Mobile Number: +49-6131-6366781
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Privacy Policy

Data Protection Policy

1. Name and contact details of the data controller

Alukun Ltd.

Represented by

Sani Baysal

Sebastian Baysal

Vandana Geerman

Contact Information

Serdika Str. 2b 3. Stock, Office 1

8000 Burgas


Phone: +49 (0) 6131 6366781




Contact details of the data protection officer:

Our data protection officers can be contacted by email at

2. Extent and purpose of the processing of personal data

2.1 Accessing the website

When accessing this website, the internet browser used by the visitor automatically sends data to the website’s server, which is stored temporarily in a log file. The following data is saved without further input by the visitor until it is erased automatically:

We have a legitimate interest in data processing for:

This processing is expressly not to identify the visitor to the website.

2.2 Contact form

Visitors can send messages to us via an online contact form on the website. We require your name and a valid email address so that we can answer your query. The person submitting the question can provide all of the other information voluntarily. When you use the contact form, you confirm that you know this policy and agree to process the submitted data. Data processing is carried out exclusively for processing and answering queries via the contact form. This takes place based on the voluntary consent provided. The data is erased if the grounds for storage are no longer obtained.

Registration as a customer

If you register for our webshop, the following data is collected by us:

Address information

Contact details

Log-in data

The data is stored for ten years following statutory regulations. The data is erased if there are no other grounds for storage when this period elapses.

Ordering on the webshop

When you place an order in the webshop, the following data is collected about you:

If you are registered as a customer, the address and contact details set up for you are used for your order when you log in. If you do not live in Bulgaria, your data will also be stored and is vital to your shipping information. If you order as a guest, the following data is collected about you:

Address information

Contact details

Your VAT registration number, if applicable

The data is stored for ten years by the regulations.

Complaint form

If you use our complaint form, the following data is collected by us:

Address information

Contact details

Contact details

** This data is erased when the statutory storage periods elapse.

3. Transfer of data

Depending on your payment method of choice, the following service providers will have access to your data.


PayPal (Europe) S.à r.l. et Cie, S.C.A.

22-24 Boulevard Royal

L-2449 Luxembourg

DSK Bank

Address: 19 Moskova street


Personal data is transferred to third parties if

In other cases, personal data is not passed on to third parties.

4. Cookies

Legal framework

The term "Cookie," referred to as a web cookie, internet cookie, browser cookie, or magic cookie, refers to a combination of data that a computer receives and then sends back without changing or altering it. These "Cookies" consist of information. This process takes place when the browser user visits a particular website. The visited website, in this case, "AluKun," will automatically send cookies to your computer. Your computer, in turn, will store this information inside your web browser. "AluKun's" cookies do not seek to harm you. AluKun's cookies seek to gather data on performance and functionality, social media, analytics, and advertising.

Cookies are subject to the data protection regulations applicable in Germany, such as the Telemedia Act (TMG), the Federal Data Protection Act (BDSG), or the Telecommunications Act (TKG), so-called cookies are used on the website. These data packages are exchanged between the website server and the visitor’s browser. They are stored by the devices used to visit the website (PC, notebook, tablet, smartphone, etc.). Cookies cannot damage the instruments used. In particular, they do not contain any viruses or other malware. The cookies store information associated with the specific end device used. This information does not allow us under any circumstances to determine the identity of the website visitor.

Under the default browser settings, cookies are usually accepted. The browser settings can either be adjusted to reject cookies on the devices or provide specific information before a new cookie is stored. However, we point out that activating cookies may mean that some of the function websites’ functions are used at their best.

Cookies serve to make use of our website more convenient. For example, session cookies can determine whether the visitor has previously visited individual website pages. These session cookies are erased automatically when you leave the website.

Temporary cookies are used to improve user-friendliness. They are stored for a brief period on the visitor’s device. If the visitor returns to the website, it is possible to recognize that they have accessed the page previously and to apply the inputs and settings that were used on that occasion so that they do not have to be repeated. No personal data is processed in this connection.

Cookies are also used to analyze access to the website for statistical purposes and to improve what we offer. These cookies make it possible to recognize automatically that the visitor previously accessed the website. The cookies are erased after a fixed period.

The data processed using cookies is justified for the above purposes to pursue the legitimate interests of the legal practice under Art. 6 (1) subparagraph 1 (f) GDPR. More details on cookie usage can be found in the following section.

5. Analysis services for websites, tracking


Google Analytics

This website uses Google Analytics, a Google Inc. web analysis service (“Google”). Google Analytics uses so-called “cookies”, text files stored on your computer, and facilitates analysis of your website use. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. Suppose IP anonymization is activated on this website. In that case, your IP address will first be truncated by Google within Member States of the European Union or in other countries that are signatories to the Agreement on the European Economic Area. Please note that Google Analytics on this website has been extended to include the code “gat._anonymizeIp();” to ensure an anonymized collection of IP addresses (so-called IP masking).

Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. Google uses this information on behalf of the operator of this website to evaluate your use of the website, compile reports about website activities, and provide other services associated with the website and the internet for the website operator. The IP address transferred by your browser in the context of Google Analytics is not associated with any other Google data. You can prevent the cookies’ storage by a corresponding setting in your browser software; we wish to point out, however, that in this case, you may not be able to use all of the functions of this website to their full extent.

Further information about the terms of use and data protection can be found at

The analytical tool’s legal basis is Art. 6 (1) subparagraph 1 (f) GDPR. Website analysis is in the legitimate interests of our com. It is used for the statistical recording of the use of the site for ongoing improvement of our website and the services we offer.


Google Remarketing

These technologies collect information used in aggregate form to help us understand how our website is being used and help us continuously improve our websites. Google uses cookies to analyze website usage, which forms the basis for creating interest-related advertisements. The cookies are used to record visits to the website and anonymous data on the use of the website. There is no storage of the personal data of visitors to the website. If you subsequently visit another website in the Google Display Network, you will see advertisements that are highly likely to include previously accessed product and information areas.

Your data may also be transferred to the USA. The European Commission has issued an adequacy decision for data transfers to the USA. This is based on Art. 6 (1) f DSGVO in the legitimate interest of targeting website visitors with targeted advertising by placing personalized, interest-related advertisements on the provider's website when visitors visit other websites in the Google Display Network.

For reasons arising from your particular situation, you have the right to object to this data processing based on Art. 6 (1) f DSGVO. To do this, you can permanently deactivate the use of cookies by Google by following the following link and downloading and installing the plug-in provided there:
com/ads/answer/7395996?hl=en Alternatively, you can disable the use of cookies by third parties by visiting the Network Advertising Initiative's opt-out page at https://www.networkadvertising
.org/choices/ and implementing the opt-out information provided there.

For more information about Google Remarketing and its privacy policy, please visit

Google Ads

Google Conversion Tracking is an analysis service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). On our website, we use the online advertising program “Google Ads” and, in this context, conversion tracking. When you click on an ad placed by Google, a conversion tracking cookie is placed on your computer. These cookies have limited validity, do not contain personal data, and are therefore not used for personal identification. If you visit certain pages of our website and the cookie has not expired, Google and we may recognize that you clicked on the ad and were directed to that page. Each Google Ads customer receives a different cookie. As a result, there is no way that cookies can be tracked through AdWords customer websites.

The conversion cookie is used to compile conversion statistics. We learned the total number of users who clicked on one of our ads and were directed to a page with a conversion tracking tag. We do not receive information that identifies users. The processing is based on Art. 6 (1) lit. f DSGVO for the legitimate interest in targeted advertising and the analysis of the effect and efficiency of this advertising.

For reasons arising from your particular situation, you have the right to object to this data processing based on Art. 6 (1) f DSGVO. For this purpose, you can prevent the storage of cookies by selecting the appropriate technical settings in your browser software. However, we would like to point out that in this case, you may not be able to use all functions of this website to their full extent. You will then not be included in the conversion tracking statistics.

You can also deactivate personalized advertising for you in the Google advertising settings. In addition, you can deactivate the use of cookies by third parties by calling up the deactivation page of the Network Advertising Initiative at
/choices/ and implementing the further information on opt-out mentioned there.

Further information and Google's privacy policy can be found at:

Social Media

Facebook remarketing / retargeting

Remarketing tags of the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA, are integrated into our pages. When you visit our site, the remarketing tags establish a direct connection between your browser and the Facebook server. Facebook is notified that you have seen our site with your IP address. As a result, Facebook can associate the visit to our site with your user account. We can use the information obtained in this way to display Facebook ads. Please note that, as the provider of the web pages, we have no knowledge of the content of the data transferred and how Facebook uses it. You can find further information about this data protection policy on Facebook at If you do not want Custom Audience to collect your data, you can deactivate Custom Audience.

Conversion measurement with the Facebook visitor action pixel

With your consent, we use the “visitor action pixel” of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) on our website. We can use it to track users’ actions after they have seen or clicked on a Facebook advertisement. In this way, we can record the effectiveness of Facebook advertisements for statistical and market research purposes. The data collected in this way is anonymous; in other words, we do not see the personal data of individual users. However, this data is stored and processed by Facebook, and we provide you with information about this to the best of our knowledge. Facebook can associate this data with your account and use it for marketing purposes, following Facebook’s data usage policy You can enable Facebook and its partners to display advertising on and outside Facebook. A cookie may also be stored on your computer for this purpose. Consent may be given only by users aged 13 and older. If you are younger, please ask your parents or guardians for advice.

Use of Hotjar on our website

We use Hotjar to understand our users’ needs and optimize this website’s offerings. Hotjar's technology helps us better understand our user’s experiences (e.g., how much time users spend on which pages, which links they click, what they like and dislike, etc.) and helps us tailor our offerings to our users' feedback. Hotjar uses cookies and other technologies to collect information about the behavior of our users and their devices (including, but not limited to, the IP address of the device (collected and stored only in an anonymous form), screen size, unique device

identifiers, information about the browser used, location (country only), preferred language for viewing our website). Hotjar stores this information in a pseudonymous user profile. Hotjar or us will not use the data to identify individual users or merge with other information about individual users. For more information, please see Hotjar's privacy policy here.

You may opt-out of Hotjar's storage of a user profile and information about your visit to our website and Hotjar's use of tracking cookies on other websites by clicking this opt-out link.

6. Personal Data “Your rights as the data subject.”

Insofar as your data is processed when you visit our website, you have the following rights as the “data subject” within the meaning of the GDPR:

6.1 Information

You have the right to request confirmation from us whether or not we are processing personal data concerning you. There is no right to information if disclosure of the information requested would breach a confidentiality obligation or if the information must be kept secret on other grounds, mainly because of an overriding legitimate interest of a third party. Notwithstanding the above, there may be an obligation to disclose the information if your interests override the confidentiality interest, in particular given imminent damages. The right to information is also excluded if the data is stored because it cannot be erased based on legal or statutory retention periods, is used exclusively for purposes of backing up data or data protection monitoring, if disclosure of the information is associated with a disproportionately large amount of work, and if appropriate technical and organizational measures prevent processing for other purposes.

6.2 Rectification and completion

If you establish that we have incorrect personal data about you, you may demand rectification of this inaccurate data by us without undue delay. If the personal data concerning you is incomplete, you may require that it be completed.

6.3 Erasure

You have the right to erasure ("right to be forgotten"), provided that the processing is not necessary to exercise the right to freedom of expression, the right to information, to comply with a legal obligation, or to perform a task of public interest, is necessary, and one of the following reasons applies:

There is no right to deletion if, in the case of lawful, non-automated data processing, deletion is not possible or only possible with disproportionate effort due to the particular type of storage and your interest in deletion is low. In this case, the restriction of processing takes the place of deletion.

6.4 Restriction of processing

You may demand that we restrict the processing if one of the following grounds applies:

Restriction of processing means that the personal data may be processed with your consent to establish, exercise, or defend against legal claims, to protect the rights of another natural or legal person, or for reasons of significant public interest. Before we lift the restriction, we should inform you of this.

6.5 Data portability

You have the right to data portability if the processing is based on your consent (Art. 6 Para. 1 Sentence 1 Letter a) or Art. 9 Para. 2 Letter a) GDPR) or on a contract whose contracting party You are, the processing is carried out using automated procedures. In this case, the right to data portability includes the following rights, provided this does not affect the rights and freedoms of other persons: You can request that we receive the personal data that you have provided to us in a structured, familiar, and machine-readable format. You have the right to transmit this data to another responsible person without hindrance on our part. As far as technically feasible, you can request that we communicate your personal information directly to another person responsible.

6.6 Objection

Where the processing is based on Art. 6 (1) subparagraph 1 (e) GDPR (performance of a task carried out in the public interest or the exercise of official authority vested in the controller) or on Art. 6 (1) subparagraph 1 (f) GDPR (legitimate interest of the data controller or a third party), you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you. This also applies to profiling based on Art. 6 (1) subparagraph 1 (e) or (f) GDPR. Once you have exercised your right to object, we shall no longer process your data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms or if the processing serves to establish, exercise, or defend against legal claims.

You may lodge an objection to processing the personal data concerning you for direct marketing purposes at any time. Once you have exercised this right to object, we shall no longer use the personal data concerning you for purposes of direct marketing. This also applies to the profiling associated with such direct marketing.

You can notify us informally of your objection by telephone, email, fax, or by writing to the postal address of our legal practice provided at the beginning of this data protection policy.

6.7 Withdrawal of consent

You have the right to withdraw consent that you have given at any time, with effect from that point forward. Withdrawal of consent may be communicated informally via phone, email, fax, or our postal address. The withdrawal does not affect the lawfulness of the data processing carried out based on your consent until receipt of its departure. On receipt of the exit, the data processing based exclusively on your consent shall stop.

6.8 Complaints

Suppose you believe that the processing of your data is unlawful. In that case, you can lodge a complaint with a data protection supervisory authority responsible for your place of residence or work or the place of the alleged infringement.

7. Version and updating of this data protection policy

This data protection declaration is dated 27.01.2022. We reserve the right to update the data protection declaration in due course to improve data protection and adapt it to changed official practice or case law.