Privacy Policy

This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 and establishes how the Operator processes personal data and protects it on the Site at https://clustercheats.com.

Please read this Policy carefully. If you disagree with any provision, you may stop using the Site. The Operator treats respect for human and civil rights and freedoms in personal-data processing, including privacy and personal and family confidentiality, as a primary condition of its activities. This Policy applies to all information the Operator may receive about visitors to the Site.

1. TERMS AND DEFINITIONS

Automated personal-data processing means processing personal data using computer technology.

Blocking personal data means temporarily suspending personal-data processing, except where processing is needed to correct the data.

Site means the collection of graphic and informational materials, software, and databases available online at https://clustercheats.com.

Personal data information system means personal data contained in databases together with the information technologies and technical means used to process it.

Anonymization means actions after which personal data can no longer be attributed to a particular User or other data subject without additional information.

Personal-data processing means any action or set of actions performed with or without automated tools, including collection, recording, organization, accumulation, storage, correction, retrieval, use, transfer, distribution, provision, access, anonymization, blocking, deletion, and destruction of personal data.

Operator means self-employed individual Mikhail Anatolyevich Markov, acting independently or jointly with others to organize or carry out personal-data processing and to determine the purposes of processing, the data to be processed, and the operations performed on it.

Personal data means any information directly or indirectly relating to an identified or identifiable User of the Site.

User means any visitor to the Site.

Provision of personal data means actions aimed at disclosing personal data to a specified person or group of persons.

Distribution of personal data means actions aimed at disclosing personal data to an indefinite group or making it available to an unlimited group, including publication in mass media, placement on information and telecommunications networks, or otherwise granting access.

Cross-border transfer means transferring personal data to the territory of a foreign country, a foreign public authority, or a foreign individual or legal entity.

Destruction of personal data means actions that irreversibly destroy personal data so that it cannot be restored in the information system and/or destroy its physical media.

2. PERSONAL DATA THE OPERATOR MAY PROCESS

The Operator may process email addresses; telephone numbers; accounts on social networks and messaging services; and payment-account details held by financial institutions, banks, and payment systems, including, without limitation, email address, telephone number, client number, wallet number, account number, and masked bank-card number.

The Site also collects and processes anonymized visitor data, including cookies, through Internet analytics services such as Yandex Metrica and Google Analytics. All of the information listed above is collectively referred to as Personal Data.

3. PURPOSES OF PERSONAL-DATA PROCESSING

Personal Data is processed to communicate with the User by email; conclude, perform, and terminate civil-law agreements; and provide access to services, information, and materials on the Site. The Operator may send notices about new products and services, special offers, and events. The User may opt out by emailing aurelivoines@gmail.com with the subject “Opt out of notices about new products, services, and special offers.”

Anonymized data collected through Internet analytics services is used to understand User activity and improve the Site and its content.

4. LEGAL BASIS FOR PROCESSING

The Operator processes Personal Data only when the User enters or sends it through forms on the Site. By submitting a form or Personal Data, the User consents to this Policy. Anonymized data is processed when the User's browser settings permit cookies and JavaScript.

5. COLLECTION, STORAGE, TRANSFER, AND OTHER PROCESSING

The Operator protects Personal Data through legal, organizational, and technical measures required by applicable data-protection law. The Operator safeguards the data and takes reasonable steps to prevent access by unauthorized persons.

Personal Data is not transferred to third parties except where required by applicable law. If information is inaccurate, the User may request a correction by emailing aurelivoines@gmail.com with the subject “Personal data update.”

Personal Data is processed for an indefinite period. The User may withdraw consent at any time by emailing aurelivoines@gmail.com with the subject “Withdrawal of consent to personal-data processing.”

6. FINAL PROVISIONS

The User may request clarification about personal-data processing by contacting aurelivoines@gmail.com. Any changes to the Operator's personal-data practices will be reflected in this document. This Policy remains in effect until replaced by a new version. The current version is publicly available at https://clustercheats.com.

CONSENT TO PERSONAL-DATA PROCESSING

I, the Personal Data Subject, acting voluntarily and in my own interest and in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, consent to self-employed individual Mikhail Anatolyevich Markov (the Operator, taxpayer identification number 54044438908) processing the Personal Data I provide on the Operator's Site at https://clustercheats.com. Processing includes receipt, organization, accumulation, compilation, anonymization, storage, updating and correction, use, transfer, and destruction through automated information systems and paper records for the purposes of providing me with the Operator's services and information.

Personal Data includes any information relating to me, including surname, given name, patronymic, address, and contact details such as telephone, fax, email address, and postal address. Registering an account or paying for services on the Site constitutes my full and unconditional consent to the actions above. This consent applies indefinitely from the date it is given and may be withdrawn by submitting a written statement to the Operator in accordance with Russian law.