Application Review and Privacy Rules of the Pukamuka Club
Version: 14 October 2026
Welcome to the Pukamuka private club.
These Rules explain how we receive and review applications, who administers access, what personal data is processed at this stage, how applicants’ confidentiality is protected and what submitting an application means.
We want you to understand these Rules before applying. They primarily concern club admission and do not replace the terms of individual paid services or sales of goods.
1. About the Pukamuka private club
1.1. Pukamuka is an international shopping platform operating as a private club with restricted access. Pukamuka is the platform and brand name, not a separate legal entity.
1.2. Access may be granted following individual review of an application, a personal invitation, a recommendation or a specific admission round.
1.3. The Club Administrator determines the club format, number of available places, application review process, eligible territories and invitation arrangements, subject to applicable law.
2. Club Administrator and parties to future orders
2.1. The administrator of the private club, its application process and membership access, and the sole Organiser of Pukamuka services, is PERSONAL BUYER LLC (Ukraine) (the “Administrator” and, in relation to orders, the “Organiser”). The Organiser coordinates the performance of orders and dealings with its appointed partners under the contracts applicable to each service.
2.2. Once admitted, a member may place orders for Pukamuka services. PERSONAL BUYER LLC remains the sole Organiser, responsible for organising and coordinating those orders. For Personal Buyer orders, goods are sold by the legal entities listed in the Pukamuka General Terms of Service. The specific Seller is identified before payment.
2.3. Admission to the club does not, by itself, create a contract for the sale of goods or a contract for a paid service with any of those entities.
2.4. The identity and required details of the company selling goods or independently supplying a particular paid service are provided before the relevant contract is concluded and any payment is made and, where applicable, appear in order confirmations and sales documents. The Organiser’s existing contractual obligations remain unaffected.
3. What submitting an application means
3.1. By submitting an application, an applicant asks Pukamuka to consider granting access to the private club.
3.2. Applications and their review are free of charge. Pukamuka does not charge for the application form, its review, inclusion on a waiting list or the decision itself.
3.3. Submitting an application:
3.3.1. does not automatically register the applicant or create an Account;
3.3.2. does not mean automatic admission to the club;
3.3.3. does not guarantee access to Pukamuka services;
3.3.4. does not place an order or purchase a paid service;
3.3.5. does not confer an enforceable right to club membership; and
3.3.6. does not create a sales contract or an agreement for paid services.
3.4. Following approval, the applicant may be invited to create an Account, verify their details and accept separate platform terms.
4. Decisions Pukamuka may make
4.1. After reviewing an application, the Administrator may:
4.1.1. grant club access;
4.1.2. retain the application for further consideration;
4.1.3. place the applicant on a waiting list;
4.1.4. request further information;
4.1.5. defer the decision; or
4.1.6. decline access.
4.2. Decisions take account of the club format, available capacity, operational capabilities, geographical coverage, security, fraud prevention, sanctions and compliance requirements, and other lawful circumstances.
4.3. Review times may depend on demand, the platform’s launch phase and any information checks required. Unless expressly communicated otherwise, submitting a form does not guarantee a decision within a fixed period.
5. Restrictions and refusals of access
5.1. The Administrator may limit intake, suspend new admissions or refuse access for reasonable lawful grounds, including where:
5.1.1. an application does not fit the club’s format;
5.1.2. places are temporarily unavailable;
5.1.3. admissions have been restricted or suspended;
5.1.4. the service is unavailable in a particular country, region or user category;
5.1.5. the applicant provides incomplete, contradictory or manifestly inaccurate information;
5.1.6. there are reasonable concerns about fraud, sanctions breaches, security or legal compliance; or
5.1.7. legal or operational restrictions prevent access.
5.2. The Administrator is not required to disclose internal selection criteria or detailed screening results except where disclosure is legally required.
5.3. Applicants are selected without unlawful discrimination. An access decision does not affect the applicant’s personal data rights.
6. Information we may collect
6.1. When applications are submitted and reviewed, we may collect:
6.1.1. the applicant’s first and last name;
6.1.2. email address and telephone number;
6.1.3. country or city;
6.1.4. preferred contact method;
6.1.5. messages and answers provided in the application;
6.1.6. invitation or referral information, where supplied;
6.1.7. company, sole proprietor and representative details for business applications;
6.1.8. other information voluntarily provided or reasonably necessary for reviewing the application; and
6.1.9. technical data about use of the website and form, including IP address, browser settings and cookies, depending on the technologies actually deployed and consent choices.
6.2. Mandatory fields are indicated in the form. Optional information need not be provided unless necessary for the preferred contact method or the checks relevant to the application.
6.3. An applicant acting for a company or sole proprietorship confirms that they are authorised to represent that business. Additional evidence of authority may be requested before certain forms of access are granted or an order is placed.
6.4. Please do not provide unnecessary, special-category or other sensitive personal data unless expressly requested on an appropriate lawful basis.
7. How we use application information
7.1. We use application information only for specified lawful purposes, including:
7.1.1. identifying and contacting the applicant;
7.1.2. assessing eligibility for club access;
7.1.3. checking whether an application meets the club’s criteria;
7.1.4. maintaining waiting lists and invitation records;
7.1.5. obtaining necessary clarifications;
7.1.6. preventing bots, fraud, abuse and unauthorised access;
7.1.7. administering and securing the website, application form and CRM;
7.1.8. meeting applicable legal, sanctions and compliance requirements; and
7.1.9. providing and administering club access after approval.
7.2. Acknowledgements, clarification requests, status updates, admission decisions and account security notices are service communications connected with the application, and are not automatically marketing messages.
8. Marketing communications
8.1. Submitting an application is not, by itself, consent to marketing. Where marketing relies on consent, that consent is sought separately, voluntarily and without pre-ticked boxes.
8.2. News, invitations, offers and other promotional communications are sent only where an appropriate lawful basis exists under applicable law.
8.3. You may unsubscribe from marketing at any time using the link in a message or by contacting Pukamuka. Opting out does not affect the review of your application or receipt of necessary service communications.
9. Lawful bases for processing personal data
9.1. Depending on the operation and applicable law, the legal basis may be:
9.1.1. taking steps at the applicant’s request before potentially entering into a contract, where appropriate;
9.1.2. the Administrator’s legitimate interests in operating the club, securing the platform, preventing misuse and ensuring its proper functioning, subject to the applicant’s rights;
9.1.3. compliance with a legal obligation; or
9.1.4. separate consent, where required, including for certain marketing activities or optional cookies.
9.2. Different purposes and categories of data may rely on different lawful bases. Where required, further details are provided in the Privacy Policy.
10. Application confidentiality and data access
10.1. We treat the fact that an application was submitted, its contents and status, the admission decision and membership details as restricted-access information.
10.2. Access is restricted to authorised employees, representatives and contractors who need the information to review applications, communicate, maintain security, operate the website, application form and CRM, or meet lawful requirements.
10.3. PERSONAL BUYER LLC is the controller of personal data used to review applications and administer club access. Technology partners may process data on its instructions according to their actual functions and contracts.
10.4. Once an application has been approved and a particular service selected, data necessary to fulfil the order may be shared with PERSONAL BUYER LOGISTICS S.R.L. as the Romanian technology operator of the platform and, where applicable, the Seller for the relevant order, as well as with warehouses, carriers, payment providers, customs providers and other appointed service providers to the extent necessary to fulfil the order. Companies that independently determine the purposes and means of processing for their own sales or services may act as separate data controllers.
10.5. Club admission does not amount to unrestricted consent to share data with any company. Data is shared for specific lawful purposes in accordance with the Privacy Policy.
10.6. We do not publicly disclose an application, waiting-list status, admission or refusal without a proper lawful basis.
11. International data transfers
11.1. The website, email, CRM, hosting, security and support services may use international infrastructure or involve transfers outside the applicant’s country.
11.2. Where transfers are subject to particular Ukrainian, EU/EEA, UK or other rules, we use appropriate lawful transfer mechanisms and safeguards. Depending on the circumstances, these may include adequacy decisions, standard contractual clauses or other legally permitted grounds.
11.3. Further information about recipients, transfer categories and applicable mechanisms is included in the Privacy Policy or made available upon lawful request where required.
12. How long we keep application data
12.1. Data is kept no longer than necessary for its specified purpose unless law or a properly justified need to protect rights requires a different period.
12.2. Indicative maximum periods for club applications are:
12.2.1. rejected or inactive applications without further communication — up to 12 months after the last relevant interaction;
12.2.2. waiting-list or deferred applications — up to 24 months after the last relevant interaction, unless the applicant reconfirms interest;
12.2.3. data concerning admitted members — for the duration of membership and afterwards only where justified by law, security, record-keeping or claims handling; and
12.2.4. marketing-consent records — for as long as the consent is valid and, where necessary, for the minimum additional period required to demonstrate compliance and honour an opt-out.
12.3. Once the relevant period expires, data is erased or anonymised unless further retention has a separate lawful basis. The periods must reflect the actual settings of the systems used by Pukamuka.
13. Cookies and technical tools
13.1. The website may use necessary cookies and other technical tools to operate forms, secure the platform and ensure proper functioning, and, where appropriate, analytics or marketing tools.
13.2. Where consent is required for particular cookies, they are used only in accordance with the user’s choices. Cookie categories and controls are described in the relevant Cookie Policy and website settings.
14. Your personal data rights
14.1. Depending on applicable law, an applicant may have the right to:
14.1.1. receive information about the processing of their data and access it;
14.1.2. request correction of inaccurate or incomplete data;
14.1.3. request erasure where the law provides for it;
14.1.4. request restriction or object to processing where permitted;
14.1.5. withdraw consent where processing is consent-based;
14.1.6. receive data in a portable format where portability rights apply; and
14.1.7. lodge a complaint with the competent data protection authority or seek another lawful remedy.
14.2. To exercise these rights, contact us using the details in section 17. We may reasonably verify your identity before disclosing data or acting on a request. We respond within the period required by applicable law.
15. Other Pukamuka documents
15.1. These Rules govern applications, their review, club access and related data processing. They do not set the total price, fulfilment conditions or refund rules for a particular paid order.
15.2. Once admitted, members may also be subject to the Pukamuka General Terms of Service, Adresa Service Terms, Personal Buyer Terms, Privacy Policy, Cookie Policy and the terms applicable to their order.
15.3. Before a paid order is paid for, the Customer is informed of the contracting Seller or service provider, applicable terms, order details and price. Different orders under the same Account may involve different legal entities.
15.4. Where payment for goods or services has been made, cancellation, refunds and complaints are handled under the relevant contract and applicable mandatory law.
16. Changes to these Rules
16.1. The Administrator may update these Rules following changes to the club format, application process, technology infrastructure or law.
16.2. The current version, including its effective date, is published on this page. Where the law requires separate notice or consent to a change, that requirement will be observed.
16.3. Changes to these Rules do not retrospectively change material terms of concluded sales or paid-service contracts without a proper legal basis.
17. Contact details
Club Administrator and data controller for applicants in the admissions process:
PERSONAL BUYER LLC
Ukrainian company identification code (EDRPOU): 45849496
Address: 40 John McCain Street, Office 241, Kyiv 01042, Ukraine
Email: assistant@pukamuka.com
Telephone: +38 095 866-8888; +38 097 868-6868; +38 093 886-8686; +38 044 370-8686
Enquiries about applications, club access and personal data may be sent to the email address above. Enquiries about paid orders are accepted by Pukamuka’s single customer support service; the Organiser coordinates their review and resolution with the relevant Seller and appointed partners. The Seller retains its obligations relating to the goods.
