Eteri Bakunina

Русский

Personal Data Processing Policy

Updated:

This is a translation of the Russian original (https://become.ru/politika-konfidencialnosti/). If the two versions differ, the Russian version prevails.

1. General provisions

1.1. This policy explains how personal data of visitors to https://become.ru, including the English version at https://become.ru/en/, is processed. It is published under Article 18.1(2) of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”).

1.2. The data operator (controller) is Stadium LLC (ООО «Стадиум»):

  • TIN (INN) 7842513574, KPP 771301001, OGRN 1147847055322;
  • address: 15 Dmitrovskoye Shosse, bldg. 1, apt. 22, Moscow 127434, Russia;
  • General Director: Mikhail Olegovich Bakunin;
  • contact for personal data requests: eteri@become.ru.

1.3. The site lets you book a consultation, seminar or training. The services are provided by Stadium LLC; consultations are held by the operator’s specialist, psychoanalyst and coach Eteri Bakunina. Consultations are for adults only. If you are under 18, please do not submit the booking form.

1.4. Consent to the processing of the data you enter in the booking form is a separate document, the “Consent to Personal Data Processing” (https://become.ru/en/consent/). You give it by ticking the consent box in the form.

2. What data we process

2.1. Data you enter in the booking form:

  • name;
  • email address;
  • phone number with country code;
  • the text of your message, if you write one;
  • your consent tick.

2.2. Data saved automatically when the form is sent:

  • IP address;
  • address and language of the page the request was sent from;
  • date and time of sending.

2.3. Data collected by Yandex Metrica on every page of the site: a cookie identifier, IP address, browser, device and operating system details, pages viewed and the referring page, time and length of the visit, link clicks, clicks, scrolling and pointer movements on the page (Session Replay and Click Map), and the fact that the booking form was sent. See section 8 for details.

2.4. We do not ask for information about health, beliefs, intimate life or other special categories of data (Article 10 of the Law). The form has no such fields. Please do not include such information in your message: a short note on the topic is enough to book. The request itself is discussed at the consultation.

3. Purposes and legal grounds

3.1. Reply to your request, arrange and hold a consultation, seminar or training.

  • data: name, email, phone, message;
  • legal ground: your consent (Art. 6(1)(1) of the Law); once a service is agreed, also a contract with you (Art. 6(1)(5)).

3.2. Protect the form from automated and repeated submissions, look into a disputed request.

  • data: IP address, page address and language, date and time;
  • legal ground: your consent (Art. 6(1)(1) of the Law).

3.3. Understand site traffic and usability, count booking requests.

  • data: the information listed in 2.3;
  • legal ground: your consent, expressed through your browser settings and continued use of the site (Art. 6(1)(1) of the Law).

3.4. We do not use your data for newsletters or advertising, and we make no decisions with legal effect for you based solely on automated processing.

4. How we process data

4.1. Processing is mixed: automated (on the site, in email, in Yandex Metrica) and manual (when the specialist reads your request and replies).

4.2. Operations performed: collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), blocking, deletion and destruction.

4.3. Personal data of Russian citizens is recorded, systematised, accumulated, stored, updated and retrieved using databases located in the Russian Federation (Article 18(5) of the Law).

4.4. What happens to a request:

  • it is saved in the site database on a server in the Russian Federation, accessible only in the site admin panel with a login and password;
  • a notification with your name, phone, email, message and page address is emailed to the operator’s work email;
  • if you gave an email address, an automatic message confirms that your request has been received.

5. Who has access to the data

5.1. Within the operator, booking requests are handled by Eteri Bakunina, the specialist who replies to requests and holds consultations on behalf of Stadium LLC. She acts as a person working for the operator, not as a third party, uses the data only for the purposes in section 3 and must keep it confidential.

5.2. Analytics service: YANDEX LLC (Russia) — Yandex Metrica; processes the data listed in 2.3 on its own servers under its terms of use and privacy policy (https://yandex.com/legal/metrica_termsofuse/, https://yandex.com/legal/confidential/).

5.3. We do not sell data or share it for advertising. Data is disclosed to public authorities only on grounds expressly provided by law.

5.4. Links to the Telegram channel lead to an external service. The site does not send your data to Telegram; Telegram’s own rules apply once you follow the link.

6. Cross-border transfer

Personal data is not transferred across borders.

7. Retention and deletion

7.1. Booking data is kept for 3 years from your last contact with us, then deleted from the site database and the operator’s email.

7.2. If you withdraw consent, the data is destroyed within 30 days (Article 21(5) of the Law), except data the operator must keep by law or may process without consent, for example to perform a contract with you.

7.3. Yandex Metrica data is kept by Yandex for the periods set in its terms of use.

8. Cookies

8.1. Cookies are small files that a site or a third-party service stores in your browser.

8.2. The site uses:

  • functional cookies of the site: pll_language remembers the chosen language; for those who log in to the admin panel, login cookies. The site does not work properly without them;
  • Yandex Metrica cookies (for example _ym_uid, _ym_d, _ym_isad, _ym_visorc): tell visitors and visits apart; needed for statistics, Session Replay and Click Map.

8.3. You can block or delete cookies in your browser settings. Refusing Metrica cookies does not stop you from using the site or sending a request. You can also turn off Metrica in all browsers with Yandex’s add-on: https://yandex.com/support/metrica/general/opt-out.html.

9. How we protect data

  • the connection to the site is encrypted (HTTPS);
  • the admin panel, request database and the operator’s email are accessible only with a login and password and only to those who need them for the purposes in section 3;
  • the site software is updated regularly, and the database is backed up daily;
  • data is never published or shown to other visitors.

10. Your rights

10.1. You have the right to:

  • find out whether your data is processed, what data, why, how and to whom it is transferred (Article 14 of the Law);
  • require us to correct, block or destroy data that is incomplete, outdated, inaccurate, unlawfully obtained or not needed for the stated purpose;
  • require us to stop processing your data (Article 21(5.1) of the Law);
  • withdraw your consent;
  • complain about the operator to Roskomnadzor, the Russian data protection authority (https://rkn.gov.ru), or to a court.

10.2. Send requests to eteri@become.ru or by post to the operator’s address in 1.2. Include your name and the contact you left in the request so we can find your data and confirm the request is yours.

10.3. Response times under the Law:

  • information about your data — within 10 working days of receiving the request; this may be extended by up to 5 working days, in which case we will tell you why;
  • correction of inaccurate data — within 7 working days of receiving supporting information;
  • stopping unlawful processing — within 3 working days, destroying such data — within 10 working days;
  • stopping processing at your request — within 10 working days of receiving the request; this may be extended by up to 5 working days, in which case we will tell you why;
  • destroying data after consent is withdrawn — within 30 days.

11. Withdrawing consent

Email eteri@become.ru from the address you gave in your request, or send a letter to the operator’s address in 1.2, with the subject “Withdrawal of consent to personal data processing”. Include your name and the contact from your request. We will stop processing, destroy the data within the times in section 10 and confirm by reply.

12. Changes to this policy

The operator may update this policy, for example when services or legal requirements change. A new version takes effect when published on this page; the date of the last update is shown at the top.