Legal document
Personal Data Processing Policy
Version of 21 August 2026
This is an English translation provided for convenience. The legally binding version is the Russian original at https://skylabdev.ru/privacy; in case of any discrepancy, the Russian version prevails.
1. General provisions
This personal data processing policy has been drawn up in accordance with Federal Law No. 152-FZ “On Personal Data” of 27 July 2006 (hereinafter, the Personal Data Law) and sets out the procedure for processing personal data and the measures to ensure the security of personal data taken by Sole Proprietor Stanislav Sergeevich Kasymsky (hereinafter, the Operator).
1.1. The Operator’s most important goal and condition for carrying out its activities is respect for the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy and to personal and family secrets.
1.2. This Operator’s policy on personal data processing (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website https://skylabdev.ru.
1.3. Operator details: Sole Proprietor Stanislav Sergeevich Kasymsky, INN 261003853725, OGRNIP 326265100053285. Email for enquiries about personal data processing: hello@skylabdev.ru.
2. Key terms used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website — a set of graphic and information materials, as well as computer programs and databases, that make them available on the internet at https://skylabdev.ru.
2.4. Personal data information system — the set of personal data contained in databases, together with the information technologies and technical means that ensure its processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible, without additional information, to determine whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of processing, the composition of the personal data to be processed and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://skylabdev.ru.
2.9. Personal data authorized by the data subject for dissemination — personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized for dissemination in the manner prescribed by the Personal Data Law (hereinafter, personal data authorized for dissemination).
2.10. User — any visitor to the website https://skylabdev.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in the mass media, posting on information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign government authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed, making it impossible to restore the content of the personal data in the personal data information system, and/or the physical media containing personal data are destroyed.
3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
- receive reliable information and/or documents containing personal data from the personal data subject;
- if the personal data subject withdraws consent to the processing of personal data or submits a request to stop processing, continue processing personal data without the subject’s consent where there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law and the regulations adopted under it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
- provide the personal data subject, at their request, with information concerning the processing of their personal data;
- organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized body for the protection of the rights of personal data subjects, at its request, with the necessary information within 10 days of receiving such a request;
- publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
- take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision or dissemination, as well as from other unlawful actions in relation to personal data;
- stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- perform other duties provided for by the Personal Data Law.
4. Main rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- demand that the operator clarify, block or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and take legal measures to protect their rights;
- make prior consent a condition for the processing of personal data for the purpose of promoting goods, works and services on the market;
- withdraw consent to the processing of personal data and send a request to stop the processing of personal data;
- appeal against unlawful actions or omissions of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with reliable information about themselves;
- inform the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of its collection is not permitted.
5.3. Combining databases containing personal data processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of its processing is processed.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Processing personal data in excess of the stated purposes is not permitted.
5.6. When processing personal data, its accuracy, sufficiency and, where necessary, relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized once the purposes of processing have been achieved or the need to achieve them has ceased, unless otherwise provided by federal law.
6. Purposes of personal data processing
6.1. Handling requests and providing consultations (the “Discuss a project” and “Free website audit” forms, the calculator quiz, the quick contact widget):
- Personal data: name; phone number, email address or messenger username; description of the task; website link (for the audit); answers to the calculator quiz questions.
- Legal grounds: consent of the personal data subject (clause 1, part 1, article 6 of the Personal Data Law); conclusion and performance of a contract at the initiative of the personal data subject (clause 5, part 1, article 6 of the Personal Data Law).
- Types of processing: collection, recording, systematization, accumulation, storage, clarification, use, transfer (providing access to the persons listed in clause 8.2), deletion, destruction.
- Period: until the purpose of processing is achieved or consent is withdrawn.
6.2. Web analytics and improving the website:
- Personal data: IP address; browser and device data (user agent); cookies (including the Yandex.Metrica visitor ID); traffic source (UTM tags, referrer); landing page; information about the User’s actions on the website collected by the Yandex.Metrica service, including the Webvisor technology (recording of cursor movements, clicks and page scrolling).
- Legal grounds: consent of the personal data subject (clause 1, part 1, article 6 of the Personal Data Law).
- Types of processing: automated collection, recording, systematization, accumulation, storage, depersonalization, use, deletion.
- Period: until the purpose of processing is achieved or consent is withdrawn.
6.3. Confirming that consent to the processing of personal data has been obtained:
- Personal data: date and time consent was given; IP address; browser data (user agent).
- Legal grounds: fulfilment of the Operator’s obligation to prove that consent was obtained (part 3, article 9 of the Personal Data Law).
- Types of processing: recording, storage.
- Period: for the duration of personal data processing and the limitation period after it ends.
7. Conditions for personal data processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data. Consent is expressed by ticking the corresponding box in the website form before submitting the data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out on personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter, publicly available personal data).
7.7. Processing is carried out on personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the collection, storage, transfer and other types of personal data processing
The security of the personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with the requirements of current personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User’s personal data is not transferred to third parties, except in cases related to compliance with current legislation, cases where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil law contract, and transfers to the following parties engaged by the Operator to process requests and operate the website:
- the hosting provider on whose servers the website is hosted and incoming requests are stored;
- the Telegram service (Telegram Messenger Inc.) — the data entered by the User in the form is transferred to instantly notify the Operator of a new request;
- Yandex LLC (the Yandex.Metrica service) — for the web analytics purposes specified in clause 6.2.
8.3. If inaccuracies are found in the personal data, the User can update it by sending a notice to the Operator’s email address hello@skylabdev.ru marked “Updating personal data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by a contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notice by email to the Operator’s address hello@skylabdev.ru marked “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is responsible for reviewing these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions set by the personal data subject on the transfer (other than providing access) and on the processing, or conditions of processing (other than obtaining access), of personal data authorized for dissemination do not apply where personal data is processed in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing it.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Processing of personal data may be terminated when the purposes of processing have been achieved, the personal data subject’s consent has expired or been withdrawn, the subject has requested that processing stop, or unlawful processing of personal data has been identified.
8.10. The website uses cookies — small text files stored by the User’s browser. Cookies are used for the website to work correctly, to save intermediate answers in the calculator quiz and for web analytics via the Yandex.Metrica service, including the Webvisor technology. The User can disable cookies in their browser settings; this may limit some website features.
9. List of actions performed by the Operator with the personal data obtained
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained over information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before starting the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the foreign government authorities, foreign individuals or foreign legal entities to which the cross-border transfer of personal data is planned.
10.3. When the Telegram service is used for request notifications (clause 8.2), data may be processed on servers located outside the Russian Federation.
11. Confidentiality of personal data
The Operator and other persons who have obtained access to personal data are obliged not to disclose it to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User can obtain any clarification on matters concerning the processing of their personal data by contacting the Operator by email at hello@skylabdev.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://skylabdev.ru/privacy (Russian original) and https://skylabdev.ru/en/privacy (this translation).