Last updated 15 August 2026 · applies to cv.kuguk.net
This page describes my professional background. It sells nothing, collects no registrations, takes no bookings and has no login. This notice explains the little data that is processed when you open it, and what you can ask me to do about it.
Alexander Kuguk, acting as a natural person, is the controller for the purposes of Art. 4(7) GDPR:
Alex Kuguk
c/o EVA DAVA EOOD
ul. „Gen. Gurko“ 9, et. 1
8000 Burgas, Bulgaria
a@kuguk.net · full provider details in the
Impressum, German-language version in the
Datenschutzerklärung
There is no data protection officer; the volume and nature of processing here do not require one.
| Data | Purpose | Legal basis | Kept |
|---|---|---|---|
| Aggregate page views: page opened, referring link, country, device type, browser, load timings — counted without a cookie and without any identifier that would link one visit to the next | To know whether a link I sent in my own outreach was opened at all | Legitimate interest, Art. 6(1)(f) GDPR — knowing whether my own outreach reached anyone | Unaggregated for seven days at the analytics provider, aggregated thereafter for up to 12 months |
| Server request logs kept by the hosting provider, which can include an IP address | Delivering the page and defending against abuse | Legitimate interest, Art. 6(1)(f) GDPR | Short term, by the provider’s own retention policy |
| Anything you write to me by email or messenger | Answering you | Art. 6(1)(b) and (f) GDPR | Until the matter is closed, then deleted on request |
This site sets no cookies. No advertising pixel, no tracking pixel in email, no cross-site identifier, no profiling, no automated decision-making.
Visits are counted with Cloudflare Web Analytics, which works without a cookie and without a persistent identifier — it cannot tell that two page views came from the same person, and neither can I. Because nothing is stored on or read from your device beyond what is needed to deliver the page, no consent banner is shown. According to Cloudflare, your IP address is read only to derive the country, is not used to recognise you, and is not stored for the counting.
Nothing is sold, rented, or handed to advertisers.
This page links to evadava.com, the site of EVA DAVA EOOD. The link on its own transmits nothing. If you follow it, that site's own privacy notice applies. Booking a call happens there and only there — this site takes no appointments.
Under the GDPR you may ask for access to your data, correction, erasure, restriction of processing, portability, and you may object to processing based on legitimate interest. Write to a@kuguk.net and I will answer within one month.
In practice, aggregate analytics contains no identifier that lets me find "your" data — so a request will most often be answered by confirming exactly that. Email correspondence is a different matter and can be deleted on request.
You also have the right to complain to a supervisory authority in the EU or EEA country where you live or work.
What this site does is described above, and it does the same thing wherever you are reading from. What changes country to country is the name of the law, the name of your rights, and the address you write to if I get it wrong. That is what this section is for. Where a law does not bind me, I say so plainly and then honour the substance of it anyway. A profile page is a thin thing to hide behind.
One address answers all of it: a@kuguk.net. I reply within a month, usually the same week.
The GDPR applies in full. Your rights are the ones listed under “Your rights” above. You may complain to the supervisory authority where you live or work. In Ireland that is the Data Protection Commission, dataprotection.ie.
The UK GDPR and the Data Protection Act 2018 apply, and the rights are the same. Complaints go to the Information Commissioner’s Office, ico.org.uk. Measurement on this site falls under regulation 6 of PECR, which since 5 February 2026 carries a statutory exception for collecting usage statistics, provided you are told what is collected and given a free and simple way to object. Both are here: the description above, and the button under “Opting out of measurement”.
Most state privacy laws set thresholds I come nowhere near: California’s CCPA as amended by the CPRA, and the comparable acts in Virginia, Colorado, Connecticut and Utah. Texas and Nebraska work differently: they set no revenue or volume threshold and instead exempt anyone who is a small business under the definition used by the U.S. Small Business Administration, which I am. Either way they do not bind me. There is no annual revenue of twenty-five million dollars as adjusted for inflation, no hundred thousand consumers, no revenue from selling data because there is no selling of data. So they do not bind me. The substance is below anyway.
The categories collected, in CCPA terms: internet or network activity, in aggregate and with no identifier, plus whatever identifiers you hand me yourself if you write to me. Nothing is inferred, nothing is profiled. I have never sold or shared personal information and have no plans to. That is why you will find no “Do Not Sell or Share My Personal Information” link: there is nothing behind it to switch off. I offer no financial incentives tied to data. You may ask what I hold, ask for it back, ask for it corrected, or ask for it deleted, and nothing about how I treat you changes because you asked.
PIPEDA binds organisations that handle personal information in the course of commercial activity. Whether a CV page clears that bar is arguable, and I do not lean on the argument either way: ask what I hold about you and ask for it corrected, and the answer is the same. If it does not satisfy you, the Office of the Privacy Commissioner of Canada takes complaints at priv.gc.ca. In Quebec the equivalent regulator is the Commission d’accès à l’information.
The Privacy Act 1988 and the Australian Privacy Principles exempt small operators, meaning an annual turnover of three million Australian dollars or less, and I sit well under that. So the rights below come from me rather than from the statute: ask what I hold, ask for corrections, object. If you want to take it further, the regulator is the Office of the Australian Information Commissioner, oaic.gov.au.
The Privacy Act 2020 has no small-business exemption, so it applies to me the same as to anyone else. The information privacy principles govern what I do here, you may ask for access and correction under principles 6 and 7, and the Office of the Privacy Commissioner at privacy.org.nz will hear a complaint.
The APPI applies to every business handling personal information, with no minimum size, and its reach extends to anyone offering goods or services to people in Japan, so I treat it as applying here. The purpose of use is published above rather than buried: to deliver the page, to know whether a link I sent was opened, and to answer you if you write. Email me to request disclosure, correction or suspension of use. The supervisory body is the Personal Information Protection Commission at ppc.go.jp.
PIPA applies. The items, the purpose and the retention period are set out above: for correspondence, your email address and whatever you choose to write, kept until the matter is closed. Measurement collects no item that identifies you. You may ask for access, correction, deletion or suspension of processing at any time, and where processing rests on consent you may withdraw it without penalty. Complaints go to the Personal Information Protection Commission, pipc.go.kr. The privacy report centre run by KISA is the other route.
The button below switches the counting off for this browser and keeps it off: the measurement script is then not loaded at all on any page here. It costs nothing, needs no account, and the site works exactly the same afterwards. A browser setting or extension that blocks analytics scripts does the same job.
The CV describes roles by scope. Quota, compensation and revenue figures are withheld under confidentiality obligations to former employers. Company names and marks belong to their owners and appear for identification only. This page is not an offer, a solicitation, or a contractual document.
If this notice changes, the date at the top changes with it.
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