Privacy Policy – Kabluchka Jewellery
Version dated 18 July 2026. Drawn up in accordance with the Law of Ukraine "On Personal Data Protection" No. 2297-VI. This English text is provided for convenience; in case of any discrepancy, the Ukrainian version prevails.
1. Who Processes Your Data
The personal data controller is Sole Proprietor (FOP) Ostap Zapiatko (RNOKPP 3520002814), contact address: 17 Mazepy St., Drohobych, Lviv region, 82100, Ukraine; the Kabluchka website (www.kabluchka.com).
Personal data enquiries: info@kabluchka.com, +380 63 929 11 16.
2. What Data We Collect
- Order data: full name, phone number, e-mail, city and delivery address / carrier branch; for international delivery — the data required for customs clearance.
- Account data (if you create an account): login, order history, Kabluchka Rewards loyalty points.
- We do not receive or store payment card data — payments are processed by the payment service on its secure side (PCI DSS). We only see the payment status.
- Technical data: IP address, device and browser type, cookies, page-view data (Section 7).
- Communications: enquiries by e-mail, messengers and phone; product reviews.
We collect only the data necessary for the purposes in Section 3 (Art. 6 of Law No. 2297-VI; part 5, Art. 7 of the Law of Ukraine "On Electronic Commerce").
3. Purposes and Legal Bases of Processing
| Purpose | Legal basis (Art. 11 of Law No. 2297-VI) |
|---|---|
| Placing, paying for and delivering an order; order-related communication | Conclusion and performance of a contract (sale and purchase agreement) |
| Issuing a fiscal receipt, tax accounting | Compliance with a legal obligation (Law No. 265/95-ВР, Tax Code) |
| Warranty service, handling returns and claims | Performance of a contract; obligations under the Consumer Rights Protection Law |
| Kabluchka Rewards loyalty programme, publication of reviews | Performance of a contract; the data subject's consent |
| Marketing communications (new arrivals, promotions) | Only your separate consent — which you may withdraw at any time |
| Website analytics, security | Legitimate interest of the controller |
4. Who We Share Data With
Data is shared with third parties strictly to the extent necessary for the relevant purpose:
- Shopify — the online store platform and hosting; data is stored on Shopify infrastructure (EU/US) with appropriate safeguards (Art. 29 of Law No. 2297-VI);
- carriers (Nova Poshta / Nova Post, Ukrposhta) — name, phone number, address/branch — for delivery;
- the payment service and banks (including partner banks for instalment plans) — to process payments; lending decisions are made by the bank as an independent data controller;
- the fiscalisation operator / State Tax Service — the data included in the fiscal receipt, as required by law;
- Judge.me — the product review service (reviewer name and review text, e-mail for purchase verification);
- Smile.io — the technical platform of the Kabluchka Rewards loyalty programme (e-mail, points, accrual history);
- process automation services, including AI tools, engaged in order processing and communications — strictly within the processing purposes, with no right to use the data for their own purposes;
- public authorities — solely on the grounds and in the manner prescribed by law.
Data is not sold or otherwise transferred to anyone else.
5. Retention Periods
- Order data and settlement documents — at least 1,095 days (3 years) — tax law requirements.
- Account data — until the account is deleted at your request.
- Marketing data — until consent is withdrawn.
- Technical logs — up to 12 months.
After these periods expire, data is deleted or anonymised.
6. Your Rights (Art. 8 of Law No. 2297-VI)
You have the right to: know what data of yours we process and obtain a copy of it (response within 30 calendar days); request rectification or erasure of your data; object to processing; withdraw your consent to marketing (the "unsubscribe" link in every e-mail, or a request to info@kabluchka.com); and lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or a court.
Send requests to info@kabluchka.com with the subject line "Personal data".
7. Cookies
7.1. The Website uses cookies: essential (cart, session, security — the site does not work without them), analytical (Shopify built-in analytics), and widget cookies of Judge.me (reviews) and Smile.io (Kabluchka Rewards).
7.2. You can restrict or delete cookies in your browser settings. Disabling essential cookies may break the cart and checkout.
8. Data Security
Access to data is limited to persons who need it to perform their duties. We use HTTPS encryption, access restrictions, software updates and platform-level backups. In the event of a data breach posing a risk to your rights, we will notify you and take measures to minimise the consequences.
9. Children
The Website is not intended for persons under 18; we do not knowingly collect children's data.
10. Changes to This Policy
Updates are published on this page with the version date. Material changes affecting your rights are additionally announced on the Website.