1. General Provisions and Policy Purpose
1.1. This Personal Data Processing Policy (hereinafter - "Policy") establishes the procedure and conditions for processing personal data by Chutov Sergey Akopovich (TIN: 504906280580), registered and operating under the legislation of Russia (hereinafter - "Operator"), regarding information about an individual that may be obtained by the Operator from this individual or their legal representative (hereinafter - "Personal Data Subject"), in the following cases:
a) When using the functions of the website https://sergeychutov.com/, including all its domains, subdomains and pages, their content, as well as internet services and software offered by the Operator for use on this website (hereinafter - "Website");
b) When processing appeals, complaints, requests, and messages exchanged between the Operator and the Personal Data Subject.
1.2. The purpose and objective of this Policy is to ensure proper legal regime for personal data. The Policy cannot contain provisions that:

• Limit the rights and freedoms of Personal Data Subjects
• Establish cases of processing specific categories of minors' personal data, unless otherwise provided by Russian legislation
• Allow as a condition for contract conclusion/consent the inaction of the Personal Data Subject

2. Legal Basis for Personal Data Processing
2.1. The legal grounds for personal data processing are:
a) Consent to personal data processing given in the manner established by law and this Policy;
b) Processing is necessary for purposes stipulated by international treaties of the Russian Federation or law, for performing functions, powers and duties imposed on the Operator by Russian legislation;
c) Processing is necessary for exercising the rights and legitimate interests of the Operator or third parties;
d) Processing is carried out for statistical or other research purposes, provided personal data is anonymized.
2.2. The Personal Data Subject makes a voluntary, informed decision to provide their personal data and give consent for processing. Inaction by the Personal Data Subject cannot be interpreted as consent. Consent must be specific, substantive, informed, conscious and unambiguous.
2.3. The Consent text for personal data processing under this Policy is permanently available at: https://sergeychutov.com/soglasie. Consent may be given by the Personal Data Subject through the following actions:
a) Clicking the "Submit" button on the Website next to checked boxes with the text:

✔️ Я даю Согласие на обработку персональных данных на условиях Политики обработки персональных данных / I consent to the processing of my personal data in accordance with the Personal Data Processing Policy
✔️ Я согласен получать рекламные и информационные материалы / I agree to receive promotional and informational materials

3. Personal Data Processing Rules
3.1. Processing purposes, categories and list of processed data, subject categories, processing methods and storage periods, data destruction procedure:
3.1.1.1. Purpose: Preparation, conclusion and execution of civil contracts
Categories and list: Last name, first name, patronymic; phone number (work/mobile); email address
Subjects: Website Visitors
Methods: Collection, receipt, recording, systematization, accumulation, storage, updating, retrieval, use, anonymization, transfer, blocking, deletion, destruction
Storage period: 15 years from consent date
Destruction: Overwriting method (replacing all data units with "0") with destruction report
3.1.1.2. Purpose: Market promotion of goods, works, services
[Same structure as above for each purpose with respective details]
3.1.1.3. Purpose: Processing communications between Operator and Data Subject
[Same structure]
3.1.1.4. Purpose: Communication with Data Subject, sending messages/notifications
[Same structure]
3.1.1.5. Purpose: Data analysis to improve Website functionality
Categories: Metrics program data
[Same structure for other elements]

3.1.2. Cookie Technology:
3.1.2.1. Cookies are data fragments sent by the Operator's server and stored on the Personal Data Subject's device. The content may or may not constitute personal data, depending on whether it contains personal or anonymized technical data.
3.1.2.2. The Personal Data Subject may block or restrict cookie reception. Some Website functions may work incorrectly if cookies are disabled. The Personal Data Subject is responsible for configuring their device to achieve desired privacy settings, and the Operator does not provide technical or legal advice on such matters.
3.1.2.3. Cookie usage is regulated as follows:
a) Cookies exclusively controlled by the Operator are processed under this Policy;
b) Third-party cookies (e.g., from software/service providers used by the Operator) are processed under this Policy and the third party's privacy documents, which must include:

• The third party's name
• Cookie handling procedures and conditions
• Contact information for Data Subject inquiries

A) For Website Analytics, the Operator uses the following third-party tools that may utilize cookie technology:
A1) Yandex.Metrica Privacy Policy: https://yandex.ru/legal/confidential

3.2. Procedures and Conditions for Personal Data Processing
3.2.1. Personal data processing means any operation or set of operations performed with personal data, including:

• Collection, receipt, recording
• Systematization, accumulation, storage
• Updating, modification, retrieval
• Use, transfer (provision, access, distribution)
• Anonymization, blocking, deletion, destruction

This Policy establishes:

• Processing purposes
• Categories and list of processed data
• Subject categories
• Processing methods and storage periods
• Data destruction procedures upon achieving purposes or other legal grounds

3.2.2. The Operator may process data:

• Through automated systems
• Through non-automated means

3.2.3. Personal data will be processed only as long as necessary to achieve specific processing purposes.
3.2.4. Upon consent withdrawal/expiration or subject's request to stop processing:

• Data will be blocked from editing
• May be archived for 3 (three) years

3.3. Personal Data Security Measures
3.3.1. The Operator implements all necessary measures to protect personal data against:

• Unauthorized destruction, loss, alteration
• Misuse, disclosure, or illegal processing

3.3.2. By default:

• Data is processed automatically without human access
• When access is required:
• Limited to personnel needing it for processing purposes
• Personnel must comply with internal security protocols

3.3.3. Both automated and non-automated processing locations maintain adequate security.
3.3.4. Disclosure only occurs when legally required (court orders, law enforcement requests, etc.).
3.3.5. The Operator:

• Does not verify data accuracy
• Presumes subjects provide truthful information per:
• Good faith principle
• Article 19 of the Russian Civil Code

3.4. Third-Party Data Transfers
3.4.1. The Operator may transfer data (via access/provision) to:
a) JSC "Tilda Publishing"
Legal entity, Russia
Address: Tsvetnoy Bulvar, 21, bld.1, Moscow
TIN: 9707041449, PSRN: 1247700830354
Data center: Berzarina St., 36, bld.3, Moscow
Website: https://tilda.cc/ru/
b) Yandex LLC
Legal entity, Russia
Address: Lva Tolstogo St., 16, Moscow
TIN: 7736207543, PSRN: 1027700229193
Website: https://yandex.com/
c) Regulatory/law enforcement agencies when legally required
d) Parties providing legal protection to Operator/third parties
e) Third parties when:

• Subject has expressly consented, OR
• Necessary for requested Website functions/services
• Required to fulfill agreements with Subject

Includes cases where Subjects allow cookie usage per:

• Yandex Metrica/AppMetrica Terms (https://yandex.ru/legal/metrica_termsofuse)
• Yandex Privacy Policy (https://yandex.ru/legal/confidential)

Yandex LLC
Website: https://yandex.ru
Address: 119021, Lva Tolstogo St., 16, Moscow
Email: support@yandex.ru
Subjects may disable cookies via browser settings or leave the Website.
3.4.2. Public dissemination to unlimited parties is prohibited.
3.4.3. Subjects may exercise transfer-related rights:

• Through Website settings/functions
• Via written request to Operator's email if Website options are insufficient

3.5. Rights and Obligations
3.5.1. Representatives:

• May only authorize/restrict third-party data processing with legal authority (e.g., parents, guardians) or contractual rights (e.g., power of attorney)
• Must compensate Operator for damages caused by unauthorized representations

3.5.2. Subject Obligations:

• Maintain data accuracy and timeliness
• Operator not liable for inaccuracies

3.5.3. Data Modification Procedures:
a) Updates/corrections:

• Via account functions, OR
• Written request to Operator's email

b) Blocking/deletion:

• Via account functions, OR
• Written request

c) Other rights exercised similarly
3.5.4. Key Subject Rights:

• Request processing information
• Withdraw consent
• Demand processing restrictions
• Request cessation where legally permitted

3.5.5. Request Handling:

• Submit to Operator's contact details in this Policy
• Response within 10 business days
• Right to escalate to data protection authorities

3.5.6. Consent Withdrawal:

• Written notice to Operator's email/postal address
• Operator follows Russian legal procedures

3.6. Storage & Cross-Border Transfer Rules
3.6.1. Russian citizens' data is processed using Russian-based databases.
3.6.2. Before cross-border transfer, Operator must:

• Verify recipient country provides adequate data protection
• Notify Russian data protection authorities

3.6.3. For transfers to non-compliant jurisdictions:

• Requires prior authorization from Russian data protection authorities

4. Notifications & Communications
4.1. Subject agrees to receive Operator communications via provided email/phone ("Notifications").
4.2. Unsubscribing:
a) Click "Unsubscribe" in emails, OR
b) Email Operator

• Takes effect within 24 hours

4.3. Notification Purposes:
a) Website functionality updates
b) Policy/document changes
c) Informational messages
d) Promotional content
4.4. Subject must send all official communications to Operator's email in this Policy.
4.5. Operator may request paper documents when legally significant:

• Mail to Operator's address in this Policy

5. Policy Amendments. Governing Law. Interpretation
5.1. Policy Changes
The Operator reserves the right to amend this Policy. The current version will indicate the date of last update. The revised Policy becomes effective immediately upon publication, unless otherwise specified in the new version. Previous versions remain archived at the Policy's designated address.
5.2. Notification of Changes
The Operator may notify Subjects who previously consented to the Policy about amendments. Notification methods will ensure compliance with the principle that consent must be:

• Specific
• Substantive
• Informed
• Conscious
• Unambiguous

5.3. Jurisdiction and Governing Law

• Place of Consent and Policy Execution: Always the Operator's registered address
• Applicable Law: Russian law governs all Operator-Subject relations, regardless of:
• Subject's location
• Equipment used
• Dispute Resolution: All disputes shall be resolved at the Operator's location, unless otherwise required by law

5.4. Policy Duration

• Becomes effective upon Subject's consent
• Remains in force indefinitely
• Indefinite Policy validity does not imply unlimited data processing periods
• Unilateral termination by either party is prohibited

5.5. Interpretation Rules
5.5.1. The terms "agreement" and "contract" are interchangeable.
5.5.2. The phrases "include", "includes", "including", "for example", "such as", or similar expressions shall always be construed as "without limitation", preserving the general scope of preceding terms.

6. Operator Details


6. Exercising Personal Data Subject Rights
6.1. Contact Information for Rights Execution
The Personal Data Subject may exercise all rights granted to data subjects under applicable law, including obtaining clarifications regarding personal data processing, by contacting the Operator:

• Email: [Operator's email address specified in the Policy]
• Postal Mail: [Operator's physical address specified in the Policy]

7. Document Information
7.1. Publication Date of Current Version: May 30, 2025