Privacy Policy

This Data Privacy Policy (hereinafter – the Privacy Policy) applies to all Personal Data that the Website, where this Privacy Policy is posted, may collect from its Users, and to all software and products embedded into the Website.


1.1. The following terms are used in this Privacy Policy:

1.1.1. Website – a web resource owned by LLC Cashmere Capital and available at

1.1.2. Website Administration – the employees of LLC Cashmere Capital, authorized to manage the Website on behalf of LLC Cashmere Capital, who organize and/or process Personal Data and determine the purposes of processing Personal Data, the scope of Personal Data to be processed, actions (operations) performed in respect of Personal Data.

1.1.3. Personal Data – any information directly or indirectly relating to an identified or an identifiable individual (Subject of Personal Data).

1.1.4. Processing of Personal Data – any action (operation) or a combination of actions (operations) performed in respect of Personal Data, with or without automation tools, including, but not limited to, collection, recording, systematization, accumulation, storage, specification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, destruction of Personal Data.

1.1.5. Non-Disclosure of Personal Data – is a mandatory requirement for the Website Administration to prevent intentional disclosure of Personal Data, except where there is a proper consent of the Subject of Personal Data or other valid legal grounds for such disclosure.

1.1.6. Website User (hereinafter – the User) – a person accessing the Website via the Internet and using the Website for his/her own purposes.

1.1.7. Cookies – a small piece of data sent by the web server and stored on the User’s computer, which the web client or the web browser sends to the web server in an HTP request whenever the User tries to open a web page of the Website.

1.1.8. IP address – is a unique network address assigned to each node connected to a computer network that uses the IP protocol.


2.1. By using the Website, the User acknowledges that he/she accepts this Privacy Policy and the terms of processing of his/her Personal Data.

2.2. If the User does not accept this Privacy Policy, he/she must stop using the Website immediately.

2.3. This Privacy Policy applies to the Website only. The Website Administration does not control and shall not be responsible for any third-party websites that the User may access by clicking the links available on the Website.

2.4. The Website Administration shall not be responsible to verify the accuracy of the Personal Data provided by the User.


3.1. This Privacy Policy establishes the Website Administration’s commitment to ensuring non-disclosure of the Personal Data that the User may provide in response to various requests from the Website Administration (e.g. for the purposes of registration on the Website, placing orders, subscribing to notifications, etc.).

3.2. The Personal Data to be processed under this Privacy Policy shall be provided by the User by way of filling out special online forms available on the Website and shall generally include the following information about the User:

3.2.1. name, surname, and patronymic;

3.2.2. contact telephone number;

3.2.3. e-mail;

3.2.4. residential address and other data.

3.3. The Website Administration shall also take efforts to protect the Personal Data collected automatically whenever the User visits the Website pages, including, but not limited to:

– IP address;

– information stored in cookies;

– information about the browser (or any other program used to access the Website);

– session duration;

– URLs of the web pages viewed;

– URL of the referring page, etc.

3.3.1. Disabling Cookies may entail the inability to access the Website.

3.3.2. The Website collects statistics about the IP addresses of its visitors. This information is used to identify and solve technical problems, to verify the correctness of the operations performed.

3.4. Any other personal information not specified above (view history, types of browsers and operating systems used, etc.) shall not be deliberately disclosed, except as provided for by clauses 5.2. and 5.3. hereof.


4.1. The Website Administration may use the User’s Personal Data for the following purposes:

4.1.1. identify a registered User to fill out an order form and/or conclude a Contract;

4.1.2. provide the User with access to personalized resources on the Website;

4.1.3. establish feedback communication with the User, including by way of sending notifications, requests relating to the use of the Website, providing services, processing the User’s requests and applications;

4.1.4. determine the User’s location to ensure security and prevent fraud;

4.1.5. verify the correctness and completeness of the Personal Data provided by the User;
4.1.6. create a customer account for making purchases (where applicable) subject to the User’s consent to the creation of such account;

4.1.7. notify the User on the progress of his/her orders (where applicable);

4.1.8. provide the User with effective customer and technical support in case of any problems with the Website;

4.1.9. provide the User with information about product updates, special offers, pricing information, newsletters and other information on behalf of the Website or the Website’s partners, subject to the User’s consent;

4.1.10. implement advertising activities, subject to the User’s consent;

4.1.11. provide the User with access to third-party websites or services of the Website’s partners to receive their offers, updates or services.


5.1. The User’s Personal Data shall be processed for an unlimited term in any legal manner, including, but not limited to, in personal data information systems, with or without automation tools.

5.2. The User agrees that the Website Administration has the right to transfer Personal Data to third parties, particularly, courier services, postal organizations, telecommunication operators, solely for the purpose of fulfilling the User’s orders placed via the Website.

5.3. The User’s Personal Data may be transferred to the competent state authorities only on the grounds and in the manner established by the applicable laws.


6.1. The User shall:

6.1.1. provide correct and accurate Personal Data as may be required to use the Website;

6.1.2. update or supplement the Personal Data provided, in case of any changes to the User’s personal details;

6.1.3. take measures to protect the access to the User’s sensitive information stored on the Website.

6.2. The Website Administration shall:

6.2.1. use the data received, solely for the purposes specified in Article 4 hereof;

6.2.2. not disclose the User’s Personal Data, except as provided for by paragraphs 5.2. and 5.3. hereof;

6.2.3. block Personal Data related to a specific User upon receipt of the request or communication from such User, or his/her legal representative, or the competent authority responsible for the protection of rights of Subjects of Personal Data, for the duration of the audit resulting from the identification of false Personal Data or illegal actions.


7.1. For any intentional disclosure of the User’s Personal Data, except as provided for by paragraphs 5.2., 5.3., and 5.7. hereof, the Website Administration shall be held liable in accordance with the applicable laws.

7.2. The Website Administration shall not be held liable for any loss or disclosure of Personal Data that:

7.2.1. became generally known to the public prior to such loss or disclosure;

7.2.2. were disclosed to the Website Administration by a third party prior to being provided by the User;

7.2.3. were obtained by third parties through unauthorized access to the Website files;

7.2.4. were disclosed with the consent of the User.

7.3. The User shall be held liable for the validity, correctness, and accuracy of the Personal Data provided, in accordance with the applicable laws.


8.1. For any disputes arising between the User and the Website Administration, a letter before action (a written proposal for amicable settlement of a dispute) shall be mandatory.

8.2. Within 30 calendar days upon receipt of a letter of claim, the recipient shall notify the claimant in writing about the results of the examination of such claim.

8.3. If the parties fail to agree, the dispute shall be referred to the competent judicial authority in accordance with the applicable laws.

8.4. This Privacy Policy and the relationship between the User and the Website Administration shall be governed by the applicable laws.


9.1. The Website Administration has the right to revise this Privacy Policy without the User’s consent.

9.2. Unless otherwise provided for by the new revision of the Privacy Policy, a revised Privacy Policy shall become effective from the moment it is posted on the Website.