This is an English translation provided for convenience. In case of any discrepancy, the Russian version shall prevail.
This Policy sets out what personal data is processed on the website https://rupor.agency (hereinafter, the “Website”), for what purposes, on what legal grounds, for how long and how it is protected. The Policy has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter, the “Law”) and is published pursuant to Part 2 of Article 18.1 of the Law.
1.1. The personal data operator is Sole Proprietor Mikhail Evgenievich Babchinsky, INN (taxpayer ID) 780715473679, OGRNIP (state registration number) 313470327000026 (hereinafter, the “Operator”). The Website and the Operator’s services are presented under the designation “Rupor”.
1.2. Questions about the processing of personal data, requests and withdrawals of consent should be sent to hello@rupor.agency.
2.1. Personal data means any information relating directly or indirectly to an identified or identifiable natural person (the personal data subject).
2.2. Processing of personal data means any action or set of actions performed with personal data, with or without the use of automation tools: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction.
2.3. User means any person who visits the Website or submits data through its forms.
2.4. Cookie means a small file that the Website or a service connected to it stores in the User’s browser.
2.5. Consent log means the records of when and to which version of a document the User gave or withdrew consent.
| Purpose | Data | Legal basis | Period |
|---|---|---|---|
| To review a request or inquiry submitted through a form on the Website, contact the User and prepare a proposal, cost estimate or invoice | Name; email address; phone number, company name, position or role, website address — if provided; message text; the selected service or product | Consent (Clause 1 of Part 1 of Article 6 of the Law); actions taken at the User’s request prior to the conclusion of a contract (Clause 5 of Part 1 of Article 6) | Until the purpose is achieved, but no longer than 3 years from the date of the last inquiry if no contract has been concluded — or until consent is withdrawn |
| To conclude and perform a contract, including the sale and support of a module license | Data from the request; data from correspondence under the contract; information contained in invoices and completion documents | Conclusion and performance of a contract (Clause 5 of Part 1 of Article 6); accounting and tax record-keeping obligations (Clause 2 of Part 1 of Article 6) | The term of the contract and 5 years after it ends (Article 29 of Federal Law No. 402-FZ “On Accounting”, Subclause 8 of Clause 1 of Article 23 of the Tax Code of the Russian Federation) |
| To confirm that consent has been obtained (consent log) | Consent type and status, selected cookie categories; date and time; IP address; browser information (user-agent); page URL; document version and date; for consents given through forms — email address | The Operator’s obligation to prove that consent has been obtained (Part 3 of Article 9, Clause 2 of Part 1 of Article 6 of the Law) | 3 years from the date of the record, after which the records are deleted automatically |
| Web analytics: to understand how visitors use the Website and to improve it | Cookie identifiers; IP address; browser and device information; URLs of pages viewed and referral sources; actions on pages, including session recording by Webvisor (a Yandex Metrica tool); date and time of the visit | Consent to analytics cookies (Clause 1 of Part 1 of Article 6), which is given in the cookie banner. Without it, Yandex Metrica (Yandex’s web analytics service) is not loaded on the Website | Until consent is withdrawn; data in the service is stored under the terms of Yandex Metrica |
| To ensure the operation and security of the Website | Web server logs: IP address, date and time of the request, page URL, browser information, server response code | The Operator’s legitimate interest in protecting the Website against failures and attacks (Clause 7 of Part 1 of Article 6) | 31 days, after which the logs are deleted automatically |
3.1. The personal data subjects are visitors to the Website and persons who have submitted data through its forms, including representatives of organizations.
3.2. The Operator does not process special categories of personal data or biometric personal data, does not make decisions based solely on automated processing, does not sell personal data and does not use it for advertising mailings.
4.1. Processing is automated, with transfer via the Internet. Personal data obtained through the Website is not kept on paper.
4.2. Actions performed with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction.
4.3. The recording, systematization, accumulation, storage, clarification and extraction of personal data of citizens of the Russian Federation are carried out using databases located in the territory of the Russian Federation (Part 5 of Article 18 of the Law): the Website, the request database and the consent log are hosted on servers of the Timeweb Cloud infrastructure in the Russian Federation, and notifications of requests are delivered to the Yandex 360 email service.
4.4. No cross-border transfer of personal data is carried out.
4.5. The Operator engages Yandex LLC (INN 7736207543, 16 Lva Tolstogo St., Moscow, 119021): the Operator receives requests from the Website’s forms through the Yandex 360 email service, and the Yandex Metrica service collects visit statistics if the User has consented to analytics cookies. Yandex LLC processes the data under the terms of use of these services. The Operator transfers personal data to other third parties only in the cases provided for by law.
4.6. The Operator and persons authorized by the Operator have access to personal data to the extent necessary to perform their tasks. All of them are obliged to maintain the confidentiality of personal data.
5.1. The Website always uses necessary cookies: they remember the User’s choice in the cookie settings. Analytics cookies (Yandex Metrica) are set only after consent is given in the cookie banner.
5.2. The choice can be changed at any time via the “Cookie settings” link at the bottom of every page. The list of cookies and their retention periods are set out in the Cookie Policy.
6.1. The User has the right to:
6.2. Requests should be sent to hello@rupor.agency. The Operator responds within 10 business days from the date of receipt of the request; this period may be extended by no more than 5 business days, provided that the User is notified of the reasons.
6.3. To withdraw consent given through a form, send an email to hello@rupor.agency with the subject line “Withdrawal of consent to the processing of personal data”. The Operator ceases processing and destroys the personal data within no more than 30 days from the date of receipt of the withdrawal, unless otherwise provided by a contract or by law. Consent to analytics cookies is withdrawn in “Cookie settings”.
7.1. The Operator takes legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision and dissemination, including by:
7.2. If an unlawful or accidental transfer of personal data that has resulted in a violation of the rights of Users is detected, the Operator notifies Roskomnadzor within the time limits established by Part 3.1 of Article 21 of the Law: of the incident within 24 hours, and of the results of its investigation within 72 hours.
8.1. Personal data is destroyed when the purposes of processing are achieved, when the retention periods expire, when consent is withdrawn or when unlawful processing is detected, unless otherwise provided by law. The destruction is confirmed in accordance with the procedure established by Roskomnadzor.
9.1. The Operator may amend the Policy. A new version takes effect upon its publication on the Website and is assigned a new version number; if the changes require new consent, the Operator will request it.
9.2. The current version of the Policy is always available at https://rupor.agency/privacy (in Russian; this English translation is at https://rupor.agency/en/privacy). The text of the consent to the processing of personal data is available at https://rupor.agency/agreement (English translation: https://rupor.agency/en/agreement).
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