PERSONAL DATA

Personal Data Processing Policy

PERSONAL DATA PROCESSING POLICY
Version dated 2 August 2026. Effective from the moment of publication on mironovstudio.online. This is a translation of the Russian original; in case of any discrepancy the Russian version published at mironovstudio.online/privacy-policy/ru shall prevail.

1. General provisions
1.1. This Personal Data Processing Policy (the “Policy”) has been adopted pursuant to clause 2 of part 1 of Article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and defines the procedure for processing personal data as well as the security measures taken by Individual Entrepreneur Maxim Konstantinovich Mironov (TIN 665815277209, OGRNIP 321665800182450), hereinafter the “Operator”.
1.2. The Policy applies to all information about users that the Operator may obtain in connection with the use of the website mironovstudio.online and all of its subdomains and language versions (the “Website”), as well as in the course of concluding and performing contracts.
1.3. The Policy covers the processing of personal data carried out both with and without the use of automation tools.
1.4. By using the Website and by submitting a request through the feedback forms, messengers or e-mail, the user confirms that they have read the Policy and accept its terms.
1.5. The current version of the Policy is published at mironovstudio.online/privacy-policy/en and is available to an unlimited number of persons free of charge.

2. Key terms
2.1. Personal data — any information relating directly or indirectly to an identified or identifiable natural person (the data subject).
2.2. Operator — a person that independently or jointly with other persons organises and (or) carries out the processing of personal data and determines the purposes of processing, the composition of the data and the actions performed with it.
2.3. Processing of personal data — any action or set of actions performed with personal data, including collection, recording, systematisation, accumulation, storage, updating (renewal, modification), retrieval, use, transfer (provision, access), depersonalisation, blocking, deletion and destruction.
2.4. User — any visitor of the Website.
2.5. Other terms are used in the meanings defined by Federal Law No. 152-FZ.

3. Operator details
Full name: Individual Entrepreneur Maxim Konstantinovich Mironov.
TIN: 665815277209. OGRNIP: 321665800182450.
Address: 620041, Sverdlovsk Region, Yekaterinburg, Uralskaya St. 1, apt. 100.
E-mail for enquiries regarding the processing of personal data: mironov@mironovstudio.online.
Phone: +7 (995) 919-77-87.
Person responsible for organising the processing of personal data: Maxim Konstantinovich Mironov.

4. Categories of data subjects and scope of data processed
4.1. The Operator processes the personal data of the following categories of data subjects: visitors of the Website, prospective clients, clients and their representatives, counterparties and their representatives, candidates for employment or cooperation.
4.2. Data processed: surname, first name and patronymic; phone number; e-mail address; company name and position; messenger identifiers (Telegram, WhatsApp); the content of enquiries and correspondence; payment and accounting details required for issuing invoices and closing documents; data required to conclude a contract in accordance with the law.
4.3. When the Website is visited, the following data is processed automatically: IP address, date and time of the request, browser and operating system information, interface language, referral source (referer), pages viewed, cookies and web analytics identifiers.
4.4. The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life) or biometric personal data.
4.5. The Operator does not process the personal data of minors. The Website is not intended for persons under 18 years of age.

5. Purposes of processing
5.1. Processing is carried out solely for the following purposes:
— reviewing requests and enquiries received through the Website forms, messengers, e-mail and by phone, and providing feedback to the user;
— preparing and sending commercial proposals, cost estimates and invoices;
— concluding, performing, amending and terminating service contracts and fulfilling the obligations arising from them;
— drawing up primary accounting documents, maintaining accounting and tax records and fulfilling the duties imposed by the legislation of the Russian Federation;
— sending informational and advertising messages subject to the prior consent of the recipient in accordance with part 1 of Article 18 of Federal Law No. 38-FZ of 13 March 2006 “On Advertising”;
— improving the Website, analysing traffic and ensuring technical operability and information security;
— protecting the rights and legitimate interests of the Operator, including pre-trial and judicial settlement of disputes.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing that is incompatible with these purposes is not permitted.

6. Legal grounds for processing
6.1. The legal grounds for processing are: 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. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”; Federal Law No. 38-FZ of 13 March 2006 “On Advertising”; Law of the Russian Federation No. 2300-1 of 7 February 1992 “On Protection of Consumer Rights”; Federal Law No. 402-FZ of 6 December 2011 “On Accounting”.
6.2. Processing is carried out on the basis of: the consent of the data subject to the processing of their personal data; a contract to which the data subject is a party, beneficiary or guarantor; the need to fulfil the duties imposed on the Operator by law.

7. Procedure and conditions of processing
7.1. Processing is carried out by means of collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer, depersonalisation, blocking, deletion and destruction of personal data.
7.2. The personal data of citizens of the Russian Federation is recorded, systematised, accumulated, stored, updated and retrieved using databases located in the territory of the Russian Federation in accordance with part 5 of Article 18 of Federal Law No. 152-FZ.
7.3. The Operator does not take decisions producing legal effects in respect of a data subject solely on the basis of automated processing of their personal data.
7.4. The Operator may entrust the processing of personal data to another person with the consent of the data subject on the basis of a contract setting out the list of actions, the purposes of processing and the obligation to maintain confidentiality and ensure the security of the data.

8. Transfer of personal data to third parties
8.1. The Operator does not sell or disclose personal data to third parties except in the cases provided for by this Policy and by law.
8.2. Personal data may be transferred to persons engaged by the Operator to achieve the purposes of processing, including: the Website platform and form service provider Tilda Publishing LLC; hosting and cloud infrastructure providers; web analytics operators; CRM and mailing service operators; credit institutions and electronic document management operators for settlements and document exchange; persons providing accounting and legal services to the Operator.
8.3. Personal data may be provided to state authorities, courts and other authorised bodies on the grounds and in the manner established by law.
8.4. The Operator does not carry out cross-border transfer of personal data to the territory of foreign states. Should such a need arise, the Operator will notify the authorised body for the protection of the rights of data subjects prior to the start of the transfer in accordance with Article 12 of Federal Law No. 152-FZ.

9. Processing and storage periods
9.1. Personal data is processed until the purposes of processing are achieved or until the data subject withdraws their consent.
9.2. Data obtained from feedback forms is stored for no longer than 3 (three) years from the date of the last interaction, unless another period is established by law or by contract.
9.3. Data contained in contracts and primary accounting documents is stored for the periods established by the legislation on accounting and archiving, but for no less than 5 (five) years.
9.4. Once the purposes of processing have been achieved or consent has been withdrawn, personal data is destroyed or depersonalised within a period not exceeding 30 (thirty) days, unless otherwise provided by law. The destruction is recorded in a formal act.

10. Security measures
10.1. The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution and other unlawful actions, including:
— appointing a person responsible for organising the processing of personal data;
— issuing internal regulations on the processing and protection of personal data;
— limiting the range of persons with access to personal data and differentiating access rights;
— encrypting the data transmission channel (HTTPS protocol, TLS certificate) on all pages of the Website containing forms;
— using information protection tools, anti-virus software and backup copying;
— providing unrestricted access to this Policy on the Website;
— carrying out internal control of the compliance of processing with statutory requirements.
10.2. The Operator undertakes to notify the authorised body and the data subject of any identified incidents resulting in the unlawful transfer of personal data within the periods established by part 3.1 of Article 21 of Federal Law No. 152-FZ.

11. Rights of the data subject
11.1. The data subject has the right to: obtain information about the processing of their personal data as provided for by part 7 of Article 14 of Federal Law No. 152-FZ; demand the updating, blocking or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing; withdraw consent to the processing of personal data; object to receiving advertising and informational messages; appeal against the actions or omissions of the Operator to the authorised body for the protection of the rights of data subjects or in court.
11.2. Requests and demands are to be sent to mironov@mironovstudio.online or by post to the Operator’s address. The request must contain the information provided for by part 3 of Article 14 of Federal Law No. 152-FZ.
11.3. The Operator reviews the enquiry and sends a reply within a period not exceeding 10 (ten) business days from the date of receipt. This period may be extended by no more than 5 (five) business days with notification of the applicant.
11.4. Withdrawal of consent is to be sent in free form to the e-mail address indicated above. Upon receipt of the withdrawal the Operator ceases processing and destroys the personal data, except in cases where processing is permitted without the consent of the data subject.

12. Cookies and web analytics
12.1. The Website uses cookies — small text files stored in the user’s browser that are necessary for the correct operation of the Website, for saving user settings and for collecting depersonalised statistics.
12.2. The Website may use web analytics systems that collect depersonalised information about visits.
12.3. The user may disable or delete cookies in their browser settings. Disabling certain cookies may make some functions of the Website unavailable.
12.4. Detailed terms are set out in the Cookie Policy published at mironovstudio.online/cookie-policy/en.

13. Final provisions
13.1. The Operator may amend this Policy. A new version comes into force from the moment it is published on the Website, unless the new version provides otherwise.
13.2. Superseded versions of the Policy are retained by the Operator and provided upon request.
13.3. All relations connected with the processing of personal data are governed by the legislation of the Russian Federation.
13.4. For any questions relating to the processing of personal data, please contact mironov@mironovstudio.online.