This policy explains how SLCTR processes and protects the personal data of visitors to slctr.org. It is drafted to meet the requirements of Russian Federal Law No. 152-FZ “On Personal Data” and, where applicable, the EU General Data Protection Regulation (GDPR).
01Who we are
- The controller (operator) of your personal data is SLCTR, the owner of slctr.org (“SLCTR”, “we”, “us”).
- This policy applies to all information we may receive about visitors to slctr.org and its subdomains (the “Website”, “you”).
- By using the Website and submitting data through its forms, you confirm that you have read this policy. If you disagree with it, please do not send us personal data.
02Data we process
We only process data needed for the purposes listed below.
| Category | What it includes | Source |
|---|---|---|
| Enquiry data | Name; contact details (Telegram, phone number or email address); website or company name; indicative marketing budget; message text | You enter it in the Website form |
| Correspondence | Content of emails and messages you send to support@slctr.org | You |
| Technical data | IP address, browser and device type, date and time of request, requested page, referring page | Automatically, in hosting logs, when you access the Website |
| Browser storage | A flag recording that you have seen the cookie notice | Automatically, see the cookie policy |
We do not process special categories of personal data or biometric data. Please do not include such information in your enquiry. The Website is not intended for anyone under 18, and we do not knowingly collect their data.
03Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Replying to your enquiry, clarifying your needs and preparing a proposal | Your consent (152-FZ art. 6(1)(1); GDPR art. 6(1)(a)) and steps taken at your request before entering into a contract (GDPR art. 6(1)(b)) |
| Entering into and performing a services contract | Contract (152-FZ art. 6(1)(5); GDPR art. 6(1)(b)) |
| Keeping the Website secure and preventing abuse | Our legitimate interests (152-FZ art. 6(1)(7); GDPR art. 6(1)(f)) |
| Complying with legal obligations | Legal obligation (152-FZ art. 6(1)(2); GDPR art. 6(1)(c)) |
We do not use enquiry data for marketing mailings without your separate consent, do not make decisions with legal effects based solely on automated processing, and do not sell personal data.
04How we process data
- Processing is carried out with and without automation and includes collection, recording, organisation, storage, updating, retrieval, use, transfer (provision, access), restriction, erasure and destruction.
- Only staff and contractors who need the data to do their job have access to it, and they are bound by confidentiality.
- We do not disclose personal data to third parties without your consent unless the law requires it.
05Sharing and international transfers
We share personal data only with:
- infrastructure providers — hosting, content delivery and email — who process data on our behalf solely to run the Website and communicate with you;
- public authorities, where and as required by law.
The Website’s infrastructure (hosting and content delivery network) may be located in different countries, so technical data may be transferred internationally. Such transfers are made in compliance with applicable law, including art. 12 of 152-FZ and, where GDPR applies, with appropriate safeguards such as standard contractual clauses.
06Retention
| Data | How long |
|---|---|
| Enquiry data and correspondence where no contract follows | Until the purpose is achieved, but no longer than 3 years after your last contact, or until you withdraw consent — whichever is earlier |
| Data related to a signed contract | For the term of the contract and thereafter for periods required by accounting and archiving laws |
| Technical logs | No longer than 12 months |
| Browser storage | Until you clear it, see the cookie policy |
When the period ends or the purpose is achieved, personal data is destroyed or anonymised.
07Your rights
You have the right to:
- access information about how your personal data is processed and obtain a copy of it;
- have inaccurate or incomplete data corrected;
- have data erased or its processing restricted where it is unlawful, no longer needed or you withdraw consent;
- object to processing based on our legitimate interests;
- receive data you provided in a portable format (where GDPR applies);
- withdraw consent at any time without affecting the lawfulness of prior processing;
- lodge a complaint with a data protection authority — in Russia, Roskomnadzor; in the EU, the supervisory authority of your country — or go to court.
To exercise your rights, email support@slctr.org. Tell us how to address you and the contact you used in your enquiry so we can find your data and verify the request came from you. We reply within 10 business days of receiving your request; this may be extended once by up to 5 business days, in which case we will explain why.
08Security
We use legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, alteration, restriction, copying, disclosure and distribution, including:
- transmitting data between your browser and the Website only over encrypted HTTPS;
- limiting access to the people who need it and using individual accounts;
- not embedding third-party advertising or analytics trackers on the Website;
- regularly reviewing our safeguards and the data we hold.
09Changes to this policy
We may update this policy, for example when the data we process or legal requirements change. The new version is published on this page with its date and takes effect on publication unless stated otherwise. Previous versions are available on request.
10Contact
For any question about personal data, write to support@slctr.org.
Other documents: Consent to Personal Data Processing · Terms of Use · Cookie Policy