Personal Data Processing Policy

1. General Provisions

This Policy defines the procedure for processing and protecting the personal data of visitors to the website https://www.irinasirenko.ru in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data.”

Operator: Sirenko Irina Valeryevna
Status: self-employed taxpayer (professional income tax)
TIN: 772205232909
Email for personal data inquiries: pina_s@mail.ru

2. What Data Is Processed

When using the first-contact form, the following are processed:

• surname, first name, and patronymic;
• chosen contact method and the corresponding email, phone number, or messenger username;
• topic of inquiry and the messenger selected for redirect after the form;
• technical data: date and time, consent version, IP address, and User-Agent.

The form is not intended for submitting health information, diagnoses, intimate life details, political, religious, or other special categories of personal data. Such information should not be provided in the first inquiry.

3. Purpose and Legal Basis of Processing

Data is processed solely to respond to an inquiry, arrange the first session, and choose a suitable format of work. The legal basis is separate consent of the data subject.

This data is not used for advertising or informational mailings. Such use would require separate consent.

4. Actions with Data and Retention Period

The Operator may carry out collection, recording, systematization, accumulation, storage, updating, retrieval, use, blocking, deletion, and destruction of data using automated means.

If no agreement is concluded, application data is stored for no more than 90 days after the last contact, until the purpose is achieved or until consent is withdrawn — whichever occurs first. After that, application data is deleted or anonymized.

Proof of consent is stored separately for three years after consent ceases to be effective, unless another period is established by law. Contractual and tax data are processed and stored on independent legal grounds for the periods provided for them.

5. Storage and Transfer

Primary collection and processing of the full application take place in the territory of the Russian Federation using Yandex Cloud infrastructure. The full notification is sent via Yandex Mail and stored in Mail.ru email infrastructure in the Russian Federation.

To support the website, form, and delivery of notifications, the Operator may engage technical contractors. They may receive limited access to data only on the Operator’s instruction, without their own purposes, to the extent necessary to support infrastructure, subject to confidentiality and security measures.

For operational notification, application number, date and time, masked full name, and the name of the chosen contact method may be transmitted in encrypted form through the Jester technical gateway to Telegram. Full name, contact value, and topic of inquiry are not transmitted to Jester and Telegram. Since these services may process information outside the Russian Federation, such operation may constitute cross-border transfer and is carried out in compliance with the requirements of Article 12 of Federal Law No. 152-FZ, including prior fulfillment of mandatory procedures where applicable.

6. User Rights

The user has the right to:

• receive information about the processing of their data;
• request updating, blocking, or deletion of data;
• withdraw consent to processing;
• appeal the operator’s actions to Roskomnadzor or a court.

A request or withdrawal of consent should be sent to pina_s@mail.ru. The inquiry must indicate contact details by which a previously submitted application can be identified.

7. Data Protection

The Operator takes necessary legal, organizational, and technical measures to protect data from unauthorized access, alteration, disclosure, blocking, copying, and destruction, restricts access to data, and deletes it after the purpose is achieved.

8. Cookies and External Services

In the current version, the website does not use analytics systems, advertising trackers, or non-essential cookies. If such tools are connected, the Policy will be updated, and a separate mechanism for user choice will appear for non-essential cookies.

9. Changes to the Policy

The current version is permanently available at https://www.irinasirenko.ru/en/privacy.html. A new version takes effect from the moment of publication unless another date is specified in it.