Application Review and Privacy Rules of the Pukamuka Club

Welcome to the Pukamuka Club.

This page explains how we review applications to join the Club, how confidentiality works at this stage, what data we may collect, why we use it, and what submitting an application means.

We have written this document in a clear and accessible way so that the rules are easy to understand before you submit your application.

1. What the Pukamuka Club is

Pukamuka operates as a private club with limited access.

This means access is not granted automatically. It may be offered following an individual review of an application, by personal invitation, by referral, or within a limited onboarding or testing phase.

The Club format, number of available places, application review process, regions of availability, and invitation model are determined by Pukamuka at its discretion.

2. What submitting an application means

Submitting an application on this page means that you are asking Pukamuka to consider whether access to the Club may be offered to you.

Submitting an application:

• is not an automatic registration;
• does not automatically create an account;
• does not mean you have been accepted to the Club;
• does not guarantee access to Pukamuka services;
• does not create a contract;
• does not give the applicant a right to demand admission to the Club or access to any service.

Each application is reviewed individually.

3. What decision Pukamuka may make

After receiving your application, Pukamuka may:

• grant access to the Club;
• keep the application under further review;
• place the application on a waiting list;
• request additional information;
• postpone the review;
• decline access.

Pukamuka makes its decision taking into account the Club format, available capacity, operational capabilities, geography of service availability, security, compliance, sanctions, technical, commercial, and other lawful factors.

Pukamuka is not required to disclose its internal selection criteria or explain its decision beyond what is required by applicable law.

4. Pukamuka’s right to limit or decline access

Because the Club is private, Pukamuka has the right to decide to whom, when, and in what format access may be offered.

Pukamuka may decline access, including where:

• the application does not fit the Club format;
• there are no available places at the time of review;
• onboarding is temporarily limited or paused;
• the service is not yet available for a certain country, region, or user category;
• incomplete, inconsistent, or clearly inaccurate information was provided;
• there are security, sanctions, fraud, compliance, or reputational concerns;
• legal or operational restrictions do not allow access to be offered.

Pukamuka does not apply unlawful discrimination where such discrimination is prohibited by mandatory law.

5. What data we may collect

At the application stage, we may collect and process data that you provide in the form or in subsequent communication, including:

• first name and last name;
• email address;
• phone number;
• country or city;
• preferred contact method;
• the content of your message;
• referral or invitation information, if applicable;
• any other data you voluntarily choose to provide;
• technical information related to your interaction with the website, the form, cookies, or your device within the operation of the website.

Please do not include unnecessary or sensitive personal data in your application unless the form specifically requests it.

6. Why we use this data

We use the data received through the application only to the extent necessary for operating the private Club, including to:

• identify the applicant;
• contact you regarding your application;
• review possible access to the Club;
• assess whether the application matches the Club format;
• build a waiting list or invitation list;
• protect the Club against abuse, fraud, bots, and other risks;
• ensure security, proper administration, and access control;
• comply with legal, sanctions, tax, compliance, or other mandatory requirements;
• administer access after approval, if access is granted.

We may also send you messages directly related to your application, such as confirmation of receipt, requests for clarification, the decision on your application, or information about access being granted.

7. Marketing communications

Submitting an application does not by itself mean that you consent to advertising or marketing communications, unless this is clearly indicated in the form and you confirm it separately where required.

If you separately agree to receive news, invitations, or special offers from Pukamuka, we may send such communications in accordance with your choice and applicable law.

You may opt out of such communications at any time using the method stated in the message or by contacting us.

8. Legal basis for processing

We process applicant data because this is necessary to review your request and to take steps at your request before a possible service relationship begins.

We may also process data based on our legitimate interests in securely administering a private club, controlling access, protecting against abuse, and ensuring the proper functioning of the Pukamuka website and internal processes.

Where required by law, we will rely on your consent, including in relation to certain marketing communications or certain cookie technologies.

9. Who may access your application data

We treat information about your application, its status, and possible Club participation as restricted-access information.

It may be accessed only by those employees, representatives, contractors, or technical partners of Pukamuka who objectively need it for:

• reviewing the application;
• communicating with the applicant;
• supporting the website, form, CRM, or related systems;
• security, anti-fraud, or compliance checks;
• legal or administrative support.

We aim not to disclose to third parties the fact that you submitted an application, received an invitation, were placed on a waiting list, or were accepted or declined, unless this is required by law, necessary to protect Pukamuka’s rights, or based on your separate consent.

10. International processing and transfers

Because Pukamuka may use international technical infrastructure for the website, forms, hosting, email, CRM, analytics, or support, some data may be processed or become accessible outside the country from which you apply.

Where the laws of Ukraine, the EU/EEA, the United Kingdom, or another jurisdiction apply, we take reasonable legal, contractual, and organizational measures to protect personal data as required by applicable law.

11. How long we keep data

We do not keep data longer than necessary for the purposes for which it was collected.

As a general approach, we may keep:

• applications that were not approved and are no longer under active communication — for up to 12 months from the last relevant interaction;
• applications on a waiting list or under postponed review — for up to 24 months;
• data of persons granted access to the Club — during their participation and thereafter for as long as reasonably necessary for administration, compliance, protection of Pukamuka’s rights, or dispute resolution;
• data related to marketing consent — until consent is withdrawn or the relevant purpose ends.

In some cases, we may retain a minimum necessary amount of data for longer where needed for security, prevention of repeated abuse, responding to claims, or compliance with legal obligations.

12. Cookies and technical tools

When using this page and form, cookies and other technical tools may be used for the proper functioning of the website, security, analytics, or service improvement.

Where consent is required for certain cookies or technologies, they are used according to the settings you choose on the website.

13. Your rights

Depending on your country and applicable law, you may have the right to:

• know what personal data we process about you;
• access your data;
• correct inaccurate or incomplete data;
• request deletion of data where provided by law;
• restrict or object to certain processing;
• withdraw consent where processing is based on consent;
• lodge a complaint with a competent data protection authority.

To exercise these rights, you may contact us using the details below. Where necessary, we may ask you to verify your identity before processing your request.

14. When other website documents apply

This document governs the stage of applying to the private Club.

If, after your application is reviewed, you are granted access to the Club, create an account, start using Pukamuka services, or place orders, additional documents and rules available within the service or on relevant parts of the website will also apply.

15. Updates to this document

Pukamuka may update this document from time to time if the Club format, application review process, technical infrastructure, legal requirements, or access model changes.

The current version published on this page applies from the date it is posted, unless stated otherwise.

16. Contacts

Application review operator:‍

LLC «PERSONAL BUYER»‍

welcome@pukamuka.com