Privacy Policy
1. General Provisions
1.1. This Personal Data Processing Policy (the «Policy») sets out the procedure and conditions for processing the personal data of users of anotherperson.ru (the «Website») by Individual Entrepreneur Pavel Andreyevich Potseluev (the «Controller»).
1.2. The Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 «On Personal Data», other laws and regulations of the Russian Federation, and the recommendations of Roskomnadzor.
1.3. The Policy applies to all personal data that the Controller receives through the Website, contact forms and applications for events or services, as well as through subsequent communications using the contact details provided by the user.
1.4. The personal data controller is Individual Entrepreneur Pavel Andreyevich Potseluev. OOO PERSPEKTIVA, which provides the Wfolio platform, is not the controller of Website visitors’ personal data and processes such data on the Controller’s instructions to the extent necessary for the operation of the Website and its forms.
1.5. Use of the Website without completing any forms does not constitute consent to personal data processing where consent is required by law. Consent is given by a separate affirmative action of the user.
1.6. The Policy takes effect on the date of its publication on the Website. The current version is permanently available on the Privacy Policy page at: anotherperson.ru/en/legal-privacy
2. Key Terms
2.1. Personal data means any information relating directly or indirectly to an identified or identifiable individual.
2.2. Personal data processing means any operation or set of operations performed on personal data, including collection, recording, organization, accumulation, storage, updating, retrieval, use, disclosure, restriction, erasure and destruction.
2.3. User means an individual who visits the Website, sends a message or application, or enters into a contractual relationship with the Controller.
2.4. Cookies are small data files stored by the user’s browser and used to operate the Website, retain selected settings and analyze Website traffic.
3. Processing Principles
3.1. The Controller processes personal data lawfully and fairly, solely for predetermined purposes and only to the extent necessary to achieve those purposes.
3.2. Processing that is incompatible with the purposes for which personal data was collected, combining databases created for incompatible purposes, and retaining personal data for longer than required by the processing purposes or applicable law are not permitted.
3.3. The Controller ensures the accuracy and relevance of personal data and takes measures to erase or correct incomplete or inaccurate data.
4. Categories of Data Subjects and Personal Data
4.1. The Controller may process the personal data of Website visitors, persons who send a message or application, customers and course participants, customer representatives, and counterparties.
4.2. When forms are completed, the following data may be processed: name; telephone number; email address; username or link to a social media or messenger profile; message content; and information about the selected service or event.
4.3. In connection with entering into and performing a contract, the following data may also be processed: surname, first name and patronymic; identification document details and other information where objectively required by law or for a particular contract; payment information without storage of full bank card details; and correspondence and documents relating to contract performance.
4.4. When the Website is visited, the following technical data may be processed: IP address; date and time of access; requested page and referring page; browser and operating system type; device type; language; approximate region; cookie identifiers; and information about actions performed on the Website.
4.5. The Controller does not intend to collect special categories of personal data, biometric data, or information about minors through the Website. Users should not provide such information in free-text form fields.
5. Purposes, Legal Bases and Retention Periods
5.1. Processing enquiries and applications. Purpose: receiving a message, identifying the sender to the extent necessary to respond, providing feedback, preparing an offer, and organizing negotiations. Data: the information specified in Clauses 4.2 and 4.4. Legal basis: the user’s separate consent and steps taken at the user’s request prior to entering into a contract. If no contract is entered into, the data is erased no later than one year after the last substantive interaction, unless there is a dispute or another lawful basis for retention.
5.2. Entering into and performing a contract. Purpose: booking, service delivery, payments, sending organizational information, refunds, and handling claims. Data: the information specified in Clauses 4.2–4.3. Legal basis: entering into and performing a contract to which the data subject is a party or beneficiary, and compliance with legal requirements. Contractual data is retained for the term of the contract and applicable limitation periods; accounting and tax records are retained for the periods prescribed by law.
5.3. Website operation and security. Purpose: correct page display, protection against abuse, error diagnosis, and information security. Legal basis: the Controller’s legitimate interests, provided that users’ rights are respected, and user consent where applicable. Technical logs are retained for no longer than twelve months unless a longer period is required to investigate an incident or comply with the law.
5.4. Traffic analysis. Purpose: obtaining statistics and improving the Website’s structure using Yandex Metrica. When a page is opened, the Yandex Metrica code may load automatically and process the technical data listed in Clause 4.4. Legal basis: the Controller’s legitimate interest in maintaining and improving the Website, provided that the user’s rights are respected; where consent is required by law, the user’s consent. The processing period is determined by the lifetime of the relevant cookies and the service settings but does not exceed twelve months unless a longer period is required by law.
5.5. Consent given through a contact form is not used as a basis for advertising or informational mailings. The Controller obtains separate consent for such communications, which may be withdrawn at any time.
6. Processing Procedures and Methods
6.1. Processing is performed by automated, non-automated and mixed means.
6.2. The Controller may perform the following operations: collection, recording, organization, accumulation, storage, updating, retrieval, use, disclosure to persons acting on the Controller’s instructions, restriction, erasure and destruction.
6.3. Personal data is not made available to the general public or published without a separate lawful basis or separate consent to dissemination.
6.4. Once the processing purpose has been achieved, the retention period has expired, or consent has been withdrawn, personal data is destroyed or anonymized unless the Controller is entitled or required to continue processing it on another lawful basis.
7. Parties Involved in Processing
7.1. The Controller uses the Wfolio platform to host the Website, operate forms and store messages: OOO PERSPEKTIVA, OGRN 1147847022564, INN 7806518351, registered address: Office 115, 8 Belorusskaya Street, St Petersburg 195298, Russian Federation. OOO PERSPEKTIVA processes Website visitors’ personal data on the Controller’s instructions.
7.2. Traffic analysis is performed using Yandex Metrica, provided by OOO YANDEX, OGRN 1027700229193, registered address: 16 Leo Tolstoy Street, Moscow 119021, Russian Federation. Counter number: 96561515.
7.3. The Controller’s assistants and persons involved in organizing a course may access enquiries only to the extent necessary, under written instructions, a contract or another lawful basis, and subject to confidentiality obligations.
7.4. Personal data may be disclosed to public authorities in the cases and in accordance with the procedures prescribed by the laws of the Russian Federation.
7.5. The Controller does not use Google Analytics and does not intentionally transfer personal data across national borders. Before commencing any such transfer, the Controller will comply with applicable legal requirements, notify Roskomnadzor where required, and update this Policy.
8. Cookies and Yandex Metrica
8.1. Strictly necessary cookies are used to operate Website pages and retain the user’s choices. Disabling such cookies in the browser may impair certain Website functions.
8.2. The Yandex Metrica code may load automatically when Website pages are opened. The cookie notice informs users about the use of cookies and contains a link to this Policy.
8.3. Users may delete or block cookies in their browser settings. Restricting cookies may affect certain Website functions but must not prevent access to its main content.
8.4. Yandex Metrica may receive the technical data listed in Clause 4.4 and record an anonymized sequence of actions on Website pages. The Controller ensures, through field masking and appropriate Webvisor settings, that data entered by users into form fields is not transmitted to Yandex Metrica.
9. Data Localization and Security
9.1. When personal data of citizens of the Russian Federation is collected, its recording, organization, accumulation, storage, updating and retrieval are performed using databases located in the Russian Federation.
9.2. The Controller implements the necessary legal, organizational and technical safeguards, including access restrictions, passwords and multi-factor authentication where available, backups, monitoring of actions involving personal data, software updates, and an incident response procedure.
9.3. Persons authorized to process personal data are granted access only to the extent required for their duties and must maintain confidentiality.
10. User Rights
10.1. Users have the right to obtain information about the processing of their personal data; request its correction, restriction or destruction; object to processing; withdraw consent; and lodge a complaint against the Controller with Roskomnadzor or a court.
10.2. Withdrawal of consent does not affect the lawfulness of processing performed before the withdrawal was received and does not prevent processing that the Controller is entitled to continue under a law or contract.
10.3. To exercise these rights, the user may contact pavel@potseluev.ru or write to the Controller’s postal address. The request must make it possible to identify the applicant and their relationship with the Controller; the Controller may request reasonable proof of identity without collecting excessive data.
10.4. The Controller considers requests and complies with lawful requirements within the periods prescribed by the laws of the Russian Federation.
11. Amendments to the Policy
11.1. The Controller may amend the Policy following changes in legislation, the services used, or processing activities. A new version takes effect on the date of publication unless it specifies otherwise.
11.2. An amendment to the Policy does not by itself modify consent previously given. If the purposes, categories of data, or other material conditions of consent-based processing change, the Controller will obtain new consent.
11.3. Policy version: 1.1. Publication date: 4 July 2026.
Controller Details
Information
Value
Controller / Service Provider: Individual Entrepreneur Pavel Andreyevich Potseluev
OGRNIP: 318774600329858
INN: 772784434759
Registration Authority: Interdistrict Inspectorate of the Federal Tax Service No. 46 for Moscow
Registered Address: Apt. 97, 6 Kolomenskaya Embankment, Moscow, Russian Federation
Email: pavel@potseluev.ru
Website: anotherperson.ru