Personal Data Processing Policy
Version of 7 October 2026
Contents
This English version is provided for the convenience of visitors. In case of any discrepancy, the Russian version published at https://bogdancreates.ru/privacy/ prevails.
1. Who processes your data
The personal data operator (the “Operator”) for the website https://bogdancreates.ru (the “Site”):
- name: Bogdan Tsviliuk;
- email: giantsofhits@yahoo.com;
- phone: +7 905 859-09-01.
The Operator personally organises the processing of personal data and is responsible for it. Processing is governed by Russian Federal Law No. 152-FZ “On Personal Data” of 27 July 2006 (the “Personal Data Law”).
2. What we process, why and for how long
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| Booking the free studio lighting lesson and contacting you about your request | name; the contact you choose — phone number (including for WhatsApp), Telegram username or email address; comment (optional); date and time of submission; IP address and browser details (User-Agent) of the submission; record of your consent | your consent (Art. 6(1)(1) of the Personal Data Law) | until the purpose is achieved, but no longer than 12 months from submission, or until you withdraw consent; expired requests are deleted automatically (the clean-up runs when a new request arrives and when the Operator signs in to the admin panel) |
| Replying to your messages and requests | name, contact details, content of the message | legal obligations of the Operator (Art. 6(1)(2)); legitimate interest in correspondence you started (Art. 6(1)(7)) | 12 months after the last message; data subject requests and replies — 3 years |
| Visit statistics via Yandex Metrica — only after you click “Accept” | cookie identifiers; IP address; browser, operating system and device data; pages viewed and referring page; date, time and duration of the visit; actions on pages (scrolling, clicks, outbound link clicks, pointer movements); achievement of goals (form sent, contact buttons clicked, link to a publication opened) without the contents of the form; if the Webvisor feature is enabled, a replay of actions without the contents of form fields; approximate location derived from the IP address | your consent (Art. 6(1)(1)) | consent is valid for 12 months or until withdrawn; Metrica cookies are kept in your browser for up to 1 year |
| Security and operation of the Site | IP address; date and time of the request; requested URL; server response code; browser and device data; referring page; an irreversible hash of the IP address and the time of the request (protection of the form against spam); log of logins to the Site’s admin panel (date and time, the account name entered, IP address, result) | legitimate interest in protecting the Site (Art. 6(1)(7)) | web server logs — up to 30 days; IP hashes — 7 days, then deleted automatically while the Site is running; admin login log — the last 500 entries |
| Showing photographic work | image of the person; name only if the person has agreed | consent of the person (Art. 152.1 of the Civil Code, Art. 10.1 of the Personal Data Law) or the exceptions provided by Art. 152.1 of the Civil Code, within the Operator’s creative activity (Art. 6(1)(8)) | as stated in the consent or until the person asks for removal |
We do not process special categories of personal data or biometric data, do not make decisions based solely on automated processing, do not send marketing messages, and do not collect data of persons under 18 through the Site.
3. Where your data is stored and who receives it
Personal data collected through the Site is stored in databases located in the Russian Federation, as required by Art. 18(5) of the Personal Data Law. Country where the Site’s servers are located: Russian Federation.
Only the Operator has access to lesson requests and messages. The Operator does not disclose them to third parties and does not transfer data collected through the Site abroad. Notifications about new lesson requests that the Site sends to the Operator by email or Telegram contain only the request number and a link to the admin panel — no name, contact or comment. Data may be provided to public authorities only where required by Russian law.
Visit statistics are processed on the Operator’s behalf by YANDEX LLC (16 Lva Tolstogo Street, Moscow, 119021, Russia) under the Yandex Metrica terms of use, and only after you click “Accept”.
If you contact the Operator via Telegram, WhatsApp or Instagram*, or give a Telegram username or a WhatsApp phone number in the lesson request, the conversation takes place on the service you have chosen. These services belong to foreign companies and process conversation data under their own terms. If you prefer not to use them, give a phone number for calls or an email address, or email giantsofhits@yahoo.com.
4. Cookies
Essential cookies remember your choice in the consent window (the cc cookie and an entry in the browser’s local storage, kept for 12 months) and keep the Operator’s admin session working (a session cookie, for the Operator only). They are used without separate consent and are not used for analytics.
Analytics cookies (_ym_uid, _ym_d, _ym_isad, _ym_visorc, _ym_metrika_enabled, yandexuid, i, yabs-sid, ymex and _ym… entries in browser storage) are set by Yandex Metrica only after you click “Accept”. They are kept for up to 1 year.
You can change your choice at any time via “Cookie settings” at the bottom of any page. After you decline, the Metrica counter is not loaded and its cookies on the Site’s domain are deleted. You can also delete cookies in your browser settings or install the Yandex Metrica opt-out add-on: https://yandex.ru/support/metrica/ru/general/opt-out. Declining analytics cookies does not limit your use of the Site.
The Site does not use advertising cookies or analytics services other than Yandex Metrica.
5. Your rights
You have the right to obtain information about the processing of your data; to request rectification, blocking or destruction of data that is incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary; to withdraw your consent; to request that processing be stopped; to request removal of a photograph showing you; and to lodge a complaint with Roskomnadzor, the Russian data protection authority (rkn.gov.ru), or with a court. If you are located outside Russia, the law of your country may give you additional rights — contact us to exercise them.
6. How to contact us and response times
Send requests by email to giantsofhits@yahoo.com.
- Information about processing: within 10 business days (may be extended by up to 5 business days with a reasoned notice).
- Withdrawal of consent: processing stops and the data is destroyed within 30 days.
- Request to stop processing: within 10 business days.
- Removal of a photograph showing you: within 3 business days.
To withdraw consent or delete a lesson request, an email sent from, or mentioning, the contact given in the request is sufficient.
7. How we protect your data
Data travels between your browser and the Site only over HTTPS. Only the Operator can access the admin panel, using a personal account with a strong password, a limit on failed login attempts and a record of logins. The database is hosted in Russia and backed up regularly; backups are overwritten within 30 days. Software is kept up to date and spam submissions are filtered without sharing data with third parties. The Site does not load fonts, scripts or widgets from third-party servers that could receive your data without your consent. Lesson requests are deleted automatically after the retention period ends: the clean-up runs when a new request arrives and when the Operator signs in to the admin panel after the period has ended. Each deletion is recorded in a log that contains no personal data. In the event of a data breach, the Operator notifies Roskomnadzor within 24 hours and reports the results of the investigation within 72 hours.
8. Changes
The Operator may update this Policy. The new version takes effect when published on the Site; the date of the current version is shown at the top.
* Instagram is owned by Meta Platforms Inc., which has been designated an extremist organisation; its activities are banned in the Russian Federation.