Privacy and Personal Data Processing Policy

Version dated July 31, 2026.

This is a courtesy translation. In case of any discrepancy, the Russian version of this policy prevails.

1. General provisions

This policy is drawn up in accordance with the Russian Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and describes how personal data of users of the Polka Nastolok website at https://polkanastolok.ru (the “Site”) is processed and protected.

Personal data operator: Proshin Boris (the “Operator”). Contact for personal data inquiries: support@polkanastolok.ru.

The Site is provided free of charge. The Operator provides no paid services and accepts no payments.

By signing up for and using the Site, the user accepts this policy and consents to the processing of their personal data under the terms set out in it.

2. What data is processed

Account data:

Data that arises from using the Site:

Technical data transmitted automatically:

The Site does not collect special categories of personal data or biometric data. Providing a first and last name, date of birth and username is voluntary: the Site works without them, except for the features named in section 3.

3. Purposes of processing

4. Legal grounds for processing

Processing is based on the user’s consent given at sign-up and on the necessity to provide the user with the Site’s functionality.

Web analytics data is processed solely on the basis of separate consent, which the user gives in the cookie notice and may withdraw at any time (section 6).

5. Who processes the data on the Operator’s behalf

To provide the Site, the Operator engages the following parties that process personal data on its behalf:

The Operator collects, records, organizes, accumulates, stores, updates, retrieves, uses, blocks, deletes and destroys personal data by automated means.

Personal data is not shared with any other third parties except where required by the laws of the Russian Federation and in the case described in section 8.

Personal data is kept until the user’s account is deleted or consent is withdrawn. Technical logs are kept no longer than six months from the moment they are recorded.

6. Cookies and web analytics

Necessary cookies are always active; the Site does not work without them:

In addition, the user’s analytics choice is stored in the browser’s local storage, so that the question is not asked on every visit.

Analytics cookies are only enabled after the user has pressed “Accept” in the cookie notice. The Site uses Yandex.Metrica (OOO “YANDEX”). Metrica collects information about visited pages, actions on them, the referral source, as well as the IP address and browser and device information. Until consent is given, the Metrica script is not loaded and no data is collected.

The user may decline analytics outright or withdraw consent given earlier: it is enough to clear the Site’s data in the browser settings — the notice will appear again, and “Necessary only” can be chosen in it. Declining analytics does not affect how the Site works.

No advertising trackers are used on the Site. No advertising is placed on the Site.

7. User rights

The user has the right to:

To exercise these rights, send a request to support@polkanastolok.ru from the email address used at registration. The Operator responds within the period required by law, and no later than 10 business days from the request. Withdrawing consent or deleting the account terminates access to the Site.

8. Push notifications and cross-border transfer

If the user has subscribed to push notifications, they are delivered through the push service of the user’s own browser — Google (Firebase Cloud Messaging) for Chromium-based browsers, Mozilla for Firefox, Apple for Safari. The servers of these services are located outside the Russian Federation.

Such a service receives the subscription endpoint it issued itself and the text of the notification. The email address, password, collection contents and other data from section 2 are not transferred.

The Operator carries out no other cross-border transfer of personal data: everything else is stored and processed within the Russian Federation.

This transfer can be declined by turning push notifications off in the Site’s or the browser’s settings. This does not affect the rest of the functionality.

9. What other users can see

Some data is by its nature visible to other users of the Site:

The user controls this themselves: by not providing optional data, not adding friends and not opening up collections.

10. Data protection

The Operator takes the necessary organizational and technical measures to protect personal data from unauthorized access, alteration, disclosure or destruction: the connection to the Site is protected by HTTPS, passwords are stored only in hashed form, and access to the infrastructure is restricted.

11. Final provisions

The Operator may update this policy. The new version is published on this page with its revision date. Continued use of the Site after a new version is published constitutes acceptance of it.

This policy is published in Russian and English. The Russian version is the legally binding one; the English version is provided for convenience, and in case of any discrepancy the Russian text applies.

Questions about this policy can be sent to support@polkanastolok.ru.