This English version is a translation provided for convenience. The Russian version of this document is the governing one: in case of any discrepancy between the English and Russian versions, the Russian version prevails.
Revised October 22, 2026.
1. General provisions
1.1. This Personal Data Processing Policy (the «Policy») is drawn up in accordance with Federal Law No. 152-FZ of July 27, 2006 «On Personal Data» (the «Personal Data Law»). The Policy sets out how personal data is processed and the measures taken to protect it when using the website https://organicops.ru (the «Website»).
1.2. Personal data controller (the «Controller»): Individual Entrepreneur Pryakhin Leonid Alekseevich, OGRNIP 324774600652732, INN 771873192877. E-mail address for personal data inquiries: step.el3@yandex.ru.
1.3. The Policy applies to personal data that the Controller processes in connection with the operation of the Website. Third-party websites linked from the Website are not covered by the Policy.
1.4. The Policy is published at https://organicops.ru/en/privacy-policy/ in accordance with Part 2, Article 18.1 of the Personal Data Law.
2. Key terms
Terms are used in the meanings established by Article 3 of the Personal Data Law:
- personal data — any information relating to a directly or indirectly identified or identifiable individual (a personal data subject);
- processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not using automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, amendment), extraction, use, transfer (disclosure, provision, access), de-identification, blocking, erasure, and destruction;
- automated processing of personal data — the processing of personal data using computing equipment;
- cookies — small text files that a website saves in the user’s browser (for details, see the Cookie Policy).
3. Principles of processing
The Controller processes personal data:
- lawfully and fairly, for specific, predetermined, and legitimate purposes;
- to the extent necessary for those purposes, avoiding excess;
- ensuring the accuracy and adequacy of the data and, where necessary, its relevance to the purposes;
- keeping it no longer than the purposes of processing require, unless a retention period is set by federal law or by a contract;
- without combining databases whose processing is carried out for incompatible purposes.
4. Purposes, categories of data, legal grounds, and retention periods
4.1. Operation and security of the Website
- Data: IP address, date and time of the request, address of the requested page, server response code and size, the referring page address, and browser and operating system information (User-Agent).
- How it is collected: automatically, in web server logs and system server logs whenever the Website is accessed.
- Legal basis: processing is necessary to exercise the Controller’s rights and legitimate interests — keeping the Website operational and secure (Clause 7, Part 1, Article 6 of the Personal Data Law), provided the rights and freedoms of the subject are not violated.
- Retention period: web server logs and system logs containing IP addresses and other technical identifiers are kept for no more than 30 days and are then deleted automatically.
- The logs are not used to identify visitors and are not disclosed to third parties, except as provided by law.
4.2. Inquiries via Telegram and e-mail
- Channels: the Controller’s account @orgnops in the Telegram messenger (the link https://t.me/orgnops on the Website) and the e-mail address step.el3@yandex.ru. Following the link takes the visitor away from the Website; correspondence in Telegram takes place within the Telegram service, which processes its users’ data under its own rules.
- Data: name or display name, Telegram username, phone number (if the user has made it available), e-mail address, the content of the inquiry, and any other data the sender provides on their own initiative.
- Legal basis: the subject’s consent (Clause 1, Part 1, Article 6 of the Personal Data Law); if the inquiry concerns entering into a contract — processing necessary to conclude a contract at the subject’s initiative (Clause 5, Part 1, Article 6).
- Retention period: correspondence with a person with whom no contract has been concluded is kept for 1 year from the date of the last message, unless there is another lawful ground for retention. If a contract has been concluded, the data is kept for the periods required by the accounting, tax, and other mandatory legislation of the Russian Federation.
- Please do not send data that is not needed for a response: passport details, health information, or other special categories of personal data.
4.3. Requests submitted through forms on the Website
The request form is published on the Contacts page (/contacts/; English version — /en/contacts/). Requests are stored in the Website database; a copy of a request may be sent to the Controller’s e-mail address step.el3@yandex.ru.
- Data: the information the visitor enters in the form fields: name, e-mail address and/or phone number, and the text of the inquiry.
- Legal basis: the subject’s consent (Clause 1, Part 1, Article 6 of the Personal Data Law), recorded in a separate document — the Personal Data Processing Consent.
- Retention period: requests are kept for 1 year, unless there is another lawful ground for retention. Records of the fact of consent (date, document revision, form) are kept for the duration of the corresponding processing and for 3 years after it ends — to confirm that consent was obtained (Part 3, Article 9 of the Personal Data Law).
4.4. Web analytics (Yandex Metrica)
- Purpose: analyzing traffic and improving the Website.
- How it works: a Yandex Metrica counter is installed on every page of the Website. It loads when a page is opened and saves cookies and browser storage entries; their list and retention periods are given in the Cookie Policy. On a visitor’s first visit, the Website shows a cookie notice; the notice is purely informational, and the counter loads regardless of it.
- Data: identifiers in cookies and browser storage; IP address; information about the browser, device, operating system, language, and screen size; pages visited, referral source, date, time, and duration of the visit; clicks, scrolling, cursor movement, and a recording of the visitor’s on-page actions (Session Replay, click map); clicks on external links; clicks on the Telegram link, with the link’s location on the page, and the page’s type and address; the fact of a successful request form submission, with the form, and the page’s type and address (without the contents of the form fields).
- Legal basis: processing is necessary to exercise the Controller’s legitimate interests — analyzing traffic and improving the Website (Clause 7, Part 1, Article 6 of the Personal Data Law), provided the rights and freedoms of the subject are not violated.
- Processing on the Controller’s instructions: the data is processed by Yandex LLC in accordance with the Yandex Metrica Terms of Use.
- Opting out: a visitor can delete cookies and block them from being saved in the browser settings, and can block data collection by Metrica using the «Yandex Metrica Blocker» browser extension.
- Retention period: the retention periods for cookies and browser storage entries are set by the Yandex Metrica service and are given in the Cookie Policy; data within the service is kept in accordance with its own terms. The Controller does not set a separate retention period for Metrica data.
4.5. Informational and promotional mailings
As of the date of this revision, no mailings are sent. If mailings are introduced, messages will be sent only to persons who have given separate prior consent to receive them (Part 1, Article 18 of the Federal Law «On Advertising»). Consent remains valid until withdrawn; after withdrawal, sending messages stops, and further processing of the data either stops or continues only if another lawful ground exists, for the corresponding period.
4.6. Accounts for the Website’s administrative area
- Data: the username, e-mail address, and display name of persons granted access to the Website’s administrative area.
- Legal basis: processing is necessary to exercise the Controller’s rights and legitimate interests — managing the Website and controlling access (Clause 7, Part 1, Article 6 of the Personal Data Law).
- Retention period: the account is deleted no later than 30 days after access is no longer needed, unless there is another lawful ground for retaining it.
4.7. Summary of retention periods
| Data | Retention period |
|---|---|
| Web server logs | no more than 30 days |
| System server logs with IP addresses and technical identifiers | no more than 30 days |
| Correspondence with a person with whom no contract has been concluded | 1 year from the date of the last message |
| Requests from forms | 1 year |
| Records of the fact of consent | the duration of the corresponding processing and 3 years after it ends |
| Data under concluded contracts, accounting and tax documents | for the periods required by accounting, tax, and other mandatory legislation |
| Accounts for the Website’s administrative area | deleted no later than 30 days after access is no longer needed |
| Backup copies of the Website’s database | no more than 30 days |
| Cookies and browser storage (Yandex Metrica) | the periods set by the Yandex Metrica service (Cookie Policy) |
| Data for mailings | until consent is withdrawn |
If the purpose of processing is achieved or the lawful ground ends earlier than the period stated above, the data is destroyed within the periods set out in Section 8.
5. Procedure and conditions of processing
5.1. The Controller processes personal data using automation tools.
5.2. Actions performed on personal data: collection, recording, systematization, accumulation, storage, clarification (updating, amendment), extraction, use, transfer (provision, access) in the cases specified in the Policy, blocking, erasure, and destruction. Personal data is not disclosed to the public.
5.3. When collecting personal data, including over the Internet, the Controller ensures that recording, systematization, accumulation, storage, clarification (updating, amendment), and extraction of the personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation (Part 5, Article 18 of the Personal Data Law). The Website’s server, its logs, and its backup copies are located within the territory of the Russian Federation.
5.4. In addition to e-mail, the Telegram messenger — a foreign service — is used to communicate with visitors; correspondence in it is stored and processed by that service under its own rules.
5.5. The Controller may instruct another person to process personal data under a contract (Part 3, Article 6 of the Personal Data Law). Such a person must comply with the principles and rules of processing, confidentiality, and the security measures required by the Personal Data Law. Processing on the Controller’s instructions is carried out by Yandex LLC — in respect of the Yandex Metrica service.
5.6. Backup copies of the Website’s database are kept for no more than 30 days and are deleted automatically.
5.7. Personal data is provided to government authorities only in the cases and in the manner established by the legislation of the Russian Federation.
5.8. The Controller does not make decisions that produce legal effects for the subject or otherwise affect the subject’s rights and legitimate interests based solely on the automated processing of personal data.
5.9. The Controller does not process special categories of personal data or biometric personal data.
6. Security measures
The Controller takes the necessary legal, organizational, and technical measures to protect personal data (Articles 18.1 and 19 of the Personal Data Law), including:
- the processing of personal data is organized personally by the Controller — Individual Entrepreneur Pryakhin Leonid Alekseevich;
- data between the browser and the Website is transmitted over a secure connection (HTTPS);
- access to the server and the Website’s administrative area is restricted to individual accounts with separated access rights;
- if an unlawful or accidental disclosure of personal data is identified, the Controller notifies Roskomnadzor of the incident within 24 hours and of the results of the internal investigation within 72 hours (Part 3.1, Article 21 of the Personal Data Law).
7. Rights of the personal data subject
7.1. The personal data subject has the right to:
- receive information about the processing of their personal data to the extent provided by Part 7, Article 14 of the Personal Data Law;
- demand the clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose;
- demand that the processing of their personal data be stopped;
- withdraw their consent to the processing of personal data;
- appeal the Controller’s actions or inaction to Roskomnadzor or in court.
7.2. The request is sent to the e-mail address step.el3@yandex.ru. The request must contain the number of the subject’s or their representative’s primary identity document, the date it was issued and the authority that issued it, information confirming the subject’s involvement in a relationship with the Controller (for example, the date of an inquiry) or otherwise confirming that the Controller processes the subject’s data, and the signature of the subject or their representative (Part 3, Article 14 of the Personal Data Law). A request submitted as an electronic document is signed with an electronic signature in accordance with the legislation of the Russian Federation.
7.3. The Controller’s response time depends on the type of request:
- information about the processing of personal data, or a reasoned refusal to provide it — within 10 business days of receiving the request; the period may be extended by no more than 5 business days, with a reasoned notice sent (Part 3, Article 14; Parts 1–2, Article 20);
- clarification of incomplete, inaccurate, or outdated data, and destruction of unlawfully obtained or unnecessary data — within 7 business days of the date the supporting information is submitted (Part 3, Article 20);
- a demand to stop processing — within 10 business days of receiving the demand, with a possible extension of no more than 5 business days, except in the cases provided by Clauses 2–11, Part 1, Article 6 of the Personal Data Law (Part 5.1, Article 21).
8. Discontinuation of processing and destruction of data
8.1. Consent is withdrawn by a letter sent to the e-mail address step.el3@yandex.ru.
8.2. The Controller stops processing and destroys personal data:
- when the purpose of processing is achieved — within no more than 30 days of the date the purpose is achieved (Part 4, Article 21);
- when consent is withdrawn — it stops processing and, if retaining the data is no longer necessary for the purposes of processing, destroys it within no more than 30 days of the date the withdrawal is received (Part 5, Article 21);
- when unlawful processing is identified — it stops the processing within 3 business days, and if lawfulness cannot be restored, destroys the data within 10 business days of the date it was identified (Part 3, Article 21).
These periods apply unless otherwise provided by a contract to which the subject is a party, another agreement with the subject, or federal law. The Controller may continue processing without consent where grounds specified in Clauses 2–11, Part 1, Article 6 of the Personal Data Law exist (Part 2, Article 9). If the data cannot be destroyed within the stated period, the Controller blocks it and destroys it within no more than 6 months (Part 6, Article 21).
8.3. The destruction of personal data is documented in accordance with the requirements established by Roskomnadzor (Part 7, Article 21 of the Personal Data Law).
9. Final provisions
9.1. The Controller may amend the Policy. A new revision takes effect from the moment it is published on the Website, unless it states otherwise.
9.2. Matters not addressed by the Policy are resolved in accordance with the legislation of the Russian Federation.
9.3. Related documents: