; deployment time is not used to invent a deletion deadline.

Switching passkey-only off before deletion makes surviving original verifiers usable again under the normal account and authentication checks. A later genuine activation starts a new period. Switching off never restores deleted password material or revoked sessions and tokens. Deletion ends the old-password return path; access through passkeys and configured recovery remains.

A user with a currently usable passkey and configured recovery can request deletion of their own old password at any time within this retained-password contract. After policy OFF, this requires proof that the unchanged password stock predates the original activation; new OFF passwords or unproven history are refused. An authorized tenant admin can deliberately remove retained verifiers early while passkey-only is active, with audit. The irreversible effect on the password return path is explained beforehand and requires explicit confirmation. This process does not silently remove the only current login factor outside the retained-password contract.

New accounts created through a passkey-only path receive no password. New tenants still start with passkey-only disabled; enabling it remains an explicit tenant decision subject to readiness checks.

Separate, restricted deletion records contain account and tenant identifiers, comparison identifiers for removed verifiers and original activation and deletion metadata, not reusable password verifiers. They prevent removed material being accepted again even after account deletion. These are personal security records, not anonymous data. The prepared technical implementation has no automatic expiry or deletion process for these records. The 720-hour period for old password verifiers is not a claim that these records are erased at the same time; their purpose and retention must be assessed separately before release.

Deleting active database rows does not immediately remove copies from existing encrypted backups; those copies follow the actual backup-retention policy. A restore must remain isolated from authentication and writers until original deletion records, activation state and revocations have been reconciled. Restoring a complete old backup that discards the deletion history cannot be made safe by the cleanup worker alone. It must not silently reactivate deleted verifiers or revoked sessions and refresh tokens.

The intended session rules end all other user sessions and refresh tokens after recovery setup, and all non-passkey sessions and tokens in the tenant on opt-in. Returning the policy to off does not revive them. Only Tuurio performs an application rollback: commit policy off, stop affected writers, end the specifically affected sessions, then restore the recorded prior application image. A backup restore and an application-image rollback are different operations.

6. Supervisory authority

You have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The competent supervisory authority for Tuurio GmbH is the Berliner Beauftragte fuer Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin.

Version 2.0, March 9, 2026