Privacy Policy

1) Introduction and Contact Details of the Controller

We are pleased that you are visiting our website and thank you for your interest. Below, we inform you about the handling of your personal data when using our website. Personal data is any data with which you can be personally identified.

The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Utku Pul, Kullrichstr. 10, 44141 Dortmund, Germany, Tel.: +491738235070, Email: utkupul@gmail.com. The controller responsible for the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

The controller has appointed a data protection officer, who can be reached as follows: Utku Pul

2) Data Collection When Visiting Our Website

When using our website for informational purposes only, i.e., if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to the page server (so-called 'server log files'). When you access our website, we collect the following data that is technically necessary for us to display the website:

  • Our visited website
  • Date and time of access
  • Amount of data sent in bytes
  • Source/reference from which you reached the page
  • Browser used
  • Operating system used
  • IP address used (if applicable: in anonymized form)

Processing is carried out pursuant to Art. 6(1)(f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to subsequently review the server log files if there are specific indications of unlawful use.

For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the string 'https://' and the lock symbol in your browser line.

3) Hosting & Content Delivery Network

For hosting our website and displaying page content, we use a provider that renders its services exclusively on servers within the European Union, either itself or through selected subcontractors. All data collected on our website is processed on these servers. We have concluded a data processing agreement with the provider that ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.

4) Cookies

To make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e., small text files that are stored on your device. Some of these cookies are automatically deleted after closing the browser (so-called 'session cookies'), while others remain on your device longer and allow the storage of page settings (so-called 'persistent cookies'). In the latter case, you can find the storage duration in the overview of cookie settings of your web browser.

If individual cookies we use also process personal data, the processing takes place pursuant to Art. 6(1)(b) GDPR either for the performance of the contract, pursuant to Art. 6(1)(a) GDPR in the case of consent given, or pursuant to Art. 6(1)(f) GDPR to protect our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit.

You can set your browser to inform you about the setting of cookies and individually decide on their acceptance or exclude the acceptance of cookies for certain cases or in general. Please note that the functionality of our website may be limited if cookies are not accepted.

5) Contact

5.1 Cituro

For providing an online appointment booking function, we use the services of the following provider: Florian Heymel Consulting, Gustav-Stresemann-Str. 13, 86199 Augsburg, Germany. For the purpose of scheduling appointments, first and last name as well as email address (and, if applicable, telephone number if a telephone appointment is desired) are collected pursuant to Art. 6(1)(b) GDPR and transmitted to the provider pursuant to Art. 6(1)(f) GDPR based on our legitimate interest in effective customer management and efficient appointment administration, and stored there for appointment organization. After the appointment has been held or after the agreed appointment period has expired, your data will be deleted by the provider. We have concluded a data processing agreement with the provider that ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.

5.2 WhatsApp Business

You have the option of contacting us via the messaging service WhatsApp of WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For this we use the so-called 'Business version' of WhatsApp.

If you contact us via WhatsApp in connection with a specific transaction (e.g., a placed order), we store and use the mobile phone number you use on WhatsApp and - if provided - your first and last name pursuant to Art. 6(1)(b) GDPR to process and respond to your request. On the basis of the same legal basis, we may ask you via WhatsApp to provide further data (order number, customer number, address or email address) in order to be able to assign your inquiry to a specific process.

If you use our WhatsApp contact for general inquiries (e.g., about the range of services, availability, or our website), we store and use the mobile phone number you use on WhatsApp and - if provided - your first and last name pursuant to Art. 6(1)(f) GDPR based on our legitimate interest in efficiently and promptly providing the desired information.

Your data will only be used to respond to your inquiry via WhatsApp. It will not be passed on to third parties.

Please note that WhatsApp Business has access to the address book of the mobile device we use for this purpose and automatically transfers phone numbers stored in the address book to a server of the parent company Meta Platforms Inc. in the USA. For the operation of our WhatsApp Business account, we use a mobile device in whose address book only the WhatsApp contact data of those users are stored who have also contacted us via WhatsApp.

This ensures that every person whose WhatsApp contact data is stored in our address book has already consented to the transfer of their WhatsApp phone number from the address books of their chat contacts pursuant to Art. 6(1)(a) GDPR by accepting the WhatsApp terms of use when first using the app on their device. A transfer of data of users who do not use WhatsApp and/or have not contacted us via WhatsApp is therefore excluded.

For the purpose and scope of data collection and the further processing and use of data by WhatsApp, as well as your related rights and settings options to protect your privacy, please refer to WhatsApp's privacy notices: https://www.whatsapp.com/legal/?eea=1#privacy-policy

We have concluded a data processing agreement with the provider that protects the data of our site visitors and prohibits disclosure to third parties. In the context of the above-mentioned processing, data may be transferred to servers of Meta Platforms Inc. in the USA. For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision of the European Commission.

In the course of contacting us (e.g., via contact form or email), personal data is collected. Which data is collected in the case of using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for processing this data is our legitimate interest in responding to your request pursuant to Art. 6(1)(f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6(1)(b) GDPR. Your data will be deleted after final processing of your request. This is the case when it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided there are no legal retention obligations.

6) Use of Customer Data for Direct Marketing

Registration for our email newsletter

If you sign up for our email newsletter, we will regularly send you information about our offers. The only mandatory information for sending the newsletter is your email address. The provision of further data is voluntary and is used to address you personally. We have entrusted the technical operation of our website and the sending of the newsletter to our technical service provider Bodo Tech UG (haftungsbeschränkt), Kullrichstr. 10, 44141 Dortmund, Germany. We have concluded a data processing agreement (DPA) with Bodo Tech pursuant to Art. 28 GDPR. Bodo Tech uses the service Brevo (formerly Sendinblue), operated by Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany, for email delivery. Your data is processed on servers within the European Union (Germany and France locations). Brevo is listed as a sub-processor in our DPA with Bodo Tech. Upon registration, the following data is collected and processed: email address, preferred language (German/Turkish/English), registration source, and date and time of registration. The legal basis is your consent pursuant to Art. 6(1)(a) GDPR. The data collected by us when registering for the newsletter is used exclusively for the purpose of advertising by means of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the controller mentioned above. After unsubscribing, your email address will be immediately deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we have reserved a use of data beyond this that is permitted by law and about which we inform you in this statement. For more information about data protection at Brevo, please visit: https://www.brevo.com/de/legal/privacypolicy/

7) Web Analytics Services

7.1 1&1 IONOS WebAnalytics

This website uses the web analytics service of the following provider: 1&1 IONOS Internet SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. Using cookies and/or comparable technologies (tracking pixels, web beacons, algorithms for reading device and browser information), the service collects and stores pseudonymized visitor data, including information from the device used such as IP address and browser information, to evaluate it for statistical analyses of usage behavior on our website and to create pseudonymized usage profiles. Among other things, this enables the evaluation of movement patterns (so-called heatmaps), which show the duration of page visits as well as interactions with page content (e.g., text entries, scrolling, clicks and mouse-overs). Pseudonymization generally excludes a direct personal reference. There is no merging with clear data about your person collected in other ways. All processing described above, in particular the reading or storage of information on the device used, is only carried out if you have given us your express consent pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the 'cookie consent tool' provided on the website. We have concluded a data processing agreement with the provider that ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.

7.2 Plausible

This website uses 'Plausible', a web analytics tool from Plausible Insights OUe, Vaestriku tn 2, 50403, Tartu, Estonia. It anonymously records and evaluates interactions of randomly selected individual visitors with the website to collect information about page usage (such as visitor numbers, page views, bounce rates and dwell time). At no time is personal data processed. Plausible collects exclusively non-personal data when using this website, such as information about the browser and user agent. This is stored in a non-personally identifiable form and evaluated for statistical purposes. Deletion takes place as soon as the data is no longer needed for our evaluation purposes. If personal data is processed in individual cases, the processing is based on our legitimate interest in the statistical evaluation of usage behavior for optimization purposes pursuant to Art. 6(1)(f) GDPR.

8) Site Functionalities

8.1 Instagram Plugins

Plugins of the social network of the following provider are used on our website: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland. These plugins enable direct interactions with content on the social network. To increase the protection of your data when visiting our website, the plugins are initially deactivated and integrated into the page using a so-called '2-click' or 'Shariff' solution. This integration ensures that when a page of our website containing such plugins is called up, no connection to the provider's servers is yet established. Only when you activate the plugins and thereby give your consent to data transmission pursuant to Art. 6(1)(a) GDPR, your browser establishes a direct connection to the provider's servers. Regardless of a login to an existing user profile, certain information about your device used (including your IP address), your browser and your page history is transmitted to the provider and possibly further processed there. If you are logged into an existing user profile on the provider's social network, information about interactions carried out via the plugins will also be published there and displayed to your contacts. You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no influence on the data already transferred to the provider. Data may also be transferred to: Meta Platforms Inc., USA. We have concluded a data processing agreement with the provider that ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties. For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision of the European Commission.

8.2 Google Maps

This website uses an online map service from the following provider: Google Maps (API) from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ('Google'). Google Maps is a web service for displaying interactive (land) maps to visually present geographical information. By using this service, our location is displayed to you and any directions are made easier. When accessing the subpages in which the Google Maps map is embedded, information about your use of our website (such as your IP address) is transmitted to and stored on Google servers; this may also involve transmission to Google LLC servers in the USA. This occurs regardless of whether Google provides a user account through which you are logged in or whether a user account exists. If you are logged into Google, your data is directly assigned to your account. If you do not wish the assignment to your Google profile, you must log out before activating the button. Google stores your data (even for non-logged-in users) as usage profiles and evaluates them. The collection, storage and evaluation are carried out pursuant to Art. 6(1)(f) GDPR based on Google's legitimate interest in displaying personalized advertising, market research and/or needs-based design of Google websites. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right. Where legally required, we have obtained your consent pursuant to Art. 6(1)(a) GDPR for the processing of your data described above. You can revoke your consent at any time with effect for the future. For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision of the European Commission.

8.3 Google Web Fonts

This site uses so-called web fonts from the following provider for the uniform display of fonts: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly and establishes a direct connection to the provider's servers. Certain browser information, including your IP address, is transmitted to the provider. Data may also be transmitted to: Google LLC, USA. The processing of personal data in the course of establishing a connection with the font provider is only carried out if you have given us your express consent pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the 'cookie consent tool' provided on the website. If your browser does not support web fonts, a standard font from your computer will be used. For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision of the European Commission.

8.4 Google reCAPTCHA

On this website we use the CAPTCHA service of the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Data may also be transmitted to: Google LLC, USA. The service checks whether an input is made by a natural person or abusively by machine and automated processing, and blocks spam, DDoS attacks and similar automated malicious access. To ensure that an action is performed by a human and not by an automated bot, the provider collects the IP address of the device used, recognition data of the browser and operating system type used, as well as the date and duration of the visit, and transmits these to the provider's servers for evaluation. Cookies may be used. If the processing described above is based on cookies, these are only set if you have given us your express consent pursuant to Art. 6(1)(a) GDPR. If the processing described above is carried out without the use of cookies, the legal basis is our legitimate interest in determining individual responsibility on the Internet and avoiding misuse and spam pursuant to Art. 6(1)(f) GDPR. We have concluded a data processing agreement with the provider that ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties. For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection based on an adequacy decision of the European Commission.

9) Tools and Miscellaneous

Cookie Consent Tool

This website uses a so-called 'cookie consent tool' to obtain effective user consent for cookies and cookie-based applications that require consent. The 'cookie consent tool' is displayed to users when the page is called up in the form of an interactive user interface on which consent for certain cookies and/or cookie-based applications can be given by ticking boxes. By using the tool, all cookies/services that require consent are only loaded if the respective user grants corresponding consent by ticking the box. This ensures that such cookies are only set on the user's respective device if consent has been given. The tool sets technically necessary cookies to store your cookie preferences. Personal user data is generally not processed. If, in individual cases, personal data is processed for the purpose of storing, assigning or logging cookie settings (such as the IP address), this is done pursuant to Art. 6(1)(f) GDPR based on our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website. A further legal basis for the processing is Art. 6(1)(c) GDPR. As the controller, we are subject to the legal obligation to make the use of technically non-necessary cookies dependent on the respective user's consent.

10) Rights of the Data Subject

Applicable data protection law grants you the following data subject rights (rights of access and intervention) vis-a-vis the controller with regard to the processing of your personal data, whereby for the respective exercise requirements, reference is made to the cited legal basis:

  • Right of access pursuant to Art. 15 GDPR
  • Right to rectification pursuant to Art. 16 GDPR
  • Right to erasure pursuant to Art. 17 GDPR
  • Right to restriction of processing pursuant to Art. 18 GDPR
  • Right to notification pursuant to Art. 19 GDPR
  • Right to data portability pursuant to Art. 20 GDPR
  • Right to withdraw consent pursuant to Art. 7(3) GDPR
  • Right to lodge a complaint pursuant to Art. 77 GDPR

RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST IN THE CONTEXT OF A BALANCING OF INTERESTS, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED. HOWEVER, FURTHER PROCESSING IS RESERVED IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTION, EXERCISE OR DEFENSE OF LEGAL CLAIMS.

IF YOUR PERSONAL DATA IS PROCESSED BY US FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

11) Duration of Storage of Personal Data

The duration of storage of personal data is determined by the respective legal basis, the processing purpose and - if applicable - additionally by the respective statutory retention period (e.g., commercial and tax law retention periods).

When processing personal data on the basis of express consent pursuant to Art. 6(1)(a) GDPR, the data concerned is stored until you revoke your consent.

If statutory retention periods exist for data processed in the context of legal or similar obligations on the basis of Art. 6(1)(b) GDPR, this data is routinely deleted after the retention periods have expired, provided it is no longer necessary for contract performance or contract initiation and/or there is no legitimate interest on our part in continued storage.

When processing personal data on the basis of Art. 6(1)(f) GDPR, this data is stored until you exercise your right to object pursuant to Art. 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the assertion, exercise or defense of legal claims.

When processing personal data for the purpose of direct marketing on the basis of Art. 6(1)(f) GDPR, this data is stored until you exercise your right to object pursuant to Art. 21(2) GDPR.

Unless otherwise stated in the other information in this statement about specific processing situations, stored personal data is otherwise deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.

This privacy policy was created by the specialist lawyers of IT-Recht Kanzlei and is protected by copyright.

Last updated: 03.03.2026