Personal data processing policy
Version 1.0. Effective from the publication date.
This is an English translation for convenience. The original Russian document is available on the Russian version of the site. Russian original
1. Operator and scope
The personal data operator is ESVI DIGITAL LLC, Russian Tax ID 7816765279, Russian State Registration Number 1267800069921. Address: 192286, Saint Petersburg, Georgievsky Municipal District, 59 Bukharetskaya Street, Building A, Apartment 41. For questions about personal data processing, contact info@aswemay.ru.
This policy applies to visitors of aswemay.ru and aswemay.digital, including people who send enquiries through the contact form.
2. Purposes, data and legal grounds
| Purpose | Whose data and what information is processed | Legal ground and retention period |
|---|---|---|
| Receive and answer an enquiry | People submitting the form. Email address, nickname, date and time of the enquiry. | The user’s separate consent, clause 1, part 1, article 6 of Federal Law No. 152-FZ. Until the purpose is achieved, but no longer than 12 months after the last substantive contact about the enquiry. If there was no answer or further communication, the period starts on the enquiry date. |
| Confirm receipt of consent | People submitting the form. The fact, date, time and version of consent, linked to the enquiry. | The operator’s duty to confirm receipt of consent, part 3, article 9 of Federal Law No. 152-FZ. The record is retained while the corresponding enquiry is processed. |
| Keep the website secure and operational | Website visitors. IP address, request date and time, and technical request details recorded in logs. | The operator’s legitimate interest in website security while respecting users’ rights, clause 7, part 1, article 6 of Federal Law No. 152-FZ. Up to 90 days. |
| Remember the cookie choice | Website visitors. The selected cookie setting. | To provide the user’s settings. The choice is stored in the browser for up to 12 months or until it is changed or deleted. |
| Understand how visitors use the website | Visitors who allow analytics. Cookie identifiers, IP address, device and browser information, viewed pages, actions and referral sources. | Separate consent to analytics, clause 1, part 1, article 6 of Federal Law No. 152-FZ. Collection stops upon withdrawal. Individual cookie lifetimes are listed in the cookie rules and the counter documentation. |
The email address from the form is used to answer the enquiry. This consent does not permit its use for promotional mailings.
3. How data is processed and protected
The operator collects, records, systematises, stores, retrieves, uses and, where necessary, blocks, deletes and destroys data using automated tools. Authorised persons can access enquiries through a restricted administration interface. Form data is stored in a database within the Russian Federation.
When analytics is enabled, visit information is processed using Yandex Metrica. Email addresses and nicknames from the form are not sent to analytics. Analytics controls are described in the separate cookie rules.
The operator takes organisational and technical protection measures required by law. Once the purpose is achieved or consent is withdrawn, the operator stops processing on that ground and destroys the data within the periods provided by article 21 of Federal Law No. 152-FZ, unless further processing is required on another legal ground.
4. User rights and withdrawal of consent
Users may request information about the processing of their personal data, request its correction, blocking or destruction in cases provided by law, withdraw consent, and challenge the operator’s actions before Roskomnadzor or a court.
Send requests or withdrawals to info@aswemay.ru and identify the relevant enquiry. The operator may request information needed to confirm the identity and authority of the person making the request. Consent to web analytics can be withdrawn under “Cookie settings”.
The current version of this policy is published on the website.