Privacy Policy
Last updated: 18 May 2025 · Effective: 18 May 2025
This policy applies to all personal data processed by Alunika Systems through the website https://alunikasystems.com and in connection with our business activities.
1. Identity of the Data Controller / Data Fiduciary
Alunika Systems (hereinafter "Alunika Systems," "the Company," "we," "us," or "our") is the Data Controller under the GDPR and UK GDPR, the Data Fiduciary under the Indian DPDP Act 2023, and the Data Controller under UAE PDPL 2021.
Registered Address
G-6, Bypass Road, Langre ki Chowki, Water Works, Agra, Uttar Pradesh 282003, India
Data Protection Officer (DPO) / Grievance Officer
Where required by applicable law, we have appointed a Data Protection Officer. Contact:
- Email: alunika@alunikasystems.com
- Postal: Data Protection Officer, G-6, Bypass Road, Langre ki Chowki, Water Works, Agra, Uttar Pradesh 282003, India
- Response time: We aim to respond within 30 calendar days (GDPR), 30 days (UAE PDPL), 30 days (DPDP Act).
EU/UK Representative
As Alunika Systems is established outside the EU/UK but processes data of EU/UK data subjects, we are in the process of designating an EU and UK representative pursuant to Article 27 GDPR. Until a representative is formally appointed, all enquiries should be directed to alunika@alunikasystems.com.
2. Scope of This Policy
This Policy applies to:
- Visitors to and users of https://alunikasystems.com;
- Architects, specifiers, engineers, contractors, and procurement professionals who engage with our product information, technical downloads, or contact forms;
- Business clients, distributors, and supply-chain partners;
- Prospective employees who submit applications via our Careers page;
- Any natural person whose personal data we process in connection with our export and manufacturing business activities globally.
This Policy does not apply to the personal data of our own employees processed in the context of employment, which is governed by our internal Employee Privacy Notice.
3. Categories of Personal Data We Collect
3.1 Data You Provide Directly
- Identity Data: Full name, title, professional designation, company/organisation name.
- Contact Data: Business email address, telephone number, postal address, country of residence.
- Enquiry & Project Data: Project specifications, quantities, technical requirements, and any content submitted through contact, lead, or specification request forms.
- Correspondence Data: Records of emails, messages, and other communications exchanged with us.
- Career Data: Curriculum vitae, cover letters, educational and employment history, professional references (submitted via Careers page).
3.2 Data Collected Automatically
- Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, time zone.
- Usage Data: Pages viewed, time spent, referral URLs, click-path data, scroll depth, and interaction events.
- Cookie & Tracking Data: Session cookies, persistent cookies, and similar tracking technologies (see Section 8 below).
3.3 Data Received from Third Parties
- Business contact information from publicly available trade directories, architectural professional registers, or industry databases;
- Analytics and audience data from third-party analytics providers (e.g. Google Analytics);
- Technical performance data from content delivery networks and hosting providers.
Special Categories of Data: We do not intentionally collect special category data (sensitive personal data) as defined under GDPR Article 9, UAE PDPL Article 4, or DPDP Act sensitive data provisions. If such data is inadvertently provided, it will be promptly deleted unless legally required to retain it.
Children's Data: Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that personal data of a minor has been collected without appropriate consent, we will take steps to delete it immediately.
4. Legal Bases for Processing
We process your personal data only where a valid legal basis exists. The applicable bases vary by jurisdiction:
4.1 Under EU/UK GDPR (Article 6)
- Contractual Necessity (Art. 6(1)(b)): Processing necessary for the performance of a contract, or to take pre-contractual steps at your request (e.g. responding to specification enquiries, preparing quotations).
- Legitimate Interests (Art. 6(1)(f)): Processing necessary for our legitimate interests, including: business development and marketing to B2B professionals, website security, fraud prevention, and improving our services — where such interests are not overridden by your rights and freedoms.
- Legal Obligation (Art. 6(1)(c)): Processing required by applicable law, including export control regulations, tax obligations, anti-money laundering laws, and court orders.
- Consent (Art. 6(1)(a)): Where you have given explicit, freely-given, specific, informed, and unambiguous consent (e.g. subscription to marketing communications). You may withdraw consent at any time without detriment.
4.2 Under UAE PDPL (Federal Decree-Law No. 45/2021)
We process personal data of UAE data subjects under the grounds of consent, contractual necessity, legal obligation, vital interests, or legitimate interests as permitted under the PDPL and its implementing regulations issued by the UAE Data Office.
4.3 Under Indian DPDP Act 2023
We process personal data of Indian Data Principals on the basis of consent (obtained in a clear, plain-language notice), or under deemed consent as permitted by Section 7 of the DPDP Act 2023 (e.g. for performance of a contract, legal compliance, medical emergency, employment, or State functions). We maintain records of all consents obtained.
4.4 Under CCPA/CPRA (California, USA)
We do not sell personal information as defined under the CCPA. We do not share personal information for cross-context behavioural advertising. California residents have the rights set out in Section 9.4 below.
5. Purposes of Processing
| Purpose | Legal Basis |
|---|---|
| Responding to specification, product, and quotation enquiries | Contractual necessity / Legitimate interests |
| Processing and delivering technical data sheets, BIM files, and product documentation | Contractual necessity |
| Managing ongoing client and business partner relationships | Contractual necessity / Legitimate interests |
| Operating and improving our website and user experience | Legitimate interests |
| Sending marketing communications to B2B professionals (where permitted) | Legitimate interests (B2B) / Consent (B2C) |
| Processing career applications | Pre-contractual steps / Consent |
| Compliance with export control, customs, and trade regulations | Legal obligation |
| Fraud prevention, network security, and abuse detection | Legitimate interests / Legal obligation |
| Analytics and business intelligence | Legitimate interests / Consent |
| Legal claims, compliance, and regulatory reporting | Legal obligation / Legitimate interests |
6. Data Sharing and Disclosure
We do not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual protections:
6.1 Service Providers (Data Processors)
- Cloud Infrastructure: Supabase Inc. (database hosting — governed by a Data Processing Agreement);
- Website Hosting & CDN: Vercel Inc. (governed by Vercel's Data Processing Addendum);
- Analytics: Google LLC (Google Analytics — with IP anonymisation enabled where required by law);
- Email Communications: Email service providers used to respond to enquiries;
- Professional Advisers: Lawyers, accountants, auditors, and insurers bound by professional confidentiality obligations.
6.2 Legal and Regulatory Bodies
We may disclose personal data to courts, regulatory authorities, law enforcement agencies, or government bodies where required by law, court order, or to protect our legal rights.
6.3 Corporate Transactions
In the event of a merger, acquisition, asset sale, or restructuring, personal data may be transferred to the relevant third party, subject to equivalent data protection obligations.
All third-party processors are required to process personal data only on our instructions and in accordance with applicable data protection law.
7. International Data Transfers
As a global export business, your personal data may be transferred to, stored in, and processed in countries outside your country of residence. We implement the following safeguards:
- EU/UK GDPR: Transfers to third countries are made on the basis of European Commission Adequacy Decisions, EU Standard Contractual Clauses (SCCs) (Commission Decision 2021/914), or UK International Data Transfer Agreements (IDTAs) where applicable.
- UAE PDPL: Transfers outside the UAE are subject to confirmation that the destination country provides an adequate level of protection, or are governed by appropriate contractual measures approved by the UAE Data Office.
- India DPDP Act: Cross-border transfers comply with the provisions of Section 16 of the DPDP Act 2023 and any regulations issued by the Data Protection Board of India. Transfers to notified restricted countries are not made.
- CCPA: Data transferred to service providers is subject to contracts prohibiting further sale or use outside the scope of services.
You may request a copy of the relevant transfer safeguard by contacting alunika@alunikasystems.com.
8. Cookies and Tracking Technologies
8.1 What We Use
- Strictly Necessary Cookies: Essential for the website to function. Cannot be disabled.
- Analytics Cookies: Help us understand how visitors interact with our website (e.g. Google Analytics with anonymised IPs).
- Functional Cookies: Remember your preferences and settings.
- Marketing/Targeting Cookies: Currently not deployed. Will be subject to prior consent if introduced.
8.2 Your Cookie Choices
Under the EU ePrivacy Directive, UK PECR, and similar laws, you have the right to refuse non-essential cookies. You may manage your preferences through your browser settings or any cookie consent mechanism we deploy. Withdrawing consent does not affect the lawfulness of processing prior to withdrawal.
9. Your Data Subject Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data. To exercise any right, contact alunika@alunikasystems.com with proof of identity.
9.1 Rights Under EU/UK GDPR
- Right of Access (Art. 15): Obtain confirmation of and access to your personal data.
- Right to Rectification (Art. 16): Correct inaccurate or incomplete personal data.
- Right to Erasure (Art. 17): Request deletion of personal data in certain circumstances.
- Right to Restriction (Art. 18): Request restriction of processing in certain circumstances.
- Right to Data Portability (Art. 20): Receive your personal data in a structured, machine-readable format.
- Right to Object (Art. 21): Object to processing based on legitimate interests or for direct marketing purposes.
- Rights re Automated Decisions (Art. 22): Not to be subject to solely automated decisions with significant effects. We do not carry out such processing.
- Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time without detriment.
- Right to Lodge a Complaint: Lodge a complaint with your national supervisory authority (e.g. UK: ICO; Ireland: DPC; Germany: relevant Landesbehörde).
9.2 Rights Under UAE PDPL
UAE data subjects have rights to: access their personal data; correct inaccurate data; withdraw consent; object to processing; request deletion (subject to legal retention requirements); and lodge complaints with the UAE Data Office (ado.gov.ae).
9.3 Rights Under Indian DPDP Act 2023
Indian Data Principals have the right to: access information about personal data processed; correct and update personal data; nominate another person to exercise rights on death or incapacity; withdraw consent (without affecting lawfulness of prior processing); obtain information about third parties with whom data has been shared; and lodge complaints with the Data Protection Board of India.
Our Grievance Officer for India can be contacted at: alunika@alunikasystems.com. We will acknowledge complaints within 24 hours and resolve within 30 days.
9.4 Rights Under CCPA/CPRA (California Residents)
- Right to Know: Know what personal information is collected, used, shared, or sold.
- Right to Delete: Request deletion of personal information, subject to exceptions.
- Right to Correct: Request correction of inaccurate personal information.
- Right to Opt-Out of Sale/Sharing: We do not sell or share personal information for advertising purposes. No opt-out is therefore required.
- Right to Non-Discrimination: We will not discriminate against you for exercising your rights.
- Right to Limit Sensitive PI Use: Limit the use of sensitive personal information to necessary purposes.
To submit a CCPA request, contact alunika@alunikasystems.com. We will verify your identity and respond within 45 calendar days, with one 45-day extension where reasonably necessary.
10. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Key retention periods:
- Client & contract records: 7 years from the end of the contractual relationship (legal/tax retention obligations).
- Enquiry and lead data: 3 years from last contact, unless a business relationship develops.
- Career applications (unsuccessful): 12 months from notification of outcome, or as required by local employment law.
- Website analytics: 26 months (Google Analytics default with anonymisation).
- Legal claims: Duration of the claim plus applicable statutory limitation period.
After retention periods expire, personal data is securely deleted or anonymised.
11. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage. Measures include:
- TLS/HTTPS encryption for all data in transit;
- Encryption of data at rest within our cloud infrastructure;
- Role-based access controls and principle of least privilege;
- Regular security assessments and vulnerability management;
- Data processor due diligence and contractual security obligations.
In the event of a personal data breach that is likely to result in risk to your rights and freedoms, we will notify relevant supervisory authorities within 72 hours (GDPR) and affected individuals without undue delay, in accordance with applicable law.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in law, our data practices, or our business. We will post the updated policy on this page with a revised "Last Updated" date. Where changes are material, we will provide prominent notice. We encourage you to review this policy periodically. Continued use of the website after changes constitutes acceptance of the revised policy to the extent permitted by law.
13. Contact and Complaints
For any questions, concerns, or to exercise your rights under this Policy:
- Email (DPO / Grievance Officer): alunika@alunikasystems.com
- General enquiries: alunika@alunikasystems.com
- Postal: Data Protection Officer, G-6, Bypass Road, Langre ki Chowki, Water Works, Agra, Uttar Pradesh 282003, India
If you are not satisfied with our response, you have the right to lodge a complaint with the supervisory authority in your jurisdiction:
- EU: Your national Data Protection Authority (find yours at edpb.europa.eu)
- UK: Information Commissioner's Office (ICO) — ico.org.uk
- UAE: UAE Data Office — ado.gov.ae
- India: Data Protection Board of India (when established)
- USA (California): California Privacy Protection Agency (CPPA) — cppa.ca.gov

