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Personal data processing policy

Published: 14 September 2026. This edition applies from that date.

The operator is listed in the Russian personal-data operators register. Registration number 78-26-217231, Roskomnadzor order No. 297 of 09.09.2026. Register card: pd.rkn.gov.ru.

This Policy sets out how personal data is processed on https://xelo.pro (the Site) under the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and other Russian regulations.

1. Operator

Personal-data operator:

  • name (as in the Roskomnadzor register): individual entrepreneur Petrov Andrey Alekseevich;
  • trade name: XELO;
  • tax ID: 602001326693;
  • address: Sakņu iela 16/18, LV-5401, Daugavpils, Latgale;
  • e-mail: webwork.edu@gmail.com;
  • phone: +371 27 182 828;
  • operators-register number: 78-26-217231.

For personal-data requests write to that e-mail with the subject “Personal data”.

2. Terms

Personal data — any information relating to a directly or indirectly identified natural person (the data subject).

Processing — any operation with personal data, including collection, recording, storage, updating, use, transfer, depersonalization, blocking and deletion.

Consent — a separate informed expression of will, given by ticking a checkbox on the Site or another unambiguous action (for example submitting a form).

3. Data processed

Depending on the user’s action the Operator may process:

  • full name (if you provide it);
  • e-mail address;
  • phone number;
  • account login and password (the password is stored in protected form);
  • message content from the contact form;
  • Google, Yandex or Sber ID identifiers when you sign in with those services (id, name, e-mail, and phone if available);
  • technical data: IP address, request date and time, cookies, browser data, visited pages (including via Yandex Metrica and Google Tag Manager).

The Site does not intentionally request or process special categories of personal data (health, biometrics, etc.).

4. Purposes

  • account registration and sign-in, providing services, performing a contract;
  • replying to contact-form, e-mail and phone requests;
  • sign-in via third-party identity services (Google, Yandex, Sber ID);
  • Site security (abuse protection, captcha);
  • traffic measurement and Site improvement (Yandex Metrica, Google Tag Manager, cookies) — only with cookie consent;
  • compliance with the law.

5. Legal bases

  • data-subject consent (Art. 6 part 1 p. 1, Art. 9 of 152-FZ) — forms, cookies, analytics, third-party sign-in;
  • performance of a contract to which the subject is a party (Art. 6 part 1 p. 5) — account and services;
  • the Operator’s legitimate interests in keeping the Site working and secure, where this does not override the subject’s rights.

6. Giving and withdrawing consent

Processing consent is given by ticking the checkbox under a form (“I agree to personal data processing…”) and submitting the form, or by using an identity-service sign-in button.

Cookie consent is given with the “Accept” button in the Site notice.

You may withdraw consent by writing to webwork.edu@gmail.com. Withdrawal does not affect processing already performed. If processing is required for a contract, some account features may become unavailable.

7. Cookies and analytics

The Site uses necessary cookies (session, auth) and, with consent, analytics cookies of Yandex Metrica (YANDEX LLC, 119021, Moscow, Leo Tolstoy St., 16) and Google Tag Manager (Google LLC). They help understand how the Site is used. Yandex policy: yandex.ru/legal/confidential. Google policy: policies.google.com/privacy.

You can disable cookies in the browser; some Site features may then work with limits.

8. Sharing with third parties

Data is not sold. Transfer is possible:

  • to the hosting provider and persons engaged to run the Site, on the Operator’s instructions;
  • to identity services you choose: Google LLC, Yandex LLC, Sberbank PJSC (Sber ID) — to the extent needed for sign-in;
  • to Yandex Metrica and Google Tag Manager — with cookie consent;
  • to public authorities — where Russian law requires it.

When you sign in with Google and when you accept cookies (Google Tag Manager), some data may be processed outside the Russian Federation. Using Google sign-in or the cookie “Accept” button means you agree to that transfer.

9. Place of processing and retention

The database of Russian citizens is kept on infrastructure in the Russian Federation. Retention: as long as needed for the processing purposes, until consent is withdrawn, or for periods set by law (including accounting and tax rules). Correspondence and requests — up to 3 years from the last contact, unless the law requires otherwise.

10. Security measures

The Operator applies organisational and technical measures: access control, HTTPS, a limited circle of people with data access, and a record of subject requests.

11. Data-subject rights

You may obtain information about processing, request correction, blocking or deletion, withdraw consent, and appeal to Roskomnadzor or a court. Write to webwork.edu@gmail.com; the Operator replies within the time limits of 152-FZ.

12. Roskomnadzor operators register

The Operator notified the authority of the start of processing under Article 22 of 152-FZ and is listed in the operators register:

13. Policy changes

The current edition is always published at https://xelo.pro/privacy/. Continuing to use the Site after a new edition is published means you accept it, unless the law requires fresh consent.