"Law" refers to the Federal Law of the Russian Federation "On Personal Data," including all amendments and additions, as well as other legislative acts of the Russian Federation.

"Controller" refers to the entity responsible for processing and safeguarding the Personal Data of Users located within the EU, as defined by the General Data Protection Regulation of 27 April 2016 (referred to as "GDPR").
"Site" refers to an internet-based unit of information, a collection of web pages (documents) sharing a common theme and interconnected through links. The Site is registered under the ownership of the Rights Holder and is associated with a specific domain, serving as its address. This Privacy Policy applies to the following website:

"Personal Data" refers to the collective information provided by the User, whether personally identifiable or non-personally identifiable, that is either voluntarily provided by the User to the Rights Holder or automatically collected by the Rights Holder or third parties.

"Policy" refers to this Privacy Policy for the website, including all existing additions and amendments.
"User" refers to the individual or entity that utilizes and/or accesses the Website from any device.
"User Agreement" refers to the agreement between the Rights Holder and the User regarding the terms, rules, and features of Website usage. The User accepts the agreement and is not entitled to make any changes or additions to it. The terms of the User Agreement can be found at the following link:

«Rights holder" refers to the individual registered as the owner of the Site, as follows: GORKHIIAN OLGA Gg. Pdg Kluma No.26, Padangsambian, Kec. Denpasar Bar., Kota Denpasar, Bali 80118
"Cookies" refer to small files sent by a website and stored on the User's computers, smartphones, tablets, watches, and other mobile devices. Cookies aim to enhance website performance and improve the quality of posted content.


General Provisions

This Policy is exclusively applicable to Personal Data obtained from the User in connection with their use of the Site. The purpose of this Policy is to:

(1) specify the types of Personal Data collected, the purposes for which Personal Data is processed, and the sources from which it is obtained.

(2) establish the User's rights regarding the confidentiality and protection of the Personal Data transmitted.
(3) identify the responsible parties for the processing and storage of Personal Data, as well as third parties with whom such data may be shared, in whole or in part.

The rules outlined in this Policy do not apply to the processing of Personal Data voluntarily provided by the User to third parties. By using the Website, the User agrees to the terms of this Policy and gives consent to the Rights Holder to collect, process, retain, and store Personal Data in accordance with the provisions of this Policy. If the User disagrees with the terms of the Policy or finds certain terms unclear, the User must immediately cease using the Website.

User Rights for Personal Data Protection

In connection with the provision of Personal Data, the User automatically holds the following rights:
(1) Access to information regarding the processing of their Personal Data, including the grounds and purposes for such processing, the methods employed, and information about individuals or entities who have access to or may receive the data based on a contract or legal requirements.

(2) Access to information about the location and identification of the individuals or entities processing Personal Data.
(3) Access to information about the retention period for Personal Data.

(4) Access to information about cross-border transfers of Personal Data that have occurred or are expected to occur.

(5) The right to file complaints or grievances against the actions or omissions of the Rights Holder to the authorized body responsible for protecting personal data rights or to a court of law.

(6) The right to seek compensation for losses and/or damages due to violations of User rights in relation to the protection and defense of Personal Data by the Rights Holder or third parties.

(7) The right to exercise other rights related to personal data protection as provided by the Law or the provisions of this Policy.


Non-Personal Information about Users
In connection with the use of the Website, the Rights Holder may automatically collect and process the following non-personalized information about the User:
(1) Traffic information, click rates, logs, and other related data.
(2) Device information, such as the identification number of the device used to access the Site, operating system, platform, browser type, and other browser details, as well as the IP address.
Personal Information about Users
The User provides the Rights Holder with the following personal data:
(1) Mobile phone number.
(2) User's citizenship.
(3) Data from the following social network: WhatsApp. The Rights Holder may collect, process, and store the User's ID from any social network used for registration and/or login on the Site. By registering on the Website through a social network account, the User provides automatic consent to the collection, processing, and storage of Personal Data accessible to the Rights Holder through the selected social network.
(4) Data and information obtained by combining specific Personal Data from the User, as well as data and information obtained from third parties (partners, marketers, researchers) about the User.
The User is solely responsible for the accuracy of the personal data provided and is obligated to make timely updates and corrections on a regular basis.
The Rights Holder assumes that all personal data provided by the User is accurate, and the User will keep such information up to date.
Use of Cookies
The Site employs certain Cookie files to store the User's IP address, preferences, and device type. The purpose of Cookies is to:
(1) Gather statistics on Site visits and traffic.
(2) Personalize the data displayed to the User.
(3) Identify the User, even when accessing the Site from different devices.
(4) Display advertisements based on the User's interests and preferences.
The Site may use both its own Cookies and third-party Cookies.
The following types of Cookies are used on the Site:
(1) Technical (functional) Cookies, necessary for traffic control, data transmission, user identification, and providing access to content. Failure to accept these Cookies may limit the functionality and access to the Site and prevent the delivery of user-oriented recommendations.
(2) Statistical Cookies, used to track the frequency of Site visits, analyze Site usage patterns, and identify popular or interesting content to the User.
(3) Third-party Cookies, set with the User's consent by third parties to conduct statistical research on the User's internet behavior, deliver personalized advertising or marketing materials, and provide goods or services.
The User has the right to disable Cookies at any time by adjusting the settings in their browser. Disabling Cookies will not restrict or alter the User's access to Site functionality or content. To disable Cookie files, follow these steps: Go to settings and disable files.
Definition of Processing Purposes
Personal Data is collected and processed for the following purposes:
(1) Analyzing User behavior and preferences regarding specific types of content.
(2) Ensuring the proper and efficient operation of the Site, improving its functionality and content.
(3) User identification.
(4) Sending personalized advertising and marketing materials to the User's provided email
 address and/or mobile phone.
(5) Compliance with legal requirements.
(6) Technical support for the Site, troubleshooting, and issue resolution.
(7) Communication with the User.
(8) Fulfillment of other obligations of the Rights Holder to the User.
(9) Any other purpose with the User's separate consent.
Personal Data processing is based on the following principles: (1) lawfulness of processing purposes and methods; (2) good faith; (3) compliance of Personal Data processing with predetermined and stated purposes; (4) compliance of the amount and nature of Personal Data processed with the stated purposes.
Conditions for Personal Data Processing
Personal Data processing takes place in the following circumstances:
(1) Obtaining consent from the User.
(2) Fulfilling the purposes of the Rights Holder under international treaties or the Law.
(3) Making Personal Data publicly available by the User.
(4) Fulfilling other obligations of the Rights Holder to the User, including the provision of specific content.
(5) Preserving the life or health of the User when consent for Personal Data processing cannot be obtained in advance.
In cases where Personal Data is depersonalized and cannot directly or indirectly identify the User, subsequent use and disclosure of such data to third parties is permitted, and the rules outlined in this Policy no longer apply.
The Rights Holder takes all necessary measures to protect the confidentiality of the Personal Data received, except in cases where the User has made such data publicly available.
Personal Data processing may occur with or without the use of automated means.
Use of Remarketing Services
The Rights Holder utilizes remarketing services to display content from the Site on other websites visited by the User. Remarketing services are provided to the Rights Holder through the Facebook platform. Facebook collects and processes non-personally identifiable data that does not directly identify the User. The collected information typically includes (1) content viewed by the User, (2) date and time of content viewing, (3) geolocation data. This collection and processing of non-personally identifiable information allow for targeted advertising or marketing content to be presented to the User.
By using the Site, the User agrees to the privacy policy (Privacy Policy) of Facebook and the automatic installation of appropriate Cookies on the User's device.
The User has the right to opt out of such advertising at any time by adjusting the appropriate browser settings.
Use of Analytics Platforms
The Rights Holder employs the Google Analytics platform to (1) track User visit frequency to the Website, (2) monitor User interactions with the Website and/or its content, (3) identify popular content types and categories, and (4) determine User location. The User consents to the Rights Holder's use of information obtained through Google Analytics.
For these purposes, the Google Analytics platform may collect data related to the User's IP address, geolocation, behavior, preferences, and interests.
The Google Analytics platform accesses Personal Data to provide the Rights Holder with insights on Website effectiveness, popular content, and the efficacy of specific advertisements, aiding in the development and improvement of the Rights Holder's marketing strategy.
By using the Site, the User agrees to the privacy policy (Privacy Policy) of Google Analytics and the automatic installation of appropriate Cookie files on the User's device.
Disclosure of Personal Data to Third Parties
The Rights Holder has the right to disclose Personal Data in the following cases:
(1) To its affiliates, branches, and representative offices within the Russian Federation and other countries.
(2) To legal successors of the Rights Holder resulting from liquidation, reorganization, or bankruptcy, who have obtained exclusive rights to the Website.
(3) To third parties for the sole purpose of providing the User with specific content or access to it.
(4) To third parties when the User has given consent for such disclosure.
The Rights Holder discloses Personal Data only if (1) third parties agree to comply with the terms of this Policy and take necessary measures to protect Personal Data, and (2) the User has previously provided consent or such disclosure is permitted by the Law.
Advertising on the Website
The Rights Holder does not place advertisements on the Website.
Sending of Advertising Materials
The User agrees to receive personalized advertising and marketing materials at the provided email address and/or mobile phone.
The User has the right to opt out of receiving such advertising and marketing materials at any time by following these steps:
The User can indicate their preference to not receive offers in a comment to the application.
Please note that refusing to receive promotional and marketing materials does not prevent the User from receiving notifications from the Rights Holder related to the use of the Website and its content.
Request to Cease Personal Data Processing
Each User has the right to object to the processing and/or storage of their Personal Data by submitting a request to the Rights Holder. Such objection can be expressed as follows:
Request for Personal Data Information

If the User has any questions regarding the application or use of this Policy, the processing of Personal Data, or any other related matter, they may submit a question as follows:

By communicating directly through messaging apps
Change (Update, Amend, Correct) or Deletion of Personal Data
The User can change or delete their Personal Data at any time by sending a request to the Rights Holder at the following address:

The Rights Holder may refuse to change or delete Personal Data if such action would result in (1) a violation of this Policy, (2) a violation of the Law, or (3) if the nature of the Personal Data is relevant evidence in any litigation between the Rights Holder and the User.

The storage of Personal Data is managed by the Rights Holder.
Personal Data is stored for the duration of the User's usage of the Site.

Users in the Russian Federation

The Site is intended for individuals over the age of 18. Access to the Site is granted only upon obtaining prior consent for the processing of Personal Data. The Rights Holder verifies the age of the User as follows:
The Site does not contain materials that restrict access to individuals under the age of 18.
If the User is a minor, they must immediately cease using the Site.
Users within the European Union

The Site is intended for individuals aged 16 years and older who can access it only with prior consent for the processing of Personal Data. The Rights Holder verifies the User's age as follows:
The Site does not contain materials that restrict access to individuals under the age of 18.
If the Rights Holder becomes aware that a User's age does not comply with the permissible age for using the Website, access to the Site will be immediately blocked.


The protection of Personal Data confidentiality is a primary and crucial task for the Rights Holder. The Rights Holder adheres to all required international standards, rules, and recommendations for the protection of Personal Data.

The Rights Holder has implemented various technical and organizational measures to protect Personal Data from unauthorized access or disclosure by third parties.


General Provisions

Given that the Site is accessible to users in the European Union, the Rights Holder must additionally adhere to GDPR provisions.

The Rights Holder acts as the controller in accordance with this Policy.
The Rights

 Holder retains Personal Data for a reasonable period necessary to fulfill processing purposes, but not less than the period stipulated by local laws of the European Union Member State where the Site is accessible for a specific type of Personal Data. After the expiration of the prescribed storage period, the Rights Holder undertakes to immediately destroy or anonymize such data.
Legal Representative

As the Controller is located outside the European Union, the following person is appointed as its official representative for the protection of Personal Data of Users in the European Union: Olga Yurievna Gorkhiyan, address: Russia, contact information: +79180441110.

User Rights regarding Personal Data Protection

According to Chapter 3 of GDPR, Users within the European Union have the following rights regarding Personal Data protection: (1) the right to be informed about their Personal Data ("the right to be informed"); (2) the right to access their Personal Data ("the right of access"); (3) the right to rectify their Personal Data ("the right to rectification"); (4) the right to erase their Personal Data ("the right to erasure"); (5) the right to restrict processing of their Personal Data ("the right to restrict processing"); (6) the right to data portability ("the right to data portability"); (7) the right to object ("the right to object").

Appointment of a Data Protection Officer

The Controller appoints the following person as the Data Protection Officer: OLGA GORKHIYAN, responsible for compliance with data protection laws, including GDPR. The Officer's contact information is:


Accessibility of the Policy Text
Users can access the terms of this Policy at the following link:
In case of a discrepancy between the original (Russian) text and its translation, the language of the original version prevails.

This edition of the Policy is effective as of October 1, 2022.
Amendments and Additions to the Policy
This Policy may be amended from time to time. The Rights Holder is not liable to the User for changes made to the terms of this Policy without the User's permission or consent.
The User agrees to periodically review the terms of this Policy for possible amendments or additions.
Applicable Law

This Policy is developed in compliance with the current legislation on personal data protection in the Russian Federation, including the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (with all amendments), the Federal Law of July 21, 2014, No. 242-FZ "On Amending Certain Legislative Acts of the Russian Federation to clarify the processing of personal data in information and telecommunications networks" (with all amendments), as well as the provisions of the General Data Protection Regulation.
Risk of Disclosure

Regardless of the measures taken by the Rights Holder to protect the confidentiality of received Personal Data, the User acknowledges that any transfer of personal data over the Internet cannot be guaranteed as completely secure, and therefore, the User assumes the risk associated with such transfer.