Personal data processing policy
Editorial from 20.10.2026. Identification: 2026-10-20-analytics-prepared-1.
Designations in the document: TIN — Taxpayer Identification Number; OGRNIP — Primary State Registration Number of the Individual Entrepreneur; OGRN — Primary State Registration Number; LLC — Limited Liability Company; IP address — the network address from which the request comes; cookie — small records that a website saves in the browser.
1. General Provisions and Information about the Operator
1.1. Personal Data Operator — individual entrepreneur Andrey Viktorovich Svirin:
- TIN: 772872317733;
- OGRNIP: 322774600176722;
- mailing address: 117647, Moscow, P.O. Box 15;
- email for questions regarding personal data: mail@perevodius.moscow;
- website: https://perevodius.moscow/.
1.2. This Personal Data Processing Policy (hereinafter referred to as the Policy) determines the purposes, legal grounds, composition, procedure and terms of personal data processing by an individual entrepreneur Svirin Andrey Viktorovich (hereinafter referred to as the Operator) when using the https://perevodius.moscow/ website (hereinafter referred to as the Site), considering appeals by e-mail and subsequent interaction on them. Applications via web forms are not accepted. If the parties separately enter into a contract, the necessary processing is also governed by this contract and law.
1.3. The Policy applies to the personal data of Website visitors, individuals submitting inquiries (hereinafter — Applicants), clients, their representatives, and other individuals whose personal data is lawfully processed by the Operator in connection with the provision of services. Handling of inquiries is carried out by the Operator personally.
2. Legal grounds and principles of processing
2.1. The processing of personal data is carried out in accordance with the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and other applicable normative legal acts of the Russian Federation. The terms "personal data," "processing of personal data," "operator," "provision of personal data," "anonymization of personal data," and "destruction of personal data" are used in the meanings established by Article 3 of the mentioned Law.
2.2. The processing of personal data is carried out on a lawful and fair basis and is limited to achieving specific, predetermined, and lawful purposes. The content and volume of the processed personal data must correspond to the stated purposes of processing; excessive processing and processing incompatible with the purposes of the original collection are not allowed.
2.3. Visiting the Site, clicking the “Write a Letter” button and sending an ordinary letter itself do not constitute universal consent to the processing of personal data. Consent, where necessary, is provided separately and does not apply to promotional mailings, promotional calls, publication of materials or optional analytics.
3. Purposes, data composition, and grounds for processing
3.1. Consideration of the inquiry and feedback
3.1.1. Purposes of processing: reception and consideration of the appeal, clarification of the circumstances relating to it, preparation and direction of the response, subsequent interaction exclusively on this issue. With regard to the Site, this is: a preliminary analysis of the task of translating documents, clarifying requirements and preparing a response for translating documents from English into Russian. The main channel of appeal is email mail@perevodius.moscow.
3.1.2. The composition of the data: name or surname, first name and patronymic in the amount provided by the applicant; e-mail address; telephone number, if it is provided for response; text of the letter; information about the task; the applicant's own personal data in the necessary documents and applications; relevant information in subsequent correspondence. Unsolicited and redundant data are not used for other purposes.
3.1.3. To register the letter and confirm the circumstances of the appeal, the date and time of receipt, the sender's address, the topic, the message ID and the necessary service delivery information are used. With a separate consent, its content, date of receipt, method of expression and editing are retained. The site does not form a record of sending a web form and does not attach information about the behavior of the visitor to the letter.
3.1.4. The legal basis is determined by the content of the appeal. At the initiative of the subject himself to conclude a contract and when executing the contract, the party, beneficiary or guarantor of which he is, paragraph 5 of part 1 of Article 6 of the Law on Personal Data applies - exclusively to the extent of the necessary processing. For other applications, if there is no independent basis, the separately obtained and confirmed consent is applied - paragraph 1 of part 1 of Article 6. The contractual basis does not automatically apply to any data from attachments and information about third parties.
Contact by email
To ask an ordinary question or enquire about a service, simply send an email. You do not need to prepare consent using a template in advance, send it in a separate email, or repeat your question.
For entering into a contract at the initiative of the data subject, and for performing a contract to which the data subject is a party or under which they are a beneficiary or guarantor, paragraph 5 of part 1 of Article 6 of Russian Federal Law No. 152-FZ on Personal Data applies, solely to the data necessary for that purpose.
For other ordinary enquiries sent voluntarily, paragraph 7 of part 1 of Article 6 of the same law applies only where minimal processing is necessary for the legitimate interest of considering the enquiry and replying, is consistent with its purpose and the sender's reasonable expectations, and does not infringe the sender's rights and freedoms. The necessity of processing, the scope of the data and the permitted retention period are assessed for the particular enquiry; this is not blanket permission to process correspondence for any purpose.
Only the contact details, message and related information necessary for the enquiry are used. This procedure does not automatically authorise the processing of any and all data in attachments, information about third parties, special categories of personal data or biometric data. Advertising, optional analytics and publication of materials require their own applicable legal grounds and any necessary separate consents.
If consent is genuinely required for particular processing, a separate request specifying the purpose, categories of data, processing operations and duration will be sent before that processing begins. You do not need to send consent on your own initiative with every ordinary email.
3.1.5. The response is sent through the contacts specified by the applicant and the agreed channels. The telephone communicated to you on the matter is not used for advertising. In telephone clarification, only the information necessary for the request is processed; this description does not provide for an audio recording of conversations.
3.1.6. Applications are used to familiarize, clarify the circumstances and prepare a response. Initial submission does not allow publication, promotional use or transfer of files to analytics. The rules of transfer are set out in Terms of transfer and use of materials.
3.2. Conclusion and execution of a separate contract
3.2.1. If the parties conclude a contract, the purposes of processing are to agree on its terms, fulfill obligations, exchange documents and transfer the result. The amount of data is determined by the subject of the contract, and not by the fact of contact through the Site.
3.2.2. Data composition: necessary surname, first name and patronymic, contacts, addresses, information about the task, documents and materials; information about the representative and his/her credentials. Identification and payment details are requested only when necessary for a specific action. The presence of this provision does not mean the payment of pro bono assistance or the availability of payment on the Site.
3.2.3. Grounds: paragraph 5 of part 1 of article 6 - for these parties, the beneficiary or guarantor and the initiative of the subject to conclude a contract; paragraph 2 of part 1 of article 6 - for statutory obligations. A separate applicable basis shall be determined for representatives and other persons.
3.3. Fulfillment of duties established by law
3.3.1. Objectives - maintenance of mandatory accounting, if necessary, fulfillment of legitimate requirements and requests of authorized bodies. The composition of the data is limited by the content of the relevant obligation. Ground - paragraph 2 of part 1 of article 6 and the rules establishing such an obligation.
3.4. Claims and protection
3.4.1. Objectives: consideration of claims, settlement of disputes, protection of rights and legitimate interests, confirmation of the content of interaction and legality of processing.
3.4.2. Composition - documents and correspondence relating to a particular dispute, the necessary information about interaction and the minimum record of consent. Grounds - requirements of the law and paragraph 7 of part 1 of article 6, subject to respect for the rights and freedoms of the subject. This rule does not allow for the indefinite retention of all applications and applications.
3.5. Operation and security of the Site
3.5.1. The goals are the delivery of pages, detection of errors, protection from illegal requests and technical abuse. Composition - IP-address, date and time of request, page address, the result of processing the request and necessary information about the browser transmitted when connecting to the server.
3.5.2. Ground - paragraph 7 of part 1 of article 6: ensuring the work and security of the Site while respecting the rights and freedoms of the visitor. This information is not used on this basis for non-binding analytics or advertising.
3.6. Analytics and advertising
3.6.1. The Site has a separate choice interface for Yandex Metrics. The meter is off now. For the future active scheme, the purpose is to assess the attendance, use of pages and convenience of the Site; the composition is the IP address when the service receives a request, browser identifiers and visits, technical information about the device, page addresses without parameters and fragments, time and events of the visit. Ground - a separate consent under paragraph 1 of part 1 of article 6. When an active version is launched, consent is requested again. No advertising subscription is provided; consent to analytics does not include advertising and appeals.
4. Processing procedure and data recipients
4.1. Within the purposes and legal bases, collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer (provision, access), blocking, disposal and destruction are carried out. Processing is carried out using automation tools, without them or in a mixed way.
4.2. Consideration of the appeal is carried out by the Operator personally. Access is limited to the amount necessary for the corresponding function; the content of the appeal and applications is not placed in the public domain.
4.3. Technical placement and delivery of appeals are provided by the hosting and email infrastructure used by the Operator. The requirements of Part 3 of Article 6 shall apply. The actual recipients are notified to the subject in accordance with the procedure established by law. For the prepared analytical scheme, Yandex LLC is provided, address: d. Moscow, st. Leo Tolstoy, 16; the data are transmitted to this person only after separate permission and the actual inclusion of the counter. Now there is no transfer to Yandex Metrica. Attracting recipients does not relieve the Operator from obligations to the subject.
4.4. Under a separate contract, the provision of materials to the agreed participants in the execution is allowed only in the required amount on the applicable legal basis. The application itself does not allow the transfer of materials to any specialist.
4.5. The provision of data to the court and state bodies is carried out in cases and in the manner prescribed by law. Transfer of contacts to third parties for their independent advertising without a separate legal basis is not allowed.
4.6. When collecting personal data of citizens of the Russian Federation, the Operator ensures compliance with Part 5 of Article 18 of the Law on Personal Data on the Use of Databases in the Russian Federation. The choice of the postal service by the applicant does not cancel the duties of the Operator.
4.7. Prior to the beginning of cross-border transfer, the Operator complies with the requirements of Article 12 of the Personal Data Act, determines the recipients and provides the necessary information to the subjects. Consent to appeal does not nullify localization and requirements for cross-border transfer. Indication of Russian hosting in itself does not confirm the geography of all mail systems.
5. Processing, storage and disposal periods
5.1. Ordinary appeals for which the contract is not concluded, including correspondence and annexes, are stored within the period necessary for consideration, but not more than 90 calendar days from the date of the last meaningful message or agreed telephone clarification. If there was no continuation - from the date of receipt of the appeal. Automatic responses and service notifications do not extend the period.
5.2. The data of a separate contract are stored during the period of its execution and the retention periods of relevant documents established by law. After that, an independent basis is required. Mandatory storage of individual documents does not allow the preservation of all excess investments.
5.3. Regular technical security logs are kept for no more than 30 calendar days. Information about a specific incident may be retained longer only on an independent basis for the period necessary for the investigation or protection of rights.
5.4. The minimum record of consent may be kept on an independent basis for no more than three years from the date of its expression, if it is necessary to confirm the lawfulness of processing or protect rights while respecting the rights and freedoms of the subject. Composition: name, if indicated, contact, allowing to correlate consent with the appeal, separate text of consent, date and time, identifier of the message and edition of the document. The full initial appeal, the contents and names of its applications, redundant technical headings are not included. Such a limit does not imply an obligation to keep the record for all three years.
5.5. The information necessary for a specific claim or dispute is stored in the required amount on an independent basis. The reason and the period for such preservation are determined separately; ordinary correspondence is not automatically converted into an archive for the protection of rights.
5.6. Upon achievement of the purpose, expiry of the term or termination of the basis, data are deleted or destroyed, if an independent legal basis does not require continued storage. Upon achievement of the goal, the terms of subsection 21 4 of the Personal Data Act apply. Deletion covers mail, attachments, local copies, information systems used and copies from processors. Saving in “Sent”, “Archive” and “Basket” folders is counted as storage.
5.7. Upon withdrawal, processing on the basis of consent is terminated. If the data are no longer needed and there is no other reason, the destruction shall be ensured in accordance with subsection 21(5): as a general rule, not more than 30 days from the date of withdrawal, subject to exceptions established by law.
5.8. When requesting to stop processing, Article 21 § 5.1 applies: as a general rule, the processing is terminated not more than 10 working days; under the grounds provided for by law, the period may be extended for no more than five working days with a reasoned notification. Legal exceptions are accounted for separately.
5.9. If destruction is not possible within the time period provided for by law, the data shall be blocked and destroyed in accordance with the procedure of subsection 21 (6), as a general rule, no later than six months, unless another period is established by federal law. The presence of a backup copy in itself does not allow further use of the data.
6. Cookies, saving choices and analytics
6.1. Cookies – small browser entries; localStorage – entries on the device without a built-in deletion period. Sending appeals through the form is still disabled: the button opens the mail program.
6.2. To save and execute the selection, the necessary site_analytics_choice_v2 cookie signed by the server (HttpOnly, Secure, SameSite=Lax) and the localStorage site-analytics-choice-v2 record are used. The selection period is 180 days from its preservation. These records contain selection, technical identifier, editing and term; are not used for behavior analysis. An expired local record is deleted the next time you visit or check the deadline on an open page. When the Site is closed, local storage cannot be deleted by its code remotely.
6.3. The minimum server selection confirmation contains a random identifier, result, date and time, edition, document address and deletion period. It does not communicate with contacts, letters and files. On an independent basis, if necessary, confirmation of the legality of processing or protection of rights may be stored up to three years from the date of selection. Expired entries are deleted when accessing the journal and daily maintenance; if the base is lost, the data is deleted earlier. Regular technical journals remain within the term of paragraph 5.3.
6.4. Yandex Metric is now disabled, even if the visitor has chosen permission. Before the start of the counter, an active edition is published and a new choice is requested. In the active circuit, the meter is launched only after positive server confirmation. Before permission, after refusal, in case of confirmation error, on legal pages and when the configuration is turned off, requests are not sent to Metrica. Noscript pixel is not installed.
6.5. You can change the choice or revoke permission by clicking on the “Analytics Settings” button. Failure immediately blocks the counter in the browser, including in case of server saving error; the change applies to other open tabs. _ym’s own entries in cookies and localStorage are cleared when stopped. Previously transmitted data in Yandex systems are not automatically deleted by this action; the requirements for them are sent to the Operator.
6.6. For the future active scheme, the main cookies Metrics: _ym_uid and _ym_d - up to one year; _ym_isad - 20 hours; _ym_metrika_enabled - 60 minutes; _ym_visorc_* - 30 minutes with the WebVisor enabled. Additional entries and their purpose are given in Yandex documentation. Cookies do not determine the storage period of data on the server.
6.7. The deadline for analytical data attributable to the visitor or browser is up to three years from the date of collection, with early termination upon reaching the goal or withdrawal, if there is no other reason. The deadline must be provided by settings and actual deletion or depersonalization; the banner code does not change storage in Yandex. The webvisor in the current configuration is off. Upon subsequent legal connection, its records are limited to a service period of 15 days, including the current day.
6.8. The full conditions are set out in Analytics consents and Cookie policy. Deleting browser data does not delete emails and server logs. Technical failure and analytics authorization do not replace consent for other purposes.
7. Rights of the personal data subject
7.1. The personal data subject has the right to receive information about the processing of their personal data, to request its clarification, blocking, or destruction in cases provided by law, to withdraw consent to processing, as well as to appeal against the actions or inaction of the Operator in the manner prescribed by law.
7.2. Requests and inquiries from personal data subjects are accepted at the email address mail@perevodius.moscow or at the correspondence address specified in section 1 of the Policy.
7.3. For identification of the request, it is recommended to indicate the contact details used when sending it, the approximate date of sending, and the request identifier, if available. The Operator has the right to request proportionate proof of the subject’s identity or the authority of their representative. Requests provided for in Article 14 of the Personal Data Law are subject to the requirements for the content of the request established by that Article.
7.4. Information about the processing of personal data is provided to the subject or their representative within 10 working days from the date of the request or inquiry. If there are grounds provided by law, this period may be extended by no more than five working days with the sending of a motivated notification containing the reasons for the extension.
7.5. Withdrawal of consent does not affect the legality of processing carried out prior to its receipt. If the processing of certain data continues on an independent legal basis, the Operator informs the subject about such processing and its legal basis.
7.6. The subject has the right to seek protection of their rights from the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court.
8. Processing of personal data of third parties
8.1. The provision of documents and information by e-mail should be limited to the amount necessary for the consideration of the appeal. Before sending materials, it is recommended to exclude or hide excessive passport, financial, medical and other personal data.
8.2. The Applicant's consent applies to his personal data and does not constitute consent from other individuals whose personal data is contained in the submitted materials.
8.3. When materials are sent by a representative or personal data of third parties is provided, the Operator verifies the presence of the appropriate authority and legal basis for processing. In the absence of a sufficient legal basis, the data is not used for providing services and is subject to blocking and deletion within the timeframes prescribed by law.
8.4. The processing of special categories of personal data and biometric personal data is carried out in compliance with the requirements of Articles 10 and 11 of the Law on Personal Data. Expression of consent by means of an ordinary email does not replace written consent in cases where such a form is expressly provided for by law.
8.5. When transferring files, the applicant ensures the legality of receipt and the availability of the right to transfer them to the Operator for consideration of the application. Applies Terms of transfer and use of materials. The letter itself is not considered the consent of all persons in the documents and does not relieve the Operator from his duties. In case of doubt, permissions and grounds for transfer are requested, access is restricted, and the use of materials is suspended.
9. Protection of personal data and final provisions
9.1. The operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions. Such measures include access restriction, ensuring secure data transmission, control over storage periods, and compliance with requirements by engaged processors.
9.2. Destruction of personal data is carried out in ways that exclude the possibility of restoring its content in the information system and/or provide for the destruction of physical media containing personal data. The operator ensures documentary confirmation of destruction in cases and in the manner established by law.
9.3. The current version of the Policy is posted on the Website with the indication of the revision date. Changes to the Policy do not alter the scope of previously given consent. If subsequent processing requires new consent, such consent is obtained separately before the start of the relevant processing.
