Last updated: 27 September 2026
This Privacy Policy explains how Anton Kuzmin (trading as Cross Elements), VAT number PT316473286 (“we”, “us”, “our”), collects, uses, shares, and protects personal data when you visit or make purchases on https://crosselements.com (the “Website”), contact us, create an account, or otherwise interact with us.
We are a contemporary jewelry brand with an atelier in Lisbon, Portugal. For data protection purposes, the data controller is:
Anton Kuzmin
VAT: PT316473286
Atelier: Rocha do Conde de Óbidos, 1350-352 Lisboa, Portugal
Contact
Email: info@crosselements.com
WhatsApp: +1 (332) 269-2388
We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Portuguese law.
1. Personal data we collect
Data you provide directly
- Orders and accounts: name, billing/shipping address, email address, phone number, order details, payment information (processed by Stripe – we do not store full card details), account login credentials, wishlist items, and order history.
- Contact forms, emails, WhatsApp, and custom/wholesale inquiries: name, email, message content, and any other details you choose to share.
- Product reviews (if you are a logged-in customer who purchased the product).
- Newsletter or marketing preferences (if you subscribe).
Data collected automatically
- Technical and usage data: IP address, browser type, device information, pages visited, referring/exit pages, timestamps, and approximate location derived from IP.
- Cookies and similar technologies (see our Cookie Policy (EU) for full details), including:
- Strictly necessary / functional cookies (WooCommerce cart and session, WordPress, LiteSpeed).
- Statistics cookies (Google Analytics, Sourcebuster JS, Elementor) – used with consent where required.
- Marketing/tracking cookies and third-party tools (Facebook, Google Fonts, Google reCAPTCHA, Google Maps where used).
Data from third parties
- Payment processors (Stripe) for transaction confirmation and fraud prevention.
- Shipping carriers (for delivery tracking).
- Social media platforms if you interact with embedded content or share buttons (Instagram, Facebook).
We do not intentionally collect special categories of data or data relating to children under 16. The Website is not directed at children.
2. Purposes and legal bases for processing
| Purpose | Legal basis (GDPR) |
|---|---|
| Process and fulfil orders, payments, shipping, returns, and customer support | Performance of a contract (Art. 6(1)(b)) |
| Create and manage customer accounts, wishlists, order tracking | Performance of a contract / legitimate interests |
| Respond to inquiries, custom orders, wholesale/press requests | Legitimate interests or pre-contractual steps |
| Website security, fraud prevention, spam protection (e.g. reCAPTCHA) | Legitimate interests / legal obligation |
| Analytics and website improvement (Google Analytics, etc.) | Consent (where required) or legitimate interests |
| Marketing communications (if you opt in) | Consent |
| Compliance with legal obligations (tax, accounting, consumer rights) | Legal obligation (Art. 6(1)(c)) |
3. Sharing of personal data
We share data only as necessary with:
- Payment processor: Stripe (secure payments and fraud prevention).
- Hosting and technical providers: WordPress/WooCommerce environment, LiteSpeed, and related services.
- Shipping and logistics partners (to deliver your order).
- Analytics and advertising tools: Google (Analytics, Fonts, reCAPTCHA, Maps), Facebook/Meta, and similar providers listed in our Cookie Policy.
- Professional advisers (accountants, lawyers) under confidentiality.
- Authorities when required by law.
We do not sell your personal data.
4. International transfers
Some providers (e.g. Google, Stripe, Meta/Facebook) process data outside the EEA (including the United States). Where this occurs, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) or other mechanisms permitted under the GDPR. You may request more information about these safeguards by contacting us.
5. Data retention
- Order and transaction data: retained as required for legal, tax, and accounting purposes (typically up to 10 years under Portuguese rules) and for handling returns/warranties.
- Account data: kept while your account is active and for a reasonable period afterward.
- Contact inquiries: retained as long as needed to resolve the matter and for a limited follow-up period.
- Analytics and cookie data: according to the periods stated in our Cookie Policy (or until you withdraw consent).
- Marketing data: until you unsubscribe or withdraw consent.
We delete or anonymise data when it is no longer needed.
6. Your rights under the GDPR
You have the following rights (subject to legal limitations):
- Access your personal data.
- Rectify inaccurate or incomplete data.
- Erase data (“right to be forgotten”) in certain circumstances.
- Restrict processing.
- Data portability (where applicable).
- Object to processing based on legitimate interests or for direct marketing.
- Withdraw consent at any time (without affecting the lawfulness of prior processing).
- Lodge a complaint with the Portuguese Data Protection Authority (CNPD – Comissão Nacional de Proteção de Dados) or your local supervisory authority.
To exercise any of these rights, email info@crosselements.com. We will respond within one month (or inform you if an extension is needed).
7. Cookies and similar technologies
We use cookies and similar technologies as described in our dedicated Cookie Policy (EU):
https://crosselements.com/cookie-policy-eu/
You can manage your preferences via the cookie consent banner (“Manage Consent” / “View preferences”) on the Website. Strictly necessary cookies cannot be disabled as they are required for the site and shopping cart to function.
8. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or alteration. Payment data is handled by Stripe using industry-standard security. No method of transmission over the internet is completely secure; please use strong passwords and keep your account details confidential.
9. Third-party links and social media
The Website may contain links to third-party sites or embed social media content (Instagram, Facebook). We are not responsible for the privacy practices of those sites. Please review their policies separately.
10. Changes to this Privacy Policy
We may update this policy from time to time. The “Last updated” date at the top will reflect the latest version. Significant changes will be notified on the Website or by email where appropriate. Continued use of the Website after changes constitutes acceptance of the updated policy.
11. Contact
For any questions about this Privacy Policy or our data practices:
Anton Kuzmin (Cross Elements)
VAT: PT316473286
Email: info@crosselements.com
WhatsApp: +1 (332) 269-2388
Atelier: Rocha do Conde de Óbidos, 1350-352 Lisboa, Portugal (by appointment)




