1. Data Controller

2. Personal Data We Process

• Identity and contact data: name, company name, job title, e-mail address, phone number, country and city.
• Request data: products, quantities and messages you send through our contact and quote forms.
• Customer transaction data: order, quotation, invoice and delivery details.
• Security and usage data: IP address, browser type, pages visited and cookie data.

We do not process special categories of personal data such as health, religion or ethnic origin; please do not share such information in our forms.

3. Purposes of Processing

• Responding to your quotation, catalog and sample requests and communicating with you.
• Managing orders, contracts, invoicing and shipments.
• Complying with our legal obligations (tax, commercial and consumer law).
• Keeping our website secure and improving its use.
• Sending product, trade show and campaign news if you have given your consent.

4. Legal Basis

• Performance of a contract or steps prior to entering into a contract (GDPR Art. 6(1)(b); KVKK Art. 5/2-c).
• Compliance with a legal obligation (GDPR Art. 6(1)(c); KVKK Art. 5/2-ç).
• Our legitimate interests, provided they do not override your rights (GDPR Art. 6(1)(f); KVKK Art. 5/2-f).
• Your consent for marketing communication (GDPR Art. 6(1)(a); KVKK Art. 5/1). You may withdraw your consent at any time.

5. Sharing of Personal Data

We do not sell your personal data or share it with third parties for their marketing. Your data may be shared only for the purposes above with:

• Shipping and logistics companies, banks and our accounting advisors.
• Hosting, e-mail and IT service providers.
• Competent public authorities where required by law.

Because of the e-mail and cloud services we use, your data may be processed on servers outside Türkiye or the EU. Such transfers are carried out with the safeguards required by KVKK Art. 9 and the GDPR.

6. Retention

We keep personal data for as long as necessary for the purposes of processing and for the statutory retention periods (generally 10 years for commercial records). Afterwards, data is deleted, destroyed or anonymised.

7. Cookies

Our website may use strictly necessary cookies and analytics cookies (e.g. Google Analytics) to measure visits. You can delete or block cookies in your browser settings; some parts of the site may then not work properly.

8. Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss and misuse. Only employees who need the data for their work can access it.

9. Your Rights

Under KVKK Art. 11 and the GDPR you have the right to:

• Learn whether your personal data is processed and request information about it.
• Learn the purpose of processing and whether it is used accordingly.
• Know the third parties to whom your data is transferred.
• Request correction of incomplete or inaccurate data.
• Request deletion or destruction of your data.
• Object to processing and claim compensation for unlawful processing.
• (GDPR) Request data portability and lodge a complaint with the data protection authority in your country.

Please send your requests to info@luxpamuk.com.tr or in writing to the address above. We will respond free of charge within 30 days at the latest.

10. Changes

We may update this policy to reflect changes in legislation or our practices. The current version is always published on this page.

Last updated: November 2026