At Clochar, we are very attentive to the need for appropriate protection and responsible processing of all personal data that we receive and we give data security and confidentiality a high priority. This Privacy policy (in the following named “Policy”) contains a policy statement regarding our processing of personal data as described below and helps you to understand which personal data we collect, why we collect it, and how we use it.
This Policy only applies to the processing of your personal data by us when we have your consent to send you a newsletter or the processing of your personal data if you purchase product(s) from our Website.
Our processing of your personal data is governed by the EU General Data Protection Regulation (in the following “GDPR”) and national data protection legislation.

CLOCHAR LLC
Tbilisi, Samgori DIstrict
Police Lane I, N5
Georgia

Personal data we collect and process
Personal data is data that may – indirect or direct – refer to you, such as an address, name, email address, phone number etc.
When you subscribe to our newsletter:
If you have given us your consent to send you our newsletter, we will process your name and email address. You can at any time unsubscribe from the newsletter service to which you have subscribed either via the link at the bottom of the newsletter or by writing to our customer care.
The legal basis for such processing is your freely given consent, cf. GDPR article 6, 1, litra a (consent).
When you place an order:
When you place an order at our Website or contact our Customer care services, we will process the data you have supplied yourself to us, such as your name, address, e-mail address, telephone number, country and payment information. Such personal data is processed for the following purposes:
Legal Basis
GDPR article 6, 1, litra b (performance of a contract) With the purpose of:

• Fulfill your order
• Ship your order
• Provide Customer care services
• Handle returns and refunds

GDPR article 6, 1, litra c (legal obligations) With the purpose of:

• Comply with legal obligations such as bookkeeping and consumer purchase laws.

We only share personal data to the extent it is required for the purposes as described in this Policy.
If you have given your consent to subscribe to our newsletter, your name and e-mail address is transferred to Klaviyo, which is located in the USA. You have explicitly consented to the transfer after you have been informed of the possible risks of the transfer due to the absence of an adequacy decision and appropriate safeguards. You can read their privacy policy here: https://www.klaviyo.com/legal
If you have placed an order at our Website, we transfer your personal data to partners, who act as independent data controllers. This is applicable for the following situations:

• Shipping services; When your order is ready to ship, we share your name, address, email and phone number with our shipping partners to fulfill your delivery.
• Payment services; When you complete an order on our Website, your payment is handled by our payment solution partners.

Besides otherwise described in this Policy, we may disclose personal data that we collect or that you provide for purposes described in this Policy and under our responsibility, to trusted third-party providers (data processors), e.g. storage, hosting and other IT-services. We only use data processors that can give your information an adequate level of data protection.
In some cases, we may also transfer personal data to organizations in so-called third countries (countries outside of the European Economic Area). Such transfers can be made if any of the following conditions apply;

• the EU Commission has decided that there is an adequate level of protection in the country in question, or
• other appropriate safeguards have been taken, for example, the use of the standard contractual clauses (EU model-clauses) approved by the EU Commission or the data processor has valid Binding Corporate Rules (BCR) in place, or
• that there are exceptions in special situations, such as to fulfil a contract with you or your consent to the specific transfer.

We have established and will maintain adequate organizational and technical measures in order for your personal data not to be accidentally or illegally deleted, deteriorated or lost, disclosed to unauthorized third parties or in any other way misused or used contrary to the data protection legislation.
In the event of a security breach where we estimate that there is a high risk that your personal data may be misused, we will, without undue delay, notify you of such a security breach. We will also inform you about what we have done to minimize the risk of misuse of your data.

We delete your personal data when we no longer need to process it in order to fulfill one or more of the purposes as stated above or to comply with specific legislative requirements.
Your consent for signing up for our newsletter will be retained for as long as we send you newsletters and up to two years after the last email has been sent.
If you have placed an order with us at our Website, your personal data will be deleted no later than 5 years after the end of the financial year in which your last transaction was made, unless we are obliged to a longer retention period to comply with legal requirements.

According to the GDPR you have the right to:

• Access the personal data about you that we collect and use. You have the right to obtain a copy of your data free of charge. However, we may charge a fee corresponding to administrative costs if further copies of the data are requested, or if the request is unfounded or excessive.
• Ask for rectification of incorrect or inaccurate data concerning you, or to have incomplete personal data completed.
• Ask that your personal data be erased.
• Ask for the restriction of the processing of your data (under certain circumstances).
• Port your data.
• Object to the processing of your personal data for marketing purposes.

Cookies, pixels and other system technologies
Our Website collects information by using technology such as cookies, pixels and tags (on your browser or device). For information about how we use this type of technologies, please see our Cookie Policy.
Questions or concerns
You are free to email us directly at info@clochar.ru with any questions or suggestions. We will do our best to reply to your questions and resolve your concerns.
If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

At CLOCHAR, we take data security and confidentiality seriously. This means we ensure appropriate protection and responsible processing of all personal information that we receive. We assure full confidentiality when handling and storing your personal data submitted on this site. Please feel free to adjust your cookie preferences below.

• Strictly necessary cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

• Cookie name: TildaConsent
• Description: This cookie is set by the cookie compliance solution from TildaTrust. It stores information about the categories of cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent cookies in each category from being set in the users browser, when consent is not given. The cookie has a normal lifespan of one year, so that returning visitors to the site will have their preferences remembered. It contains no information that can identify the site visitor.
• Cookie name: TildaAlertBox
• Description: This cookie is set by websites using certain versions of the cookie law compliance solution from TildaTrust. It is set after visitors have seen a cookie information notice and in some cases only when they actively close the notice down. It enables the website not to show the message more than once to a user. The cookie has a one year lifespan and contains no personal information.
• Performance cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect are aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

• Cookie name: _gid
• Description: This cookie name is associated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for each page visited.
• Cookie name: _ga
• Description: This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customizable by website owners.
• Cookie name: _uetvid
• Description: This is a cookie utilized by Microsoft Bing Ads and is a tracking cookie. It allows us to engage with a user that has previously visited our website.
• Cookie name: _gclxxxx
• Description: Google conversion tracking cookie
• Functional cookies

These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

• Cookie name: __tld__
• Description: From Segment Analytics.js library; this cookie helps to figure out a top-level domain for a user.
• Cookie name: _pin_unauth
• Description: This cookie is associate with pinterest. It is used to track the usage of services.
• Cookie name: __stripe_sid
• Description: Stripe is used to making credit card payments. Stripe uses a cookie to remember who you are and to enable the website to process payments without storing any credit card information on its own servers.
• Cookie name: ajs_anonymous_id
• Description: These cookies are generally used for Analytics and help count how many people visit a certain site by tracking if you have visited before. This cookie has a lifespan of 1 year.
• Cookie name: __stripe_mid
• Description: Stripe is used to making credit card payments. Stripe uses a cookie to remember who you are and to enable the website to process payments without storing any credit card information on its own servers.
• Cookie name: ajs%3Atest
• Description: This performance cookie counts visits and tracks other website traffic-related metrics. Cookies in this domain have lifespan of 1 year.
• Cookie name: __zlcmid
• Description: Live chat widget sets the cookies to store the Zopim Live Chat ID used to identify a device across visits.
• Cookie name: ajs%3Acookies
• Description: This cookie supports use, service performance, and functionality of websites. Cookies in this domain have lifespan of 1 year.
• Cookie name: __zlcid
• Description: This domain is owned by Zendesk. This particular domain for the company ensures that all Zendesk features and functionality are added to the site correctly.
• Targeting cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

• Cookie name: _uetsid
• Description: This cookie is used by Bing to determine what ads should be shown that may be relevant to the end user perusing the site.
• Cookie name: ajs_user_id
• Description: This cookie helps track visitor usage, events, target marketing, and can also measure application performance and stability. Cookies in this domain have lifespan of 1 year.
• Cookie name: _fbp
• Description: Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
• Cookie name: ajs_group_id
• Description: These cookies track visitor usage and events within the website. Cookies in this domain have lifespan of 1 year.
• Cookie name: SRM_B
• Description: This domain is owned by Microsoft - it is the site for the search engine Bing.
• Cookie name: MUID
• Description: This domain is owned by Microsoft - it is the site for the search engine Bing.
• Cookie name: _routing_id
• Description: This domain is owned by Pinterest. The main business activity is: Social Content Sharing platform.

Personal information is collected and used for the following purposes:

• Fullfilment of an order in our web-shop
• Subscribing to a newsletter
• Transmission of other marketing material, including invitations to events and the allocation of value codes
• Summary of purchase history
• Statistics and analysis of traffic on www.clochar.com
• Other marketing measures

We would like to point out that the use of your personal information for the sending of marketing material will only take place if you have previously submitted your explicit consent, unless the Act provides for the possibility of that we can contact you without you having given us your consent first. CLOCHAR maintains statistics about which areas of the website our users visit and what products are users’ favourites. These data does not contain personal information. The collected data gives us knowledge about how users use the website. This information is used to improve the website. We cannot see where you are visiting from or where you browse on the Internet when you leave our site. We do not sell or in any other way disclose information about our users’ use and navigation of our website and we neither sell nor distribute information about your purchases to a third party.

Your personal information will not be disclosed to a third party without your permission. However, under certain circumstances and in accordance with legislation, we may be required by law to disclose information to public authorities or the police. For example, we are required to disclose information to the police in cases of suspected credit card fraud.

like access to the personal information that is processed about you, or if you have inquiries about the above guidelines, please contact us at info@clochar.ru. You can also write to us at the following address:
CLOCHAR LLC
Tbilisi, Samgori DIstrict
Police Lane I, N5
Georgia