Privacy Policy

This Personal Data Processing Policy (the “Policy”) is adopted pursuant to clause 2, part 1, article 18.1 of Russian Federal Law No. 152-FZ “On Personal Data” of 27 July 2006 (the “Law”) and sets out how personal data is processed and protected.

The personal data operator (the “Operator”, “we”) is Individual Entrepreneur Andrey Yurievich Chipizubov, Taxpayer ID (INN) 752905912110, Primary State Registration Number (OGRNIP) 322750000008053, Borzya, Zabaykalsky Krai, Russia. Contact email for personal data matters: gainad_official@mail.ru.

The Policy applies to all personal data the Operator receives from visitors to gainad.ru and its subdomains (the “Site”) and from persons contacting the Operator via the contacts listed on the Site. It does not apply to third-party websites linked from the Site.

The Operator personally is responsible for organising personal data processing. The Policy is publicly available on the Site as required by part 2, article 18.1 of the Law.

Consent to personal data processing when submitting a request is given as a separate document — the Consent to Personal Data Processing.

Personal data

any information relating directly or indirectly to an identified or identifiable natural person (data subject).

Processing

any operation performed on personal data, with or without automation: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), depersonalisation, blocking, erasure, destruction.

Cross-border transfer

transfer of personal data to the territory of a foreign state, to a foreign authority, or to a foreign natural or legal person.

Cookie

a small piece of data that the Site or a third-party service stores in the user’s browser. Similar technologies include localStorage and analytics counters.

User

a natural person visiting the Site or contacting the Operator through it.

Other terms have the meanings given to them in the Law.

Processing is lawful and fair and is limited to specific, predetermined purposes. Only data relevant to those purposes is processed, and its content and volume are not excessive. Databases processed for incompatible purposes are not combined.

The legal grounds for processing are:

• the data subject’s consent — clause 1, part 1, article 6 of the Law;
• the need to enter into a contract at the data subject’s request, or to perform a contract to which the data subject is a party — clause 5, part 1, article 6;
• compliance with the Operator’s legal obligations (tax and accounting) — clause 2, part 1, article 6;
• the Operator’s legitimate interests (protecting the Site from spam and attacks), provided the data subject’s rights and freedoms are not infringed — clause 7, part 1, article 6.

The Operator does not process special categories of personal data (race, nationality, political views, religious beliefs, health, intimate life) or biometric data. No decisions producing legal effects for the data subject are made solely on the basis of automated processing.

For each purpose we define the data, the legal ground and the retention period.

If you contact us via Telegram, VK or by phone, we receive the data you provide or that is visible in your messenger profile (name, username, messages) and process it for the same purpose and period as a Site request. Processing inside messengers is carried out by their owners under their own rules.

The Operator does not send advertising or newsletters and does not use the data for direct marketing without separate consent.

The user is responsible for the accuracy of the data provided. By including third parties’ data in a request (for example, colleagues), the user confirms they are entitled to share it.

The Operator carries out mixed processing (automated and non-automated) and performs the following operations: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, erasure, destruction.

In accordance with part 5, article 18 of the Law, recording, systematisation, accumulation, storage, clarification and retrieval of personal data of Russian citizens are carried out using databases located in the Russian Federation: the Site’s servers and the Operator’s Mail.ru mailbox.

Processing stops and data is destroyed when the purposes are achieved, the retention period expires, consent is withdrawn (unless another legal ground applies), unlawful processing is detected, or the Operator ceases its activities.

The Operator does not sell personal data or share it with third parties for their own purposes. To run the Site, the Operator uses the following providers, who process data on the Operator’s behalf or as part of the services they provide:

Processors acting on the Operator’s behalf must comply with the principles and rules of the Law and ensure the confidentiality and security of the data.

Personal data may be disclosed to public authorities, courts and other authorised persons only in the cases and manner provided by Russian law.

The Operator does not transfer personal data across borders: all services processing data on the Operator’s behalf store it in the Russian Federation.

Replies are sent to the email address you provided. If that address is served by a foreign email provider, or if you contact us via a messenger owned by a foreign company, messages are delivered through such services at your choice and under their owners’ terms.

The Site uses strictly necessary technologies, without which it cannot work properly, and analytics technologies — only with your consent. Analytics counters are not loaded until you click “Accept” in the banner.

You can change your choice at any time via the “Cookie settings” link in the Site footer. You can delete stored cookies and block them in your browser settings. Disabling necessary technologies may break the Site.

Webvisor recordings do not capture the contents of the contact form fields.

The Operator takes the legal, organisational and technical measures required by articles 18.1 and 19 of the Law, including:

• data between the browser and the Site is transmitted only over HTTPS (TLS);
• only the Operator has access to the mailbox and the accounts of the services used;
• request data is not stored in a Site database — it is delivered straight to the Operator’s mailbox;
• form rate limiting, request origin checks and protection against automated submissions;
• contact form field contents are excluded from Webvisor recordings;
• monitoring compliance with the Law and this Policy, recording and investigating incidents.

Under articles 14–17 and 21 of the Law, you have the right to:

• obtain information about the processing of your data: confirmation of processing, legal grounds and purposes, the data processed, retention periods, recipients and cross-border transfers;
• demand that your data be clarified, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not needed for the stated purpose;
• withdraw your consent to processing;
• demand that processing be stopped;
• appeal the Operator’s actions or inaction to Roskomnadzor or a court.

Send your request to gainad_official@mail.ru. Under part 3, article 14 of the Law, a request must contain your full name, information confirming your relationship with the Operator (for example, the email address used for the request and the approximate date) and your signature. Electronic requests are signed with an electronic signature; we also consider emails sent from the address used in the request if they allow us to reliably identify you.

Response times:

• providing information — within 10 business days of receipt; may be extended by up to 5 business days with a reasoned notice;
• correcting inaccurate data — within 7 business days of receiving supporting information;
• stopping processing at your request — within 10 business days (extendable by 5 business days), except in the cases set out in clauses 2–11, part 1, article 6 of the Law;
• stopping processing and destroying data after consent is withdrawn — within 30 days, unless another legal ground applies.

In the event of an unlawful or accidental transfer of personal data that infringes data subjects’ rights, the Operator notifies Roskomnadzor within 24 hours of detection and reports the results of its internal investigation within 72 hours (part 3.1, article 21 of the Law).

Data is destroyed by irreversibly deleting emails and records. Destruction is documented in accordance with Roskomnadzor Order No. 179 of 28 October 2022.

The Site and the Operator’s services are intended for persons over 18. The Operator does not knowingly collect data from minors. If you believe a minor has provided us with their data, email gainad_official@mail.ru and we will delete it.

The Operator may amend this Policy, including when the law or the scope of processed data changes. A new version takes effect on the date stated in its header and is published on this page. Changes do not reduce your rights without your consent. If changes require new consent (for example, new processing purposes), we will ask for it separately.

Individual Entrepreneur Andrey Yurievich Chipizubov. INN 752905912110, OGRNIP 322750000008053. Borzya, Zabaykalsky Krai, Russia.

Email for personal data requests: gainad_official@mail.ru.

Supervisory authority for the protection of data subjects’ rights — Roskomnadzor: rkn.gov.ru.