Privacy-policy

1. General Provisions

1.1. This Personal Data Processing Policy (hereinafter — the “Policy”) defines the procedure for the processing and protection of personal data of individuals when using the website https://lagutenko.com (hereinafter — the “Website”) by the personal data operator Lagutenko Denis Nikolaevich (hereinafter — the “Operator”).
1.2. The Policy has been developed in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and the Protection of Information”, and other applicable regulatory legal acts of the Russian Federation.
1.3. The Policy applies to personal data and technical information that the Operator receives through forms on the Website, web analytics tools, as well as in connection with users’ inquiries regarding cooperation and partnership.
1.4. Personal data is considered confidential information and is subject to protection against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions.

2. Principles of Personal Data Processing

• processing is carried out on lawful and fair grounds;
• processing is limited to the achievement of specific, predetermined, and lawful purposes;
• combining databases in which processing is carried out for incompatible purposes is not permitted;
• only personal data corresponding to the purposes of processing is processed, without excess;
• the accuracy, sufficiency, and, where necessary, relevance of personal data are ensured;
• personal data is stored no longer than required by the purposes of processing, unless another period is established by law or agreement.

3. Personal Data, Purposes and Grounds for Processing

3.1. Cooperation and Partnership Requests

The Website provides a request form for discussing cooperation and partnership. When filling out the form, the following information may be processed:
• user’s name and/or company name;
• email address;
• field of activity;
• website and/or social media links;
• substance of the proposal;
• attached file, if the user has uploaded it independently (including information contained in such file);
• confirmation and fact of consent to the processing of personal data and this Policy.
Technically, when submitting the form, the following may also be recorded:
• date and time of submission of the request;
• IP address;
• browser and device data;
• Website page from which the form was submitted.
Purposes of processing: receiving and reviewing inquiries, requests, and proposals; communicating with the user; discussing potential cooperation or partnership; recording the fact of consent to the processing of personal data.
Legal grounds for processing: consent of the personal data subject; where applicable — taking actions to conclude an agreement at the initiative of the personal data subject.
In relation to the specified data, the Operator may perform collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision of access), blocking, deletion, and destruction using automation tools or without their use.

3.2. Web Analytics Data and Cookies

The “Yandex Metrica” service is used to collect and analyze information about the use of the Website, its performance, as well as to improve its content and functionality. As part of web analytics, the following may be processed:
• cookies;
• IP address;
• information about the browser, device, and operating system;
• source of the visit to the Website;
• pages visited;
• date and time of the visit;
• user actions on the Website in statistical form.
The basis for processing web analytics data is the user’s consent expressed through the consent mechanism for the use of cookies/analytics provided on the Website.
The “Yandex Metrica” service is used only in basic mode, without Webvisor, session recording, retargeting, and advertising segments.
Information processed by the “Yandex Metrica” service may be stored and processed by YANDEX LLC (TIN 7736207543, 119021, Russia, Moscow, 16 Lev Tolstoy St.) in accordance with the rules and terms of the respective service.

4. Collection and Sources of Personal Data

4.1. Personal data provided by the user in the form is collected directly from the personal data subject.
4.2. Technical information and web analytics data may be collected automatically when visiting and using the Website.
4.3. If the provision of certain information or obtaining consent is mandatory under applicable law, the user is informed of the legal consequences of refusing to provide such information or consent.

5. Storage of Personal Data and Infrastructure Used

5.1. The Website is implemented on WordPress. WordPress is used as a content management system (CMS) hosted on separate hosting dedicated to the Website and, by itself, is not an external cloud service for storing requests.
5.2. User requests are stored in the administrative part of the Website (WordPress) on a separate account of the Hostinger hosting provider. The country where the server is located is Germany .
5.3. Backups of the Website and database are created using the hosting provider’s tools and stored on Hostinger hosting for 7 days.
5.4. When a form is submitted, all information from the request is stored in the administrative part of the Website and fully duplicated to the Operator’s email address den@adsbase.com.
5.5. The Gmail email service provided by Google LLC (USA) is used to receive data from the form. The Operator’s email address is den@adsbase.com.
5.6. In addition to the “Yandex Metrica” and Gmail services, at the current stage, Google Analytics, Meta/Facebook Pixel, reCAPTCHA, external CRMs, Google Sheets, or other third-party services for storing requests are not used. If such services are connected, this Policy shall be updated.

6. Processing and Storage Periods

6.1. Personal data is processed and stored no longer than required by the purposes of processing, unless a longer period is established by the legislation of the Russian Federation or by agreement.
6.2. Requests stored in the administrative part of the Website (WordPress) are kept until manually deleted by an administrator or editor. Automatic deletion of requests is not applied. Copies of requests sent to the Operator’s email address are stored no longer than required by the purposes of processing, unless a longer period is established by the legislation of the Russian Federation or by agreement.
6.3. Upon achievement of the purpose of processing, withdrawal of consent (if there are no other legal grounds for continuing the processing), or the occurrence of other grounds provided for by law, processing is terminated, and the data is deleted or destroyed within the periods established by law.

7. Transfer of Personal Data

7.1. Personal data is transferred to third parties only when there is a legal basis, including the consent of the subject, the necessity to perform or conclude an agreement at the initiative of the subject, or in cases expressly provided for by the legislation of the Russian Federation.
7.2. As part of the operation of the Website, access to data to the extent necessary to provide the relevant services may be obtained by the hosting provider, email provider, and web analytics service provider.

8. External Links and Platforms

8.1. The Website may contain links to external platforms, including Telegram, YouTube, LinkedIn, and Instagram.
8.2. When submitting a form, the Website itself does not transfer the user’s personal data to the specified social networks and messengers. When the user independently follows an external link, further interaction takes place on the respective platform and is governed by its rules and policies.

9. Rights of the Personal Data Subject

9.1. The personal data subject has the right to receive information about the processing of their personal data, including information about the purposes, legal grounds, methods, and periods of processing and storage, as well as persons who have access to the data or receive it on lawful grounds.
9.2. The subject has the right to request the clarification, blocking, or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing.
9.3. The subject has the right to withdraw previously provided consent to the processing of personal data. Withdrawal and other requests regarding the processing of personal data shall be sent to: den@adsbase.com.
9.4. The Operator considers requests from personal data subjects within the time limits and in accordance with the procedure provided for by the legislation.

10. Protection of Personal Data

10.1. The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions.
10.2. Access to personal data is provided only to persons who need it to perform the relevant functions and duties.
10.3. When operating the Website, access control and authentication measures, SSL/TLS encryption, DDoS protection, as well as other security measures provided by the configuration of the Website and server are applied.

11. Actions in the Event of Incidents

11.1. Upon detection of an unlawful or accidental transfer (provision, dissemination, access) of personal data resulting in a violation of the rights of subjects, the Operator takes the measures provided for by law to localize and eliminate the consequences of the incident.
11.2. In cases provided for by the legislation of the Russian Federation, the Operator notifies Roskomnadzor of the relevant incident within the time limits established by law.

12. Final Provisions

12.1. Unlimited access to this Policy is provided by posting it on the Website.
12.2. The Operator has the right to make changes to the Policy. The new version comes into force from the moment it is posted on the Website, unless otherwise provided by the new version.
12.3. If the composition of the data collected, purposes of processing, services used, storage methods, hosting provider, or other significant parameters of processing change, the Policy shall be updated.

13. Information about the Operator

Operator: Lagutenko Denis Nikolaevich
Status: individual
TIN: 772403353430
Operator’s address: 115093, Moscow, Lyusinovskaya St., 26–28, Bldg. 6
Website: https://lagutenko.com
E-mail for inquiries regarding personal data: den@adsbase.com