PRIVACY POLICY (PERSONAL DATA PROCESSING POLICY)
Version of 30 August 2026.
1. GENERAL PROVISIONS
1.1. This Policy defines the procedure for processing personal data and the measures taken to ensure their security by Individual Entrepreneur Popova Elena Gennadievna (hereinafter — the Operator).
1.2. The Policy has been developed in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and constitutes performance of the obligation established by Part 2 of Article 18.1 of the said law.
1.3. The Policy applies to all personal data that the Operator receives from data subjects through the website elenreflecta.ru, through the online learning platform, through messengers and by e-mail.
1.4. Use of the website constitutes the user’s agreement with this Policy. If the user does not agree, they should stop using the website.
2. OPERATOR DETAILS
Individual Entrepreneur Popova Elena Gennadievna
OGRNIP: 304667030000104
INN: 666000434853
Address: 4-1 Vostochnaya Street, Malinovka village, Dalmatovsky District, Kurgan Region, 641756, Russia
E-mail for enquiries: elenreflecta@gmail.com
Person responsible for organising the processing of personal data: Popova Elena Gennadievna
3. KEY DEFINITIONS
Personal data — any information relating to a directly or indirectly identified or identifiable natural person.
Processing of personal data — any action or set of actions performed on personal data, with or without the use of automation tools.
Data subject — a natural person to whom the personal data relate.
User — a person using the Operator’s website.
4. CATEGORIES OF DATA SUBJECTS AND SCOPE OF DATA PROCESSED
4.1. Website visitors who submit an enquiry through the contact form: name, e-mail address, content of the enquiry.
4.2. Buyers of photographic prints: surname, name, e-mail address, telephone number, delivery address, order and payment details, Telegram username — where contact is made through it.
4.3. Buyers of access to the online course: surname, name, e-mail address, telephone number, order and payment details, account data, course progress data.
4.4. Subscribers to the newsletter: name, e-mail address.
4.5. Technical data of all website visitors: IP address, browser and device information, cookies, web analytics data.
4.6. The Operator does not process special categories of personal data, biometric personal data, or data of persons under eighteen years of age.
5. PURPOSES OF PROCESSING
5.1. Conclusion and performance of contracts for the sale of photographic prints, including arranging delivery.
5.2. Conclusion and performance of contracts for the provision of information and consulting services — granting access to the online course and supporting learners.
5.3. Handling enquiries received through the contact form, by e-mail and through messengers.
5.4. Sending informational and advertising messages — solely where the data subject has given separate consent.
5.5. Fulfilment of tax obligations, issuing cash receipts and maintaining accounting records.
5.6. Improving the operation of the website and analysing traffic in anonymised form.
6. LEGAL GROUNDS FOR PROCESSING
The Constitution of the Russian Federation; the Civil Code of the Russian Federation; the Tax Code of the Russian Federation; Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”; Federal Law No. 54-FZ of 22 May 2003 “On the Use of Cash Register Equipment”; Law of the Russian Federation No. 2300-1 of 7 February 1992 “On Protection of Consumer Rights”; Federal Law No. 38-FZ of 13 March 2006 “On Advertising”; contracts concluded between the Operator and data subjects; consents of data subjects.
7. PRINCIPLES AND CONDITIONS OF PROCESSING
7.1. Processing is carried out on a lawful and fair basis, is limited to the achievement of the stated purposes, and the content and scope of the data processed correspond to the stated purposes and are not excessive.
7.2. The Operator does not combine databases whose processing is carried out for mutually incompatible purposes.
7.3. Processing is carried out by mixed means — with and without the use of automation tools.
7.4. The Operator does not take decisions producing legal effects in respect of a data subject solely on the basis of automated processing.
8. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
8.1. The Operator entrusts the processing of personal data to the following parties on the basis of contracts containing a confidentiality undertaking and data protection requirements (Part 3 of Article 6 of Federal Law No. 152-FZ):
— OOO Perspektiva (the Wfolio service), INN 7806518351, OGRN 1147847022564 — hosting and operation of the website elenreflecta.ru: contact form data, technical data;
— OOO Sistema Getkurs (the GetCourse platform), INN 9731055900, OGRN 1197746675170 — hosting the online course, receiving orders, granting access: name, e-mail address, telephone number, order and course progress data;
— the fiscal data operator — generating and transmitting cash receipts: the buyer’s e-mail address or telephone number, settlement details;
— the acquiring bank and payment service — accepting payments; card details are not transferred to the Operator;
— delivery services, including CDEK — delivery of prints: surname, name, telephone number, delivery address.
8.2. The Operator transfers personal data to state authorities on the grounds and in the manner established by the legislation of the Russian Federation.
8.3. The Operator does not sell or transfer personal data to third parties for any other purposes, including advertising, without the data subject’s consent.
9. STORAGE LOCATION AND CROSS-BORDER TRANSFER
9.1. Databases containing the personal data of citizens of the Russian Federation are located on servers situated within the territory of the Russian Federation (Part 5 of Article 18 of Federal Law No. 152-FZ).
9.2. The Operator does not carry out cross-border transfer of personal data.
10. PROCESSING AND STORAGE PERIODS
10.1. Data are processed until the purposes of processing are achieved or until the data subject withdraws consent.
10.2. Data relating to performed contracts and settlements are stored for the periods established by tax and accounting legislation — not less than five years.
10.3. Newsletter subscribers' data are stored until consent to receive the newsletter is withdrawn.
10.4. Once the purposes of processing have been achieved, or upon withdrawal of consent, personal data are destroyed within a period not exceeding thirty days, unless otherwise provided by law.
11. RIGHTS OF THE DATA SUBJECT
11.1. The data subject has the right to: obtain information about the processing of their personal data; demand that data be clarified, blocked or destroyed if they are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose; withdraw consent to processing; opt out of the newsletter; appeal against the Operator's actions to Roskomnadzor or in court.
11.2. Enquiries should be sent to elenreflecta@gmail.com or by post to the Operator's address. The enquiry must contain the data subject's full name, information confirming their interaction with the Operator, and the signature of the data subject or their representative.
11.3. The Operator responds to an enquiry within ten working days of receipt. This period may be extended by no more than five working days, with notice to the data subject of the reasons for the extension.
11.4. You can unsubscribe from the newsletter using the “Unsubscribe” link in every message — no request to the Operator is required.
12. SECURITY MEASURES
The Operator takes the following measures: a person responsible for organising the processing of personal data has been appointed; this Policy has been issued and published, with unrestricted access to it provided; the list of persons with access to personal data has been defined; password protection of accounts and two-factor authentication are applied where available; licensed software and anti-virus protection are used; data transmission over the secure HTTPS protocol is ensured; machine media containing personal data are recorded; internal control of compliance of processing with legal requirements is carried out; work is conducted only with platforms that store data within the territory of the Russian Federation.
13. FINAL PROVISIONS
13.1. The Operator may amend this Policy. A new version takes effect from the moment it is published on the website.
13.2. The current version is permanently available on the website https://elenreflecta.ru.
13.3. Matters not covered by this Policy shall be resolved in accordance with the legislation of the Russian Federation.
This is a translation provided for convenience. In the event of any discrepancy, the Russian version of this Policy shall prevail.