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Privacy policy

What data we receive through the site and in messages, why, where we keep it, and how you can check, correct or delete it.

Edition 2 of

In short

Russian original. This English text is a translation for convenience. If the two differ, the Russian version applies.

  • One person is responsible for your data: Alexander Andreevich Simaranov, self-employed. “Simaranov” and the six studios are his lines of work, not separate companies.
  • We take only what we need to reply: your name, a contact, the task description and anything you add yourself.
  • A request sent from the site is saved on our server in Russia and deleted from it after 90 days.
  • We do not sell data, send marketing emails or pass data to outsiders.
  • Yandex Metrica turns on only if you click “Accept” in the cookie notice.
  • To find out what we hold about you, correct it or delete it, email s.simaranov8@gmail.com or message t.me/s1rne on Telegram. We reply within 10 working days, usually sooner.

1. General

  1. This policy sets out how the operator processes and protects personal data. It is adopted under Article 18.1(1)–(2) of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”).
  2. Operator: Alexander Andreevich Simaranov, Russian taxpayer number (INN) 500345602426, registered self-employed professional in Russia (professional income tax payer). Contacts for personal data questions: email s.simaranov8@gmail.com, Telegram t.me/s1rne, phone +7 968 093-07-00. “We” and “us” in this policy mean the operator.
  3. The policy covers all personal data the operator processes: on simaranov.ru (including the English version), in messages and calls, and when we agree on work and do it.
  4. The operator is personally responsible for organising data processing. The policy is publicly available on the site and linked in the footer of every page and next to the request form.
  5. Key terms: personal data is any information about a person that identifies them directly or indirectly; the data subject is the person the data relates to; the operator organises the processing and sets its purposes; processing is any action with data: collecting, recording, storing, using, transferring, deleting and others; blocking is a temporary stop of processing; destruction means actions after which the data cannot be restored. Other terms have the meanings given in Article 3 of the Law.

2. Principles

Data is processed lawfully and fairly, only for stated purposes, limited to what those purposes need, kept accurate, kept no longer than needed and destroyed once the purpose is met (Article 5 of the Law). Data collected for incompatible purposes is not combined.

3. What data, why, on what basis and for how long

3.1. Replying to a request from the site

Whose data
Visitors who send the request form.
What data
Name; contact (Telegram, email or phone); task description; chosen studios, deadline and budget if given; site page and language; campaign tags (UTM) and the domain of the site you came from; date and time of the request; consent record (date, time, document edition).
Legal basis
Your consent (Article 6(1)(1) of the Law) and steps taken at your request before a contract (Article 6(1)(5)).
Retention
On the site server a request is kept for 90 days from receipt and deleted automatically. If we do not agree on work, we delete the request data no later than 6 months after the last message. If we do, the data the work needs is kept under section 3.3.

3.2. Messages and calls you start yourself

Whose data
People who message us on Telegram, email us or call, and people we reply to at the contact they gave in a request.
What data
Name or username, phone number, email address, Telegram account, message text and attachments.
Legal basis
Steps taken at your request before a contract (Article 6(1)(5) of the Law).
Where
In the messaging service you chose yourself, under its rules.
Retention
While we discuss the work. If we do not agree on work, we delete the messages no later than 6 months after the last one.

3.3. Doing the agreed work and taking payment

Whose data
Clients who are individuals and representatives of client companies.
What data
Name or full name; contacts; the terms agreed in our messages; project messages and materials; payment records. If you asked for a written contract, also the details the parties put in it. For a company receipt: its name and taxpayer number.
Legal basis
Performance of a contract you are party to, including one made by exchanging messages (Article 6(1)(5) of the Law); the operator’s legal obligations, including issuing receipts in the “Moy Nalog” tax app under Federal Law No. 422-FZ of 27 November 2018 (Article 6(1)(2)).
Retention
While the work goes on and 5 years after it ends (tax record-keeping periods).

3.4. Protecting the site and the form from spam and attacks

Whose data
All visitors.
What data
IP address, date and time of the request, page address, browser details.
Legal basis
The operator’s legitimate interest in running the site securely, provided your rights are not infringed (Article 6(1)(7) of the Law).
Retention
The form service keeps the IP address in memory for up to 10 minutes to limit rapid repeats and does not write it to the request log. Web server logs and the form service’s own log (which records an IP address only when a request looks like spam) are kept for no more than 30 days.

3.5. Visit statistics without cookies

Whose data
All site visitors.
What data
Pages viewed, the site or tag you came from, device type, browser and system, language, and country and city derived from the IP address. The IP address itself is not stored. No cookies are set. Visits within one day are linked by an anonymous code that changes every day, so you cannot be recognised across days.
Basis
The operator’s legitimate interest in knowing which pages help visitors (Article 6(1)(7) of the Law).
Where and how long
On the operator’s own server in Russia. Aggregate statistics are kept as long as the site needs them.

3.6. Counting visits (Yandex Metrica), only with your consent

Whose data
Visitors who clicked “Accept” in the cookie notice.
What data
Cookie identifier, IP address and approximate region, browser, device and screen details, pages viewed, link clicks, time on site, referring site.
Legal basis
Your consent (Article 6(1)(1) of the Law) on the terms set out on the Cookies page.
Retention
Until you withdraw consent; we ask again after 365 days. We only look at aggregated Metrica reports. Session recording (Webvisor) is off.
Right now
Metrica is not installed on the site, so this data is not collected.

The operator does not process special categories of personal data or biometric data, does not make decisions with legal effects for you based solely on automated processing, does not publish your data and does not use it for marketing emails.

4. How data is processed

  1. Operations: collection, recording, systematisation, accumulation, storage, updating and amendment, retrieval, use, transfer (provision, access), blocking, erasure, destruction. Processing is mixed: with and without computers.
  2. Recording, systematisation, accumulation, storage, amendment and retrieval of data collected through the site take place in a database on a server in Russia (a VDSina data centre in Moscow), as Article 18(5) of the Law requires. The operator opens a request on that server over an encrypted connection and with a password.
  3. Processing stops when the purpose is met, the retention period ends, you withdraw consent and there is no other basis, or unlawful processing is found. Data is destroyed within the periods in Article 21 of the Law, and destruction is documented as Roskomnadzor requires.

5. Who receives data

We do not sell data or pass it to outsiders. Data may be received, in particular, by:

  • Invited specialists, if they work on your project: only the data they need for the work, and only with your consent, which we will ask for separately. They must keep the data confidential (Article 6(3) of the Law).
  • Yandex LLC (Moscow), which processes Yandex Metrica data on the operator’s behalf (Article 6(3) of the Law), only if you agreed to analytics cookies.
  • The Russian Federal Tax Service, through the “Moy Nalog” receipt when you pay.
  • Public authorities, only where and as the law requires.

The site server is rented from the hosting provider VDSina in a data centre in Russia. The provider supplies only the hardware: it does not receive the data or process it on our behalf.

6. If you write to us yourself

If you write to us yourself, on Telegram or by email, you choose that service yourself. We process such a message to reply to you (Article 6(1)(5) of the Law). You can also call: +7 968 093-07-00.

7. Cookies

The site uses only necessary browser storage: to remember your cookie choice and to attach to a request where you came from. Yandex Metrica analytics cookies are set only with your consent. Details on the Cookies page.

8. How data is protected

The operator takes legal, organisational and technical measures under Articles 18.1 and 19 of the Law:

  • only the operator has access to the data and is responsible for organising its processing;
  • data from the site travels only over an encrypted connection (HTTPS);
  • a full request can be opened only with a password and only over an encrypted connection; password attempts are limited; that page is closed to search engines and is not cached;
  • the form service runs isolated on the server with minimal permissions; the server can be administered only with a key; unused network ports are closed and repeated attempts to guess access are blocked automatically;
  • requests are deleted from the server automatically after 90 days, server logs after 30 days;
  • the form is protected against spam and automated submissions;
  • the operator has assessed the harm a breach of the Law could cause, approved a list of protection measures and reviews it when things change;
  • security level 4 has been set for the personal data (Russian Government Decree No. 1119 of 1 November 2012) and the requirements for that level are met;
  • in a data breach the operator notifies Roskomnadzor within 24 hours, reports the investigation results within 72 hours (Article 21(3.1) of the Law) and informs the people affected.

9. Operator rights and duties

The operator may:

  • process data for the purposes and on the bases set out in section 3;
  • entrust processing to another person with your consent or on another lawful basis (Article 6(3) of the Law);
  • continue processing without consent where the law allows it (Article 9(2));
  • refuse to answer a repeated or unjustified request, giving the reason (Article 14(6)).

The operator must:

  • process data only for the stated purposes and only to the extent they require;
  • on request, tell you what data is processed and how, and let you see it;
  • correct, block and destroy data in the cases and within the deadlines set by Articles 20 and 21 of the Law;
  • apply the measures in section 8 and keep data of Russian citizens in databases located in Russia;
  • answer Roskomnadzor requests within 10 working days and report data breaches within the deadlines of Article 21(3.1).

10. Your rights and how to use them

You can:

  • find out whether we process your data, which data, why and how (Article 14 of the Law);
  • ask us to correct, block or destroy data that is incomplete, outdated, inaccurate, unlawfully obtained or not needed for the stated purpose;
  • withdraw consent (Article 9(2)) or require us to stop processing (Article 21(5.1));
  • complain about the operator to Roskomnadzor or a court (Article 17).

Email s.simaranov8@gmail.com or message t.me/s1rne on Telegram. You can also send a written request signed with an electronic signature. To avoid handing your data to someone else, we may ask you to confirm the request from the contact you gave in your request.

What to include (Article 14(3) of the Law): your full name; the number, issue date and issuer of your passport or other ID (for a written request); something showing you contacted us, such as the date of your request and the contact in it; what exactly you are asking for; your signature if the request is written. Sample: “Please tell me what personal data of mine you process (or: correct it, delete it, stop processing it). I sent a request on simaranov.ru on [date] with the contact [contact].”

Deadlines: information about processing within 10 working days; corrections within 7 working days; stopping processing at your request within 10 working days; after consent is withdrawn, destruction within 30 days unless there is another lawful basis to keep the data (Articles 20 and 21 of the Law). Ten-working-day deadlines may be extended by up to 5 working days, and we will tell you why. There is no charge.

11. If you are under 18

If you are under 18, send a request with your parents’ knowledge or ask them to contact us. If we learn that a child sent us data without a parent’s knowledge, we will delete it.

12. Changes

The operator may update this policy. A new edition applies from the day it is published on this page; the edition date is shown at the top. Earlier editions are available on request. Consents given under an earlier edition remain valid to the extent they were given.

Other documents: Consent to personal data processing, Cookies, Legal information.