This is an English translation provided for convenience. The Russian text is the legally binding version and prevails in the event of any discrepancy.

Personal Data Processing Policy

Publication date: 9 September 2026

1. General provisions

1.1. This Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (the "Personal Data Law") and sets out the position of Individual Entrepreneur Sergey Petrovich Emelyanov (the "Operator") with regard to the personal data of visitors to the website https://sergeyem.ru (the "Site").

1.2. The Site is an information resource about the Operator's professional activities. The Site contains no feedback, registration, subscription or comment forms and no other means of collecting personal data. The Operator does not collect, record, systematise, accumulate, store, update, retrieve, use, transfer, anonymise, block, delete or destroy the personal data of Site visitors by means of the Site.

1.3. Since no personal data of visitors is collected or processed through the Site, visitors are not asked to consent to the processing of personal data.

1.4. This Policy applies to all information the Operator may obtain about Site visitors in connection with their use of the Site.

2. Terms used in this Policy

2.1. Site - the collection of graphic and informational materials, computer programs and databases that make them available on the Internet at https://sergeyem.ru.

2.2. Operator - Individual Entrepreneur Sergey Petrovich Emelyanov, who administers the Site.

2.3. User - any person who has access to the Site via the Internet and uses it.

2.4. Personal data - any information relating directly or indirectly to an identified or identifiable natural person (personal data subject).

2.5. Personal data processing - any operation or set of operations performed on personal data, whether or not by automated means.

3. What the Site does not do

3.1. The Site has no feedback, request or newsletter subscription forms and no other data entry forms. The User cannot transmit their personal data to the Operator through the Site.

3.2. The Site does not use web analytics or statistics services (including Yandex.Metrica and Google Analytics), advertising or social trackers, or any other tools for tracking User behaviour.

3.3. The Site does not set cookies on the User's device and does not use any other identifiers of the User or their device. Details are set out in the Cookie Policy published on the Site.

3.4. The Site does not store data entered by the User. A search query over the Site's content is processed only at the moment it is run and is not recorded.

3.5. The Site does not load program code or fonts from third-party servers when its pages are opened; all page resources are hosted on the Site.

4. Web server technical data

4.1. The web server hosting the Site keeps standard technical access logs, which automatically record the device's IP address, the date and time of the request, the address of the requested page and information about the browser. The logs are kept solely to ensure the security, availability and troubleshooting of the Site.

4.2. Access logs are kept for no longer than 14 days and are deleted automatically. They are not used to identify the User, are not combined with other data and are not disclosed to third parties, except in cases expressly provided for by law.

5. Contacting the Operator

5.1. The Site displays the Operator's contact details: a phone number, an e-mail address and links to messengers (WhatsApp, Viber, Telegram). The User may, on their own initiative, contact the Operator by any of these means.

5.2. Such communication takes place outside the Site, through the services of telecom operators, e-mail and messengers, each of which processes data under its own rules. The Site does not take part in transmitting or storing messages and keeps no record of enquiries.

5.3. Information the User provides when making an enquiry is used by the Operator solely to respond to that enquiry; it is not entered into databases, is not used for mailings and is deleted at the User's request.

5.4. The "Schedule a meeting" button leads to the Operator's meeting booking service at https://calendar.sergeyem.ru. The service does not ask for a name, phone number, e-mail address or any other details about the User: to book, it is enough to choose a date and time and state the topic of the conversation. Only the chosen date and time and the entered topic are stored; the Operator asks Users not to include names, phone numbers or other personal data in the topic. To hold the meeting, the booking details are passed to the Operator's Google Calendar, where a Google Meet video call link is created, and the Operator receives a booking notification in Telegram. Bookings are kept by the Operator for scheduling purposes and are deleted at the User's request. The service's web server keeps technical logs in the manner and for the period set out in section 4.

6. Links to third-party resources

6.1. The Site contains links to external resources: the Operator's social media pages and the YouTube video hosting service. By following them, the User leaves the Site; the use of such resources is governed by their own terms and policies, for which the Operator bears no responsibility.

6.2. YouTube videos embedded in Site pages are loaded only after the User presses the play button. Until then, no data is transmitted to YouTube servers.

7. User's rights

7.1. The User is entitled to obtain from the Operator clarification on any matter relating to this Policy by sending a request to se@sergeyem.ru.

7.2. The User is entitled to appeal against the Operator's actions or omissions to the authorised body for the protection of the rights of personal data subjects or in court.

8. Final provisions

8.1. The Operator may amend this Policy. A new version takes effect from the moment it is published on the Site, unless the new version provides otherwise.

8.2. The Policy remains in force indefinitely until replaced by a new version.

8.3. The current version of the Policy is freely available on the Site at https://sergeyem.ru/privacy-policy; this English translation is available at https://sergeyem.ru/en/privacy-policy.

Operator:
Individual Entrepreneur Sergey Petrovich Emelyanov
Taxpayer identification number (INN): 212802719116
428000, Cheboksary, Chuvash Republic, Russia
se@sergeyem.ru