Privacy Policy

In this Privacy Policy, we provide information about the processing of personal data in connection with our activities and operations including our website under the domain name tuliptowers.com. In particular, we explain what personal data we process, for what purpose, in what manner, and where. We also provide information about the rights of individuals whose data we process.

For specific or additional activities and operations, we may publish further privacy policies or other information regarding data protection.

The data controller under data protection law is:

NorthLight Living
Dr. Sarwar Pedawi
Waziran, Opposite Sami Abdulrahman Park
Erbil, Iraq · 44001

info@tuliptowers.com

In individual cases, third parties may be responsible for the processing of personal data, or there may be joint responsibility with third parties. Upon request, we are happy to provide data subjects with information regarding the respective responsibility.

1. Definitions and Legal Bases

1.1 Definitions

Data Subject: A natural person whose personal data we process.

Personal Data: Any information relating to an identified or identifiable natural person.

Sensitive Personal Data: Data regarding economic, political, religious, or philosophical views and activities; data regarding health, the intimate life, or ethnic or racial origin; genetic data; biometric data that uniquely identifies a natural person; data regarding criminal or administrative sanctions or prosecutions; and data regarding social assistance measures.

Any processing of personal data, regardless of the means and methods used, such as querying, matching, adapting, archiving, storing, retrieving, disclosing, obtaining, collecting, collection, deletion, disclosure, sorting, organizing, storage, modification, dissemination, linking, destruction, and use of personal data.

European Economic Area (EEA): Member­ of the European Union (EU), as well as the Principality of Liechtstein, Iceland, and Norway.

1.2 Legal­ Basis

We process personal data in accordance with Swiss law, in particular the Federal Act on Data­ (Data Protection Act, DSG) and the Ordinance on Data Protection (Data Protection Ordinance, DSV).

We process – provided that and to the extent that the European General Data Protection Regulation (GDPR) applies – personal data in accordance with at least one of the following legal bases:

  • Art. 6(1)(b) GDPR for the necessary processing of personal data to fulfill a contract with the data subject and to carry out pre-contractual measures.
  • Article 6(1)(f) of the GDPR for the necessary processing of personal data to safeguard legitimate interests – including the legitimate interests of third parties – provided that the fundamental freedoms and rights as well as the interests of the data subject do not take precedence. Such interests include, in particular, the sustainable, user-friendly, secure, and reliable conduct of our activities and operations; ensuring information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law.
  • Art. 6(1)(c) GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of Member States in the European Economic Area (EEA).
  • Art. 6( 1(e) of the GDPR for the necessary processing of personal data to perform a task carried out in the public interest.
  • Art. 6(1)(a) GDPR for the processing of personal data with the consent of the data subject.
  • Art. 6(1)(d) GDPR for the necessary processing of personal data necessary to protect the vital interests of the data subject or another natural person.
  • Art. 9(2) et seq. of the GDPR for the processing of special categories of personal data, in particular with the consent of the data subjects.


The European General Data Protection Regulation (GDPR) refers to the handling of personal data as “processing of personal data” and the handling of sensitive personal data as “processing of special categories of personal data” (Art. 9 GDPR).

2. Nature, Scope, and Purpose of the Processing of Personal Data

We process the personal data that is necessary to carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. The personal data processed may include, in particular, the following categories: browser and device data, content data, communication data, metadata, usage data, and master data – including inventory and contact data, location data, transaction data, contract data, and payment data. The personal data may also constitute special-category personal data.

We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, to the extent that such processing is permitted.

We process personal data, where necessary, with the consent of the data subjects. In many cases, we may process personal data without consent, for example, to comply with legal obligations or to safeguard legitimate interests. We may also request consent from data subjects even when their consent is not required.

We process personal data for the period necessary for the respective purpose. We anonymize or delete personal data, in particular, in accordance with statutory retention and statute of limitations periods.

3. Disclosure of Personal Data

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties may include, for example, specialized providers whose services we use. Such third parties may, in turn, disclose personal data to other third parties.

We may disclose personal data in the course of our activities and operations, in particular to banks and other financial service providers, government agencies, educational and research institutions, consultants and attorneys, bookkeeping accounting and fiduciary service providers, debt collection agencies, advocacy groups, IT service providers, cooperation partners, credit and business­ information agencies, logistics and shipping­ companies, marketing and advertising­ agencies, media outlets, parent, sister, and subsidiary­ companies, organizations and associations, social institutions, telecommunications companies, insurance companies, and payment service providers.

4. Communication

We process personal data in order to communicate with individuals as well as with government agencies, organizations, and companies. In doing so, we process, in particular, data that a data subject provides to us when contacting us, for example, by mail or email. We may store such data in an address book or using similar tools.

Third parties who provide us with data about other individuals are legally obligated to independently ensure the data protection of those data subjects. In particular, they must guarantee that they are authorized to provide such data and must also ensure the accuracy of the transmitted data.

We use selected services from suitable providers to enable and improve communication with individuals and other communication partners. We may also use such services to manage and otherwise process the data of data subjects beyond the scope of direct communication, for example in connection with orders, services, projects, and resource planning.

In particular, we use:

5. Data Security

We implement appropriate technical and organizational measures to ensure data security commensurate with the respective risk. Through these measures, we ensure, in particular, the confidentiality, availability, traceability, and integrity of the personal data we process; however, we cannot guarantee absolute data security.

Access to our website and our other digital presence is provided via transport encryption (SSL/TLS, specifically using the Hypertext Transfer Protocol Secure, abbreviated as HTTPS). Most browsers warn users before visiting a website without transport encryption.

Our digital communication is subject – as is in principle all digital communication – to mass surveillance without cause or suspicion by security agencies in Switzerland, the rest of Europe, the United States of America (USA), and other countries. We have no direct influence over how by intelligence agencies, police departments, and other security authorities. Nor can we rule out the possibility that a data subject may be specifically monitored.

6. Personal Data Abroad

We process personal­ data as a general rule in Switzerland and in the European­ Economic Area (EEA). However, we may also export or transfer personal­data to other countries, in particular to process it there or have it processed there.

We may transfer personal data to all countries on Earth and elsewhere in the universe, provided that the law there complies with decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – also in accordance with Decision of the European Commission ensures an adequate level of data protection.

We may transfer personal data to countries whose laws do not guarantee an adequate level of data protection, provided that data protection is ensured for other reasons, in particular on the basis of standard data protection clauses or other appropriate safeguards. In exceptional cases, we may export personal information to countries without adequate or appropriate data protection if the specific requirements under data protection law are met, such as the explicit consent of the data subjects or a direct connection to the conclusion or performance of a contract. Upon request, we are happy to provide data subjects with information about any safeguards or to supply a copy of any safeguards.

7. Rights of Data Subjects

7.1 Data Protection Claims

We grant data subjects all rights in accordance with applicable law. In particular, data subjects have the following rights:

  • Right of Access: Data subjects may request information as to whether we process personal data about them and, if so, what personal data is involved.
    Data subjects shall also receive the information necessary to exercise their data protection rights and to ensure transparency. This includes the personal data being processed as such, but also, among other things, details regarding the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the person
  • Correction and Restriction: Data subjects may correct inaccurate personal­ data, complete incomplete data, and have the processing of their data­ restricted.
  • Opportunity to express one’s own viewpoint and request a human review: Data subjects may, in the case of decisions that are based exclusively on automated processing of personal data and that result in legal effects concerning them or significantly affect them (automated individual decisions), may present their own point of view and request that the decision be reviewed by a human.
  • Erasure and Objection: Data subjects may have personal data erased (“right to be forgotten”) and may object to the processing of their data with effect for the future.
  • Data Retrieval and Data Portability: Data subjects may request the disclosure of personal data or the transfer of their data to another data controller.
  • We may postpone, restrict, or refuse the exercise of data subjects' rights within the scope permitted by law. We may inform data subjects of any prerequisites that must be met for the exercise of their data protection rights. For example, we may refuse to provide information in reference to confidentiality obligations, overriding interests, or the protection of other individuals. For example, we may also refuse, in whole or in part, to erase personal data, particularly by citing legal retention obligations.

In exceptional cases, we may charge a fee for the exercise of rights. We will inform data subjects in advance of any such costs.

We are obligated to take reasonable measures to identify data subjects who request information or assert other rights. Data subjects are required to cooperate.

7.2 Legal Protection

Data subjects have the right to enforce their data protection claims through legal channels or to file a report or complaint with a data protection supervisory authority.

The data protection supervisory authority for private data controllers and federal agencies in Switzerland is the Federal Data Protection and Information Commissioner (EDÖB).

European data protection supervisory authorities are organized as members of the European Data Protection Committee (EDSA). In some member states of the European Economic Area  (EEA), the data protection supervisory authorities have a federal structure, particularly in Germany.

8. Use of the Website

8.1 Cookies

We may use cookies. Cookies – including our own cookies (first-party cookies) as well as cookies from third parties whose services we use (third-party cookies) – are data stored in the browser. Such stored data is not necessarily limited to traditional text-based cookies.

Cookies can be stored temporarily in the browser as “session cookies” or for a specific period of time as so-called “persistent cookies.” “Session cookies” are automatically deleted when the browser is closed.

Persistent cookies have a specific retention period. In particular, cookies make it possible to recognize a browser the next time you visit our website and thereby, for example, measure the reach of our website. However, persistent cookies can also be used for online marketing, for example.

Cookies can be disabled entirely or partially at any time in your browser settings, restricted, or deleted at any time. Browser settings often also allow for the automatic deletion and other management of cookies. Without cookies, our website may no longer be fully available. We actively request – at least to the extent required by applicable law – your explicit consent to the use of cookies.

For cookies used to measure performance and reach or for advertising, many services offer a general opt-out option via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), and YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

8.2 Logging

For every visit to our website and our other digital presence, we may log at least the following information, provided that it is determined or transmitted to our digital infrastructure by default during such visits: date and time, including time zone, IP address, access status (HTTP status code), operating system, including user interface and version, browser, including language and version, individual subpages of our website accessed, including the amount of data transferred, last website accessed in the same browser window (referrer).

We log such information, which may also constitute personal data, in log files.

This information is necessary to ensure that our digital presence is available on a long-term basis, in a user-friendly and reliable manner. It is also necessary to ensure data security – including through third parties or with the assistance of third parties.

8.3 Web Beacons

We may incorporate tracking pixels into our digital presence. Tracking pixels are also known as web beacons. Tracking pixels – including those from third parties whose services we use – are typically small, invisible  images or scripts written in JavaScript that are automatically loaded when you access our digital presence. Tracking pixels can collect at least the same information as is recorded in log files.

9. Social Media

We maintain a presence on social media platforms and other online platforms to communicate with interested individuals and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside of Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC), Terms of Use, privacy policies, and other provisions of the individual operators of such platforms also apply. These provisions provide information, in particular, about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right of access.

For our social media presence on Facebook, including so-called Page Insights, we are – to the extent that the General Data Protection Regulation (GDPR) applies – jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the U.S.). Page Insights provide information about how visitors interact with our Facebook page. We use Page Insights to ensure that our social media presence on Facebook is effective and user-friendly.

Further information on the nature, scope, and purpose of data processing, details regarding the rights of data subjects, and the contact information for Facebook and Facebook’s Data Protection Officer can be found in the Facebook Privacy Policy.

We have entered into the so-called “Addendum for Controllers” with Facebook and have thereby specifically agreed that Facebook is responsible for ensuring the rights of data subjects. For what are known as Page Insights, the relevant information can be found on the page “Information on Page Insights”, including “ Information on Page Insights Data”.

10. Third-Party Services

We use services provided by specialized third parties to ensure that we can carry out our activities and operations in a sustainable, user-friendly, secure, and reliable manner. These services allow us, among other things, to embed features and content into our website. When such embedding occurs, the services used collect – at least temporarily – the IP addresses of users for technically necessary reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data related to our activities and operations in an aggregated, anonymized, or pseudonymized form. This includes, for example, performance or usage data required to provide the respective service.

In particular, we use:

10.1 Digital Infrastructure

We use services from specialized third parties to access the digital infrastructure required for our activities and operations. These include, for example, hosting and storage services from selected providers.

10.2 Maps

We use third-party services to embed maps on our website.

In particular, we use:

11. Measuring Success and Reach

We strive to measure the success and reach of our activities and operations. In this context, we may also measure or evaluate the impact of third parties or test how different parts or versions of our digital presence are used (the “A/B testing” method). Based on the results of our success and reach­, we can, in particular, fix errors, enhance popular content, or make improvements.

For performance and reach measurement, in most cases the IP addresses of individual users are collected. In this case, IP addresses are always truncated (“IP masking”) to comply with the principle of data minimization through the corresponding pseudonymization.

Cookies may be used to measure performance and reach, and user profiles may be created. Any user profiles created may include, for example, the individual pages visited or content viewed on our digital presence, information about the size of the screen or browser window, and the – at least approximate – location. As a general rule, any user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Certain third-party services with which users are registered may, in some cases, associate the use of our online offering with the user’s account or profile on the respective service.

In particular, we use:

  • Google Marketing Platform: Performance and reach measurement, in particular with Google Analytics; Provider: Google;
    Google Marketing Platform-specific information: Measurement also across various browsers and devices (cross-device tracking) using pseudo pseudonymized IP addresses, which are only in exceptional cases transmitted in full to Google in the U.S., Privacy Policy for Google Analytics, “Browser add-on to disable Google Analytics”.
  • Google Tag Manager: Integration and management of services from Google and third parties, in particular for measuring performance and reach; Provider: Google; Google Tag Manager-specific information: Privacy Policy for Google Tag Manager; further information on data protection can be found in the privacy policies of the individual integrated and managed services.

12. Video Surveillance

We use video surveillance to prevent criminal offenses, to secure evidence in the event of criminal offenses, to exercise and assert our own legal claims, to defend against third-party legal claims, and to enforce our right to manage our premises. In doing so – provided and to the extent that the data General Data Protection Regulation (GDPR) is applicable – overriding legitimate interests pursuant to Article 6(1)(f) of the GDPR, and in the case of particularly sensitive personal data, with reference to Art. 9(2)(f) of the GDPR.

We store recordings from our video surveillance for as long as they are necessary to preserve evidence or for any other specified purpose.

We may preserve recordings from our video surveillance and transmit them to competent authorities, such as, in particular, courts or law enforcement agencies, provided that such transmission is necessary for a specified purpose, in our other legitimate and overriding interest, or due to legal obligations.

13. Concluding Notes on the Privacy Policy

We created this Privacy Policy using the Privacy Policy Generator from Data­Protection­Partner  on July 15, 2026.

We may update this Privacy Policy at any time. We will notify you of updates by publishing the most current privacy policy on our website.