Privacy Policy

Last updated: June 24, 2026

fbx.io ("fbx.io", "us", "we", "our") operates the following websites and online profiles ("Service", "Services"):

This Privacy Policy explains how we collect, use and disclose personal information when you use our Services. This Privacy Policy will also inform you about the scope and purpose of any personal data we may collect and process, and the rights you have. You do not need to provide personal information in order to browse this website. If you contact us by email or through one of the listed profiles, or otherwise choose to interact with us, we may process the information you provide in order to respond to you. When we process your personal information, we do so in accordance with the European Union's General Data Protection Regulation (GDPR), as well as all other applicable data protection regulations.

We've implemented various technical and organizational measures to protect your personal data. However, it is technically impossible to guarantee absolute data security. Therefore, you are welcome to transfer personal data via letters or other means.

This Privacy Policy applies to all visitors, users and anyone who interacts with the Service or Services ("Customers").

Definitions

This Privacy Policy adopts the terminology of the European GDPR legislator. To help you understand our Privacy Policy, we will explain the terms we use to you.

Personal Data: Any information that relates to a natural person (an individual) or an identifiable natural person ("Data Subject"). A person is directly or indirectly identifiable, if there is a reference to an identifier that can be used to identify that person. Such an identifier may be an email address, a name, an ID, location data or one or more other pieces of information that describe attributes of a Person.

Data Subject: Any identified or identifiable natural person, whose Personal Data is being collected and/or processed by the controller processing that data.

Processing: Any kind of operation, or set of operations, performed on Personal Data or on sets of Personal Data, manually or automatically. Examples: Collection, recording, structuring, organisation, adaptation, storage or alteration, consultation, retrieval, use, dissemination, disclosure by transmission or otherwise making available, combination, alignment or restriction, destruction or erasure.

Restriction of Processing: To restrict Processing of Personal Data, stored Personal Data may be marked.

Profiling: Any kind of automated processing of Personal Data by evaluating certain personal attributes relating to a natural person in order to gain insight into or predict a natural person's performance, economic situation, health, preferences, interests, behavior, location, etc.

Pseudonymisation: The Processing of Personal Data in such a way that it is no longer possible to attribute it to a specific Data Subject without utilizing additional information. To qualify for Pseudonymisation, any existing additional information must be kept separately, and there must be technical and organizational measures to guarantee that the Personal Data is not attributed to an identified or identifiable natural person.

Controller: The natural or legal person, public authority, agency or other body or entity, alone or jointly with others, responsible for the Processing. The Controller 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.

Processor: The natural or legal person, agency, public authority or other body or entity which processes personal data on behalf of the Controller.

Recipient: A natural or legal person, agency, public authority or other body or entity, and possibly a third party, to which the Personal Data is disclosed. Exception: A public authority who may receive Personal Data via a particular inquiry, and in accordance with Union or Member State law, shall not be regarded as a recipient. The Processing of data by those public authorities shall be in compliance with the applicable data protection rules according to the specific purposes of the Processing.

Third Party: A natural or legal person, agency, public authority or other body or entity, other than the Data Subject, Controller, Processor and persons who, under the direct authority of the Controller or Processor, are authorized to process Personal Data.

Consent: A Data Subject may give Consent via any specific, freely given, unambiguous, informed indication of the Data Subject's wishes by which he or she indicates via a statement or by a clear affirmative action, an agreement to the Processing of the Data Subject's Personal Data.

The Controller

For the purposes of the European Union's General Data Protection Regulation (GDPR), the United Kingdom's Data Protection Act 2018 and UK GDPR, and other data protection laws which are applicable in Member states of the European Union and other applicable regulations and provisions, if any, related to data protection, the Controller is:

Franz Bruckhoff, operating fbx.io
Rua das Maravilhas 40 C
9000-162 Funchal
Madeira, Portugal
Email: [email protected]
Web: fbx.io

For GDPR-related inquiries and to exercise your data protection rights, please contact: [email protected]

Cookies

When you visit our Services, we may collect information about your usage so we can provide the Services to you. Such information may be collected via cookies or local storage technologies ("Cookies").

Cookies are text files, stored on a computer via an Internet browser. Servers may also use cookies, and probably most Internet sites do. A lot of cookies contain a cookie ID, which is a unique identifier, typically a string of characters, that uniquely identifies the cookie. The idea of a cookie is that Internet pages and servers can differentiate individual browsers of Data Subjects. Therefore, a cookie can identify a specific Internet browser via a cookie ID.

Cookies allow us to provide better Services to you, such as optimizing the information and offers on our Services for your own benefit. While cookies can be very helpful, we strive to minimize the use of cookies as much as possible.

It is possible to prevent the setting of cookies by configuring the Internet browser which is used to access our Services. This will then permanently reject any cookies. Via the Internet browser's settings, or via other software, it is also possible to delete any cookies that have been set in the past. However, deactivating the use of cookies may result in a less pleasing user experience.

Information We May Collect

To combat cybercrimes and document potential attacks against our Services, our Services may collect a series of general data and information when a Data Subject or system requests our Services. Such general data and information are stored in server log files. Specifically, our Services may collect Internet browser types and versions, the kind of operating system, the referring website from which an accessing system is contacting our Services, the sub-websites, the date and time of access to the Service, an IP address, the Internet service provider of the system accessing our Services, and any other similar data and/or information that may be used in the event of attacks on our Services.

We do not use the above mentioned general data and information to draw conclusions about the Data Subject. Instead, this data, aside from helping to combat cybercrimes and document potential attacks against our Services, is necessary to deliver our Services correctly, optimize the content and functions of our Services, ensure the viability of our Services over the long-term, and provide law enforcement authorities with the information necessary for criminal investigation and prosecution in case of a cyber-attack against our Services. To enhance data protection and data security, and to ensure an optimal level of protection for the personal data we process, we analyze anonymously collected data and information statistically. The server log files are stored separately from all Personal Data. Also, we aim to keep the collection of data at the bare minimum necessary to deliver our Services, which means that in some instances no data may be collected at all.

Routine Erasure and Blocking of Personal Data

The Controller shall process and store the Data Subject's Personal Data only for the period absolutely necessary to achieve the purpose of storage, and only as far as granted by the European GDPR legislator or any other legislators in laws or regulations applicable to the Controller.

If the storage purpose is not or no longer applicable, and/or if a storage period expires, the Personal Data is routinely blocked or erased in accordance with any applicable legal requirements.

The Data Subject's Rights

Right of confirmation: Every Data Subject has the right to obtain confirmation from the Controller regarding whether or not personal data concerning the Data Subject is being processed. To make use of that right, a Data Subject may at any time contact any employee of the Controller, or the Controller directly.

Right of access: Every Data Subject has the right to obtain from the Controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • Purpose of the Processing.
  • Categories of personal data concerned.
  • 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 personal data, or restriction of processing of personal data 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 Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the Data Subject has a right to obtain information as to whether Personal Data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

To make use of this right of access, a Data Subject may at any time contact any employee of the Controller, or the Controller directly.

Right to rectification: Every Data Subject has the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

If a Data Subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the Controller, or the Controller directly.

Right to erasure (Right to be forgotten): Each Data Subject has the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay, and the Controller shall have the obligation to erase personal data 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 to which the processing is based according to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the Processing.
  • The Data Subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the Processing, or the Data Subject objects to the Processing pursuant to Article 21(2) of the GDPR.
  • The Personal Data have been unlawfully Processed.
  • The Personal Data must be erased for compliance with a legal obligation in 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 Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a Data Subject wishes to request the erasure of Personal Data stored by the Controller, he or she may, at any time, contact any employee of the Controller, or the Controller directly. The Controller shall promptly ensure that the erasure request is complied with immediately.

Where the Controller has made Personal Data public and is obliged pursuant to Article 17(1) to erase the Personal Data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other Controllers Processing the Personal Data that the Data Subject has requested erasure by such Controllers of any links to, or copy or replication of, those Personal Data, as far as Processing is not required. An employee will arrange the necessary measures in individual cases.

Right of restriction of processing: Each Data Subject has the right 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 and the Data Subject opposes the erasure of the Personal Data and requests instead 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 Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Controller override those of the Data Subject.

If one of the aforementioned conditions is met, and a Data Subject wishes to request the restriction of the Processing of Personal Data stored by the Controller, he or she may at any time contact any employee of the Controller, or the Controller directly. The Controller will arrange the restriction of the Processing.

Right to data portability: Each Data Subject shall have the right granted by the European legislator, to receive the Personal Data concerning him or her, which was provided to a Controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another Controller without hindrance from the Controller to which the Personal Data have been provided, as long as the Processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the 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 his or her right to data portability pursuant to Article 20(1) of the GDPR, the Data Subject shall have the right to have Personal Data transmitted directly from one Controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the Data Subject may at any time contact any employee of the Controller, or the Controller directly.

Right to object: Each Data Subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to Processing of Personal Data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

We shall 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 for the establishment, exercise or defence of legal claims.

If we process Personal Data for direct marketing purposes, the Data Subject shall have the right to object at any time to Processing of Personal Data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the Data Subject objects to us to the Processing for direct marketing purposes, we will no longer process the Personal Data for these purposes.

In addition, the Data Subject has the right, on grounds relating to his or her particular situation, to object to Processing of Personal Data concerning him or her by the us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the Processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the Data Subject may contact any employee of the Controller or the Controller directly. In addition, the Data Subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

Automated individual decision-making, including profiling: Each Data Subject shall have 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 him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the Data Subject and a data Controller, or (2) is not 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 not based on the Data Subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the Data Subject and a data Controller, or (2) it is based on the Data Subject's explicit consent, we shall implement suitable measures to safeguard the Data Subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and contest the decision.

If the Data Subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Controller, or the Controller directly.

Right to withdraw data protection consent: Each Data Subject shall have the right granted by the European legislator to withdraw his or her consent to Processing of his or her Personal Data at any time.

If the Data Subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Controller, or the Controller directly.

Data Protection for Applications and the Application Procedures

The data Controller shall collect and process the Personal Data of applicants for the purpose of the Processing of the application procedure. The Processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the Controller. If the data Controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of Processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the Controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the Controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

Email Communications

When you contact us via email, your email and any personal information you include is processed by our email service provider to enable communication. This processing is necessary to respond to your inquiries and provide customer support.

California Consumer Privacy Act (CCPA) Disclosures

This section applies to California residents and provides additional information required under the California Consumer Privacy Act (CCPA).

Categories of Personal Information We Collect: In the preceding 12 months, we may have collected the following categories of personal information from California residents:

  • Internet/Network Activity: Server logs and usage data when accessing our website (fbx.io)
  • Identifiers: Email address and any other information you voluntarily provide when contacting us

Sources of Personal Information: We collect personal information automatically when you visit our website, such as IP address information contained in server logs. We also collect personal information directly from you when you contact us by email or through one of our listed profiles.

Business Purposes for Collection: We use personal information for the following business purposes:

  • Operating, maintaining and securing our website and online profiles
  • Responding to inquiries and providing customer support
  • Preventing fraud, abuse and other unauthorized activity

Sharing of Personal Information: We do not sell personal information to third parties. We do not share personal information for advertising purposes. We use third-party service providers only as necessary to provide our services, including hosting, infrastructure and email communication providers.

Your California Privacy Rights: California residents have the right to:

  • Know: Request information about the categories and specific pieces of personal information we have collected about you
  • Delete: Request deletion of your personal information, subject to certain exceptions
  • Non-Discrimination: Not be discriminated against for exercising your privacy rights

To exercise these rights, please contact us at [email protected]. We will verify your identity before processing your request and respond within 45 days.

Since we do not sell or share personal information for advertising purposes, there is no need for a "Do Not Sell or Share My Info" mechanism.

Canadian Privacy (PIPEDA) Disclosures

This section applies to Canadian residents and provides information required under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

Consent and Collection: We collect personal information only with your knowledge and consent where required. For website usage data, consent may be implied through your continued use of our website where permitted by law. If you contact us directly, you consent to our processing of the information you provide in order to respond to you.

Purpose Limitation: We collect and use personal information only for the purposes identified at the time of collection:

  • Providing customer support
  • Ensuring security and preventing fraud
  • Operating and improving our website and online presence

International Data Transfers: We are based in Portugal, and we may use service providers in different locations:

  • Email service providers: Process email communications within the EU/EEA or under appropriate safeguards where required
  • Website and infrastructure providers: May process limited technical data needed to host, secure and deliver our Services

Your Rights Under PIPEDA: Canadian residents have the right to:

  • Access your personal information in our possession
  • Request correction of inaccurate information
  • Withdraw consent for collection, use, or disclosure
  • File a complaint with the Privacy Commissioner of Canada

To exercise these rights or if you have questions about our privacy practices, please contact us at [email protected].

Legal Basis for Processing

Art. 6(1) lit. a GDPR serves 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, when Processing operations are necessary for the supply of goods or to provide any other service, the Processing is based on Article 6(1) lit. b GDPR. The same applies to such Processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which Processing of Personal Data is required, such as for the fulfillment of tax obligations, the Processing is based on Art. 6(1) lit. c GDPR. In rare cases, the Processing of Personal Data may be necessary to protect the vital interests of the Data Subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the Processing would be based on Art. 6(1) lit. d GDPR. Finally, Processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for Processing operations which are not covered by any of the abovementioned legal grounds, if Processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data. Such Processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the Data Subject is a client of the Controller (Recital 47 Sentence 2 GDPR).

The Legitimate Interests Pursued by the Controller or by a Third Party

Where the Processing of Personal Data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

Period For Which the Personal Data Will Be Stored

The criteria used to determine the period of storage of Personal Data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

Provision of Personal Data as Statutory or Contractual Requirement; Requirement Necessary to Enter Into a Contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide Such Data

We clarify that the provision of Personal Data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the Data Subject provides us with Personal Data, which must subsequently be processed by us. The Data Subject is, for example, obliged to provide us with Personal Data when our company signs a contract with him or her. The non-provision of the Personal Data would have the consequence that the contract with the Data Subject could not be concluded. Before Personal Data is provided by the Data Subject, the Data Subject must contact any employee. The employee clarifies to the Data Subject whether the provision of the Personal Data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the Personal Data and the consequences of non-provision of the Personal Data.

Non-Existence of Automated Decision-Making

We do not use automatic decision-making or profiling.

Furthermore

  • We use your information to provide the Services to you.
  • We use analytics information to monitor total number of visitors and traffic so we can understand and enhance our Services better.
  • Parts of this Privacy Policy have been generated by the Privacy Policy Generator of the External Data Protection Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW. The generated text has been adapted to more closely fit our Services provided to you.

Children's Privacy

We do not knowingly collect or solicit any information from children under the age of 14 years, and our Services are not directed to children. If you believe we have collected information from a child under 14, please send us an Email to help us delete such information as quickly as possible.

Other Websites and Services

Unless required under the GDPR, we are not responsible for the practices employed by any websites or services linked to or from our Services, including the information or content contained within them.

Changes

This Privacy Policy is effective as of June 24, 2026. We may update this Privacy Policy in the future at any time, and advise you to check this Privacy Policy regularly with every new update of any part of our Services that you use. We will also announce material changes via a prominent notice on our website.