Гоша Рубчинский

PRIVACY POLICY

LAST UPDATED: FEBRUARY 7, 2025

This Privacy Policy describes how Gosha Rubchinskiy ("we", "us", or "our") and our subsidiaries and affiliates collect, use, maintain, protect and disclose your personal data we may collect from you or that you may provide when you visit, use our services, or make a purchase from gosharubchinskiy.com (the "Site") or otherwise communicate with us regarding the Site (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy. This notice applies to the personal data collected through our Site, regardless of the country where you are located. The Site may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit or service you enable.

Please read this Privacy Policy carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Site, you accept and consent to the practices described in this Privacy Policy.

1. Changes to This Privacy Policy
2. How We May Collect and Use Your Personal Information
3. What Personal Information We May Collect
4. Information We May Collect Directly from You
5. Information We Collect about Your Usage
6. Information We Obtain from Third Parties
7. How We Use Your Personal Information
8. Request To Know/ To Correct / To Restrict / To Delete
9. Cookies
10. Third-Party Use of Cookies
11. How We Disclose Personal Information
12. Third Party Websites and Links
13. Data Security
14. Children’s Data
15. Security and Retention of Your Information
16. Your Rights
17. Complaints
18. International Users
19. How Can You Contact Us?

Appendix A - Jurisdiction Specific Rights

1. Changes to This Privacy Policy
We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law. Your continued engagement with our Site after any such revisions indicates that you accept and consent to them, so please check the Privacy Policy periodically for updates.

2. How We May Collect and Use Your Personal Information
To provide the Services, we collect and have collected over the past 12 months personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.
In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

3. What Personal Information We May Collect
The types of personal information we may obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

4. Information We May Collect Directly from You
Information that you directly submit to us through our Services may include:
Contact details including your name, address, phone number and email and any other identifier we may use to contact you online or offline.
Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.
Account information including your username, password, security questions and other information used for account security purposes.
Shopping information including the items you view, put in your cart, saved into your account like loyalty points, reviews, referrals or gift cards, or purchases.
Loyalty points/product reviews/referrals/gift cards saved
Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.
· Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Site feature.
· Technical information, including the full/partial Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
· Non-personal details about your Site interactions, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Site (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.
· User contributions. You also may provide information for us to publish or display ("post") on public Site areas or transmit to other Site users or third parties (collectively, "User Contributions"). You submit User Contributions for posting and transmission to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any Site users with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.
If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

5. Information We Collect about Your Usage
We may also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.
You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Site may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

6. Our Site pages and emails may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Site content popularity or verifying system and server integrity.Information We Obtain from Third Parties
Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:
Companies who support our Site and Services, such as Shopify.
Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.
Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

7. How We Use Your Personal Information
We use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:
Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and other features and functionalities related to your account. We may also enhance your shopping experience by enabling Shopify to match your account with other Shopify services that you may choose to use. In this case, Shopify will process your information as set forth in its Privacy Policy and Consumer Privacy Policy.
Marketing and Advertising. We may use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites.
Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services. T
We may also use personal data to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your data in this way, please adjust your user preferences in your account profile.
We may use personal data to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We may use non-personal data for any business purpose.

8. Request To Know/ To Correct / To Restrict / To Delete
Make sure you submit your request to know/ to correct / to restrict or to delete through one of our designated methods specified in the “Contact” section below. If our designated method of submitting request is not working, notify us in writing and consider submitting your request through another designated method if possible.
We must respond to your request within 45 calendar days. We can extend that deadline by another 45 days (90 days total) if we notify you of it. If you submitted a request and have not received any response within the timeline, check this Privacy Policy to make sure you submitted your request through the designated way.
We must verify that the person making a request is the user about whom we have personal information. We may need to ask you for additional information for verification purposes. If we ask for personal information to verify your identity, we can only use that information for this verification purpose.
If you do not know why we denied your request, follow up with us to ask us for our reasons. If you submit a request to our service provider instead of us, our service provider may deny the request. You must submit your request to us.

9. Cookies
We use cookies to personalise content and ads, to provide social media features and to analyse our traffic data. We also share information on your use of our site with our social media, advertising and analytics partners.. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.
Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.
Please note that while your browser may allow you to transmit a “do not track” signal, like many websites, our Site is not designed to respond to such signals.

10. Third-Party Use of Cookies
Some content or applications, including advertisements, on the Site are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

11. How We Disclose Personal Information
In certain circumstances, we may disclose your personal data to third parties for contract fulfillment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:
With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).
With business and marketing partners to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.
With any members of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates..
In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
· To comply with any court order, law, or legal process, including responding to any government or regulatory request.
· To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
· Audit, law firms and similar corporate professional service providers, data analysis providers. These partners enable us to better understand and conduct our business (they include accountants, lawyers and auditors who may need to use your personal information). In addition, data analysis providers may enable us to provide you with relevant information, updates and marketing content (e.g. by analysing your answers to a survey, providing insights and helping us to analyse trends and improve our products and services).
To fulfil the purpose for which you provide it.
· For any other purposes that we disclose in writing when you provide the data.
· With your consent.
We have in the past 12 months disclosed the following categories of personal information and sensitive personal information about users for the purposes set out above in "How we Collect and Use your Personal Information" and "How we Disclose Personal Information":
Category
Categories of Recipients
Identifiers such as basic contact details and certain order and account information
Personal information categories listed in the California Customer Records statute such as basic contact details and certain order and account information
Commercial information such as order information, shopping information and customer support information
Internet or other similar network activity, such as Usage Data
Geolocation data such as locations determined by an IP address or other technical measures
Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners and data analytics providers)
Business and marketing partners
Affiliates

12. Third Party Websites and Links
Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

13. Data Security
The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of the Site like message boards, which any Site visitor can view.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Site. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Site.

14. Children's Data
We do not direct our Site to minors and we do not knowingly collect personal data from children or as defined by local legal requirementsIf you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it

15. Security and Retention of Your Information
Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.
How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

16. Your Rights
Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.
Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information. Such right of access also includes the right to receive information in particular about the purposes of the processing, the categories of personal information concerned, the categories of recipients to whom your information may be disclosed, and the envisaged period for the retention of your information.
Right to Delete: You may have a right to request that we delete personal information we maintain about you.
Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.
Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
Right to object. The right to object to the processing of personal information for the performance of a task carried out in the public interest or in the exercise of official authority, or for protection of our legitimate interests.
Right to Opt out of Sale or Sharing or Targeted Advertising: You may have a right to direct us not to "sell" or "share" your personal information or to opt out of the processing of your personal information for purposes considered to be "targeted advertising", as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the "sale" or "sharing" of information for the device and browser that you use to visit the Site.
Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information. In this case, we must stop using your personal information for that purpose unless we can either demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms or where we need to process the personal information in order to establish, exercise or defend legal claims. Where we rely on legitimate interest as a justification for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial. You also have the right to lodge a complaint with your local supervisory authority if you consider that the processing of your personal information infringes applicable law.
Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.
Deceased person rights to privacy. To exercise rights on behalf of a deceased individual, you may be required to provide us with proof that you are an immediate family member or executor of the deceased person. Subject to applicable privacy laws, we may not be able to support your request. Please be informed that under certain laws, you can define directives relating to the storage, erasure and communication of your personal information after your death.
You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.
We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.
You may also send us an email at info@gosharubchinskiy.com to request access to, correct, or delete personal data that you have provided to us. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information's accuracy.
If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages or because other Site users may have copied or stored them.

17. Complaints
If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority. For the EEA, you can find a list of the responsible data protection supervisory authorities here.

18. International Users
We operate globally and may transfer your personal information to other companies within our group or to approved partners in locations around the world. We want you to have the best service and customer experience, whether online or in person all over the world. For this purpose, we may have to share your personal information outside the country where you have first shared it with us. When we do so, it will always be for the purposes described in this Privacy Policy and where we are satisfied with the levels of protection and security implemented in compliance with applicable privacy legislation. This sharing of your personal information is necessary to enable us to perform the contracts we have with you or take steps at your request, prior to entering into a contract, in order to offer you a global customer experience.
In most cases, the personal information we collect from you will be stored in servers located in TBC. However, this may vary depending on the country in which the information is collected or applicable legislation. For more information about the location where your personal information is stored, you can contact us at info@gosharubchinskiy.com (or see How can you contact us?)
When we share, use, or transfer personal information outside the country in which the information is collected, we will put in place appropriate measures to legitimize such transfer under applicable privacy legislation, which may include, as applicable, obtaining your consent or implementing adequate contractual safeguards. In particular, if we transfer your personal information from the European Union or Switzerland to a country for which no adequation decision has been adopted by the relevant authorities, we use standard contractual clauses approved by the relevant authorities (such as European Commission).

19. How Can You Contact Us?
Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please call or email us at info@gosharubchinskiy.com or contact us at IFZA Business Park, premises number 33899-001 DSO-IFZA, Dubai, United Arab Emirates.
For the purpose of applicable data protection laws and if not explicitly stated otherwise, we are the data controller of your personal information.
We will post any changes we may make to our Privacy Policy on this page and indicate on the Site that we updated our Privacy Policy. If the changes materially alter how we use or treat your personal data we will notify you by email to the primary email address specified in your account and/or through a notice on the Site. Please check back frequently to see any updates or changes to our Privacy Policy.

You may also make a complaint to your local data protection authority.
All materials © 2025 Gosha Rubchinskiy, unless otherwise noted. All rights reserved.

Appendix A - Jurisdiction Specific Rights
CALIFORNIA RESIDENTS: Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights regarding our collection, use, and sharing of their Personal Information. We do not sell your Personal Information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your Personal Information. We collect various categories of Personal Information when you use the Site, including Cookies, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information.
You have the right to know what Personal Information has been collected about you, to access that information, and to rectify your Personal Information (correct, update or modify). You also have the right to request deletion of your Personal Information, though exceptions under the CCPA may allow us to retain and use certain Personal Information notwithstanding your deletion request. You can learn more about how to submit a data rights request by contacting us by methods listed below in the “Contact Us” section. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.
We generally do not collect sensitive personal data, which is data such as your social security, driver’s license, state identification card, or passport number; religious or philosophical beliefs, racial or ethnic origin, health or medical information (other than for the purpose of processing your order or request), genetic or biometric data, bank account , debit card, or credit card number in combination with any required security or access code information (other than for the purpose of processing your order) or other similar sensitive personal data as such term is defined under applicable law. If we reasonably need to collect any sensitive personal data from you, we will obtain your consent for the collection of such personal data as may be required under applicable law.
Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what Personal Information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your Personal Information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us by methods listed below in the “Contact Us” section.

NEVADA RESIDENTS: Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell your Personal Information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us at the email address listed below in the “Contact Us” section.

GDPR Compliance. We make good faith efforts to comply with the European Union General Data Protection Regulation ("GDPR"). We fully protect your personal data from misuse in accordance with applicable law, in particular while respecting the principles and rules set out in the Regulation (EU) 2016/679 of the European Parliament and of the Council, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). We process the personal data on the basis of the compliance with a legal obligation, performance of a contract, legitimate interests of the controller, and on the basis of consent of the data subject. We are a controller of your personal data. This means that we collect, store and use (and otherwise process) your personal data in pursuance of its business (the purposes for which data are processed are described in more detail herein), which consists primarily of the provision of our services, educational or social events.