Personal data processing policy

Revised on 9 October 2026. This is a courtesy translation of the Russian original; if the two differ, the Russian version prevails.

1. General provisions

1.1. This policy sets out the procedure for processing and protecting the personal data of users of the website secondsun.pro (the “Website”) and has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.

1.2. The personal data operator: sole proprietor Andrey Atmorsky, TIN (INN) 390523740982, OGRNIP 322390000017888, address: 20/3-101 Suzdalskaya St, Kaliningrad, 236003, Russia, email a@secondsun.pro, Telegram @mderth (the “Operator”).

1.3. By using the forms and contact buttons on the Website, you confirm that you have read the Policy and agree to the processing of your personal data on the terms described.

2. Basic concepts

Personal data is any information relating to an identified or identifiable individual. Processing is any action with data: collection, recording, storage, clarification, use, transfer, deletion.

3. Purposes of processing

• communicating with the user, replying to a request, discussing terms and concluding a service contract;
• booking an introductory call;
• performing the contract and keeping records;
• analysing traffic and improving the Website;
• meeting legal requirements.

4. Legal grounds

The user’s consent; a contract to which the user is a party; the requirements of the legislation of the Russian Federation.

5. Categories of data

• name;
• contact details (Telegram, phone, email);
• the text of the message and information the user provided themselves;
• the chosen call time;
• technical data: IP address, browser and device information, cookies, data on actions on the Website.

The Operator does not request special categories of data (health, beliefs, etc.) or biometric data. Please do not include them in messages.

6. Procedure of processing

6.1. Actions with data: collection, recording, systematisation, accumulation, storage, clarification, use, transfer (in the cases of section 7), blocking, deletion.

6.2. Processing is carried out with and without automation tools. The Operator takes legal, organisational and technical protective measures: access restriction, a secure connection (HTTPS), storage with trusted providers, regular backups.

6.3. Data of Website visitors who are citizens of the Russian Federation is initially recorded and stored in databases located in the territory of the Russian Federation.

7. Transfer of data to third parties

The Operator may entrust processing or transfer data to:

• a hosting provider (Russia) for hosting the Website;
• YANDEX LLC (Yandex Metrica) for statistics;
• Google LLC (Google Analytics 4, USA) for statistics. This is a cross-border transfer. The Operator has sent Roskomnadzor a notification of the intention to carry out cross-border transfer. The transfer takes place only after the user consents to analytical cookies;
• Telegram for delivering notifications to the Operator;
• the call booking service on the domain cal.enclava.fyi;
• state authorities in the cases provided by law.

Data is not transferred for advertising mailings by third parties.

8. Retention periods

Data is kept no longer than needed for the purposes of processing: requests and correspondence — during the work and up to three years after it ends, unless a contract or the law requires otherwise. After the purposes are achieved or when consent is withdrawn, data is deleted or anonymised within 30 days, unless the law requires keeping it longer.

9. User rights

The user has the right to: obtain information about the processing of their data; require clarification, blocking or deletion of data; withdraw consent; appeal the Operator’s actions to Roskomnadzor or a court. A request is sent to a@secondsun.pro, the response time is 10 working days. Withdrawal of consent does not affect the lawfulness of processing before it was received.

10. Cookies and analytics

The use of cookies is described in the Privacy and cookie policy. Analytical cookies are enabled only after the user’s consent.

11. Final provisions

The Operator may amend the Policy. The new version takes effect from the moment it is published on the Website. The current version is always available at secondsun.pro/en/politika-pd/.