Personal Data Privacy Policy

This Personal Data Privacy Policy (hereinafter referred to as the “Privacy Policy”) shall apply to all information that the User may provide to Qwintry in relation to the use of the Website and the Service.

1. Definitions

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

1.1.1. Qwintry – Qwintry LLC, a legal entity established under the US legislation and operating under the US laws, that administers the Website, arranges and processes personal data, and defines the objectives of personal data processing, the composition of personal data to be processed, and the actions (operations) taken with respect to personal data.

1.1.2. Personal data – any information related to a directly or indirectly defined or definable individual (personal data subject).

1.1.3. Personal data processing – any action (operation) or a combination of actions (operations) performed using automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, specification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.1.4. Confidentiality of personal data – a mandatory requirement for the Operator or other person who has access to personal data to prevent the distribution without the consent of the personal data subject or other legal grounds.

1.1.5. Website – sites with identical contents hosted under the domain names and, as well as the subdomains thereof.

1.1.6. Subdomains – pages or a combination of pages located on third-level domains belonging to the Website.

1.1.7. Service – a combination of services, products, and software available on the Website.

1.1.8. User – an individual using the Service.

1.1.9. Cookies – a small piece of data sent by a web server and stored on a user's computer, which the web client or web browser sends to the web server with every HTTP request when attempting to open a page of the corresponding website.

1.1.10. IP-address – a unique network address of a host through which the User accesses the Website.

2. General Provisions

2.1. The personal data of the User will be processed in accordance with the applicable laws, including but not limited to the Federal laws of said country on Personal Data and the General Data Protection Regulation (GDPR) No. 2016/679 approved by the Regulation of the European Union.

2.2. Use of the Website by the User implies agreement with this Privacy Policy and the User's personal data processing terms.

2.3. In the event of a disagreement with the terms of the Privacy Policy, the User shall stop using the Website.

2.4. This Privacy Policy shall apply to the Website. The Website shall not control or be liable for third party websites that the User can visit using links available on the Website.

2.5. Qwintry shall not verify the validity of personal data provided by the User, unless otherwise specified by Qwintry.

3. Subject of the Private Policy

3.1. This Privacy Policy shall establish Qwintry’s obligations for non-disclosure and protection of personal data provided by the User during registering on the Website or order placement on the Website.

3.1.1. When registering on the Website, the User shall provide the following personal data: Last Name, First Name, Patronymic, date of birth, gender, delivery address for order, contact (mobile) phone number, e-mail address.

3.1.2. When placing an order , depending on the selected delivery method, the User shall provide the following personal data: Last Name, First Name, Patronymic, contact phone number, e-mail address, date of birth, gender, delivery address for order, passport data in text format and/or a passport photocopy.

3.1.3. Qwintry shall reserve the right to request other personal data from the User, including copies of the documents required to provide the Service to the User.

3.2. The Website shall protect Data that is automatically transmitted when visiting the following pages:

  • IP-address;
  • information from cookies;
  • browser information;
  • access time;
  • referrer (address of the previous page).

3.2.1. Disabling cookies may result in the inability to access website sections requiring authentication.

3.2.2. The Website shall collect statistical data of the IP-addresses of its visitors. This information is used to prevent, identify and resolve technical issues.

3.3. Any other personal information not listed above (browsing history, browsers or operating systems used, etc.) shall be subject to secure storage and non-distribution, except for cases stipulated in p. 5.4 of this Privacy Policy.

4. User’s Personal Data Collection Objectives

User’s personal data can be used by Qwintry in order to:

4.1. Create an account in order to use the Website and the Service.

4.2. Identify a User registered on the Website for his/her further authorization.

4.3. Provide the User with access to the personalized data of the Website.

4.4. Establish feedback with the User, including sending of notifications and requests associated with the use of the Website, processing of requests and applications from the User.

4.5. Define the User’s location to ensure security and prevent fraud.

4.6. Confirm the authenticity and completeness of personal data provided by the User.

4.7. Notify the User by e-mail, SMS, or in messengers.

4.8. Provide the User with efficient technical support in the event of issues related to the use of the Website.

4.9. Provide special offers, newsletters and other information to the User with his/her consent on behalf of the Website.

5. Methods and Terms of Personal Data Processing

5.1. Providing their personal data, the Website Visitor / User agrees to their collection, storage, and processing, as well as to the transfer of such data to third parties, if this is caused by the need to provide the services mentioned in this Public Offer.
The Website Visitor / User also agrees to the use of their personal data in order to enable the Service to fulfill its obligations before them, for conducting electronic surveys, managing the results of marketing campaigns, providing customer support, organizing the delivery of the order(s), conducting prize draws among the Website Visitors / Users, surveying the satisfaction of Website Visitors / Users, as well as for monitoring the quality of the services provided.

5.2. Personal data processing shall imply any action (operation) or a combination of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, specification (updating, modification), extraction, use, transfer (including transfer to third parties, including cross-border transfer, if its necessity ises during the performance of obligations), depersonalization, blocking, deletion, destruction of personal data.

5.3. User’s personal data shall be processed with no time limitation, by any legal means, including processing in personal data information systems with or without the use of automation tools.

5.4. The user’s personal data can only be provided to the competent public authorities on the grounds and in the manner established by applicable legislation. Such provision of data shall not be considered as disclosure of personal data. 

The Website Visitor / User also agrees to the transfer of his personal data to third parties determined by Qwintry, including, but not limited to, sellers of goods, postal / courier services, and law enforcement agencies, whenever this is deemed necessary to conduct proceedings on the fact of possible illegal actions.

5.5. In case of a loss or disclosure of personal data, Qwintry shall mandatorily inform the User and the corresponding supervisory authorities thereof.

5.6. Qwintry shall take the necessary organizational and technical measures to protect User's personal data against unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as the undue influence of third parties.

5.7. Qwintry together with the User shall take all necessary measures to prevent damages or other negative consequences caused by the loss or disclosure of User's personal data.

6. Rights and Obligations of the Parties

6.1. The User has the right to:

6.1.1. Make an independent decision to provide his/her personal data required to use the Website and the Service, and give consent to their processing.

6.1.2. Receive information from Qwintry regarding processing of his/her personal data, if such right is not restricted in accordance with the federal laws.

6.1.3. Update, supplement the provided information on personal data if this information changes.

6.1.4. Withdraw his/her consent to processing of personal data by filling out a refusal form posted on the Website or sending a filled-out and signed form to

6.1.5. Request the removal or prohibit the use of his/her personal data if: Personal data has already been used for its intended purpose and is no longer required by Qwintry; The User has withdrawn his/her consent to personal data processing, and there are no legal barriers for their removal; Personal data was collected illegally.

6.2. Qwintry shall:

6.2.1. Use the received information solely for the purposes specified in p. 4 of this Privacy Policy.

6.2.2. Ensure that the confidential information is kept secret, not to disclose the information without prior written consent of the User, as well as not to sell, exchange, publish or otherwise disclose User’s personal data, except for p. 5.4 of this Privacy Policy.

6.2.3. Take precautions to protect confidentiality of User's personal data in accordance with the procedure normally used to protect such information in the existing business practice.

6.2.4. Block personal data related to the corresponding User from the moment of the application or request by the User or his/her legal representative, or an authorized body for protection of the rights of personal data subjects, for the verification period, if unreliable personal data or illegal actions are revealed.

6.3. Qwintry has the right to send information, including advertising messages to the User’s e-mail address and mobile phone, with his/her consent expressed through his/her actions, uniquely identifying this subscriber and allowing to reliably determine his/her willingness to receive the messages. The User has the right to opt out of receiving advertising and other information without any reasons of explanation for refusal by sending a corresponding application to the Service e-mail address: Service messages informing the User about the order and its processing stages are sent automatically and cannot be rejected by the User.

6.4. Qwintry has the right to record telephone conversations with the User. In this case, Qwintry shall prevent the attempts of unauthorized access to information received during telephone conversations, and/or its transfer to third parties not directly related to the execution of Orders, in accordance with p. 4 art. 16 of the Federal Law “On Information, Information Technologies and the Protection of Information”.

7. Liabilities of the Parties

7.1. If Qwintry, fails to fulfill its obligations, it shall be liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation, with the exception of cases provided for in p. 5.4 and 7.2 of this Privacy Policy.

7.2. In case of a loss or disclosure of Confidential Information, Qwintry shall not be held liable, if this confidential information:

7.2.1. Became public property before its loss or disclosure.

7.2.2. Was obtained by Qwintry from a third party until it was received from the User.

7.2.3. Was disclosed with the consent of the User.

7.3. The User shall be fully responsible for compliance with the requirements of the legislation, including, but not limited to laws on advertising, protection of copyright and related rights, protection of trademarks and service marks, including full responsibility for the content and form of materials.

7.4. The User shall agree that the information provided on the Website may constitute an intellectual property asset, the rights to which are protected. The User may not amend, lease out, loan, sell, distribute or create derivative works on the basis of or with the use of such intellectual property assets, unless such actions have been expressly authorized in writing by the owner in accordance with the terms of a separate agreement.

7.5. Qwintry shall not be liable to the User for any loss or damage incurred by the User as a result of removal, malfunction or inability to preserve any Content or other communication data contained or transmitted through the Website.

7.6. Qwintry shall not be liable for any direct or indirect damages resulting from: the use or inability to use the Website or the Service; unauthorized access to the User's communications; statements or actions of any third parties.

7.7. Qwintry shall not be held responsible for any information posted on the Website by the User, including but not limited to information protected by copyright, without express consent of the copyright owner.

8. Dispute Resolution

8.1. Before applying to the court for a dispute arising from the relationship between the User and Qwintry, a claim (a written proposal or offer in electronic format concerning the voluntary resolution of the dispute) shall be mandatorily submitted.

8.2. The Claimee, within 30 (thirty) calendar days from the date of receipt of the claim, shall notify the claimant of the claim examination results in writing or in electronic format.

8.3. If the agreement is not reached, the dispute shall be referred to the court at the Сlaimant’s discretion.

8.4. Current legislation of the Russian Federation shall apply to this Privacy Policy and the relationship between the User and Qwintry.

9. Supplementary Conditions

9.1. A current version of the Privacy Policy is located on the Website: A new version of the Privacy Policy shall replace all previous revisions, and its introduction shall not require preliminary approval by the User.

9.2. The new Privacy Policy shall come into effect from the moment it is posted on the Website, unless otherwise specified in the new revision of the Privacy Policy.