Personal Data Processing Policy

Operator: IE Ezepenko Sergey Nikolaevich

INN 772774965944

OGRNIP 315774600130049

Website potokmarketing.ru

Phone +7 (985) 272-74-37

E-mail [email protected]

Date adopted 20 August 2026

Version 2.0

Language note. This is an English translation of the Russian-language Policy published by the Operator. The Russian version is the governing text: should there be any discrepancy between the two, the Russian version prevails. Russian version: privacy-policy.html.

1. General provisions

1.1. This Personal Data Processing Policy (the "Policy") has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (as currently in force), Decree of the Government of the Russian Federation No. 1119 of 1 November 2012, Order of Roskomnadzor No. 179 of 28 October 2022, and other regulatory acts of the Russian Federation in the field of personal data.

1.2. The personal data operator is: IE Ezepenko Sergey Nikolaevich, INN 772774965944, OGRNIP 315774600130049, address: Moscow.

1.3. The Policy applies to all information that the Operator may obtain about visitors to and users of the website potokmarketing.ru (the "Website"), as well as about persons who request a consultation or purchase services.

1.4. Use of the Website, completion of any forms, submission of requests, and use of the chatbot and AI services on the Website constitute the user's unconditional consent to this Policy and to the processing terms set out in it. If a user does not agree with this Policy, the user must refrain from using the Website and from sending any data to the Operator.

1.5. The Operator undertakes not to transfer personal data to third parties otherwise than in accordance with the terms of this Policy.

2. Definitions

The following basic concepts are used in this Policy:

3. Categories of personal data processed

3.1. The Operator processes the following categories of personal data:

Type of dataExample / compositionSource
Phone number+7XXXXXXXXXXForm on the Website, AI chat, quiz
Messenger IDTelegram, WhatsApp, VKontakteForm on the Website, AI chat
Name / contact detailsName, e-mail addressForm on the Website, enquiries via AI services
Content of enquiriesText of chat/quiz messages, business information provided by the userAI chat, quizzes, correspondence
CookiesTechnical, analytical and advertising cookies (including Yandex.Metrica and Google Analytics)Automatically when the Website is visited
Technical dataIP address, browser type, device dataAutomatically (log files, Metrica)

3.2. The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious beliefs, health status, intimate life and others), nor biometric personal data.

3.3. The Operator does not take automated decisions producing legal consequences for the data subject solely on the basis of automated processing of their data. The use of AI services is auxiliary in nature: final decisions on cooperation are taken by a human.

4. Purposes and legal grounds for processing

4.1. Personal data is processed only where a lawful ground exists. All operations of the Operator in the field of personal data comply with the requirements of Articles 6, 9 and 10 of Federal Law No. 152-FZ.

Purpose of processingData processedLegal ground
Feedback, consulting, conclusion and performance of a contractPhone, messenger ID, name, content of enquiriesConsent (Art. 9 of 152-FZ), contract
Sale of services (marketing support, advertising and funnel setup, implementation of AI agents)Phone, messenger ID, business informationConsent (Art. 9 of 152-FZ)
Operation of AI services (chatbot, quizzes, diagnostics)Content of enquiries, phone, messenger IDConsent (Art. 9 of 152-FZ), legitimate interest
Web analytics, improvement of the WebsiteCookies, IP address, device dataConsent (Art. 9 of 152-FZ)
Targeted and retargeting advertisingAdvertising and analytical cookiesConsent (Art. 9 of 152-FZ)

4.2. Consent to the processing of personal data is given by the data subject by confirming that they have read this Policy and completing a form on the Website, or by using the AI services. Consent may be withdrawn at any time by sending a written request to the Operator (contact details in section 11).

5. Procedure and conditions of processing

5.1. Personal data is processed strictly to the extent necessary to achieve the purposes specified in section 4 of this Policy.

5.2. The Operator uses the following methods of processing personal data: collection, recording, systematisation, accumulation, storage, updating (renewal, amendment), use, transfer in the cases provided for by this Policy, anonymisation, destruction.

5.3. Processing is carried out by the Operator in a mixed manner (with and without the use of automation tools).

5.4. Where personal data is processed using AI services, the Operator takes measures to anonymise the data before it is submitted to artificial intelligence models, where this is possible without prejudice to the purposes of processing.

5.5. Transfer of personal data to third parties is permitted only in the cases provided for by section 7 of this Policy.

5.6. Processing of personal data for direct marketing purposes (mailings) is carried out only with the separate consent of the data subject.

6. Retention periods and destruction of personal data

6.1. Personal data is stored by the Operator no longer than the purposes of processing require, and where processing is based on consent — until the data subject withdraws that consent.

6.2. After the purposes of processing have been achieved or consent has been withdrawn, personal data is destroyed (anonymised) within a period not exceeding 30 (thirty) days, unless another period is established by applicable legislation of the Russian Federation.

6.3. Records of consent (IP address, date, time, text of the consent) are stored for at least 3 years in accordance with Art. 9 of 152-FZ and the explanations of Roskomnadzor.

6.4. Cookies are stored on the user's device for the period established for the relevant type of cookie (see section 8).

6.5. Data processed in order to comply with legal requirements (tax accounting, bookkeeping) is stored for the periods established by the relevant regulatory acts.

7. Transfer of personal data to third parties

7.1. The Operator is entitled to transfer personal data to the following categories of recipients, strictly to the extent necessary for the performance of the relevant function:

RecipientType of dataPurpose / note
Yandex LLC (Yandex.Metrica, Yandex Advertising Network)Cookies, IP, behavioural dataAnalytics of visits to the Website and display of targeted advertising. Yandex processes data in accordance with its own privacy policy (yandex.ru/legal/confidential)
Google LLC (Google Analytics 4)Cookies, IP address, device and behavioural dataVisit statistics for the English-language version of the Website: traffic sources, on-site behaviour, goal completion. Analytics cookies are set only after consent. Google processes data in accordance with its own privacy policy (policies.google.com/privacy)
AI model providersAnonymised content of enquiriesOperation of AI services (chat, content generation). Data is processed in anonymised form
Messenger platforms (Telegram, WhatsApp, VKontakte)Messenger ID, phoneDelivery of messages to the user
Public authorities of the Russian FederationOn request / in established casesCompliance with the requirements of Russian legislation

7.2. The Operator does not sell, rent out or otherwise transfer personal data of data subjects to third parties on a paid basis for commercial purposes unrelated to the provision of services to the data subject.

7.3. Cross-border transfer of personal data to the territory of foreign states is carried out in the manner established by the legislation of the Russian Federation, in compliance with the requirements of Art. 12 of 152-FZ.

8. Use of cookies

8.1. The Website uses cookies — small text files stored on the user's device. Cookies alone do not allow the user to be identified as a specific natural person, but may constitute personal data when combined with other information.

8.2. Three categories of cookies are used on the Website:

Type of cookiePurposeExamples / retention
Technical (strictly necessary)Ensuring the operation of the Website, saving settings, CSRF protection. Disabling them may impair the operation of the WebsiteSession cookies (until the browser is closed) and persistent cookies (up to 1 year)
AnalyticalCollecting visit statistics via Yandex.Metrica and Google Analytics 4: traffic sources, on-site behaviour, goal completionUp to 2 years (Yandex.Metrica); up to 2 years (Google Analytics)
Advertising (marketing)Display of targeted advertising via the Yandex Advertising Network and Google Ads; conversion tracking; retargetingUp to 90 days (Yandex.Direct)

8.3. The user is entitled to refuse analytical and advertising cookies by adjusting their browser settings or by using the Yandex opt-out mechanism (https://yandex.ru/support/metrica/general/opt-out.html) or by installing the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout). If technical cookies are disabled, correct operation of the Website is not guaranteed.

8.4. The first visit to the Website is accompanied by a notice (information banner) about the use of cookies. Continued use of the Website after reading the notice is regarded as consent to the use of cookies in accordance with this Policy.

9. Rights of data subjects

9.1. The data subject has the following rights under Federal Law No. 152-FZ:

9.2. To exercise their rights, the data subject may send a written request to the Operator at the address specified in section 11 of this Policy. The Operator reviews requests and replies to them within a period not exceeding 10 (ten) business days from receipt.

10. Measures to ensure the security of personal data

10.1. The Operator takes the necessary legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as other unlawful actions, in accordance with the requirements of Decree of the Government of the Russian Federation No. 1119 of 1 November 2012.

10.2. Security is ensured by the following measures:

10.3. In the event of a personal data breach, the Operator must notify Roskomnadzor within 24 hours (as regards the fact of the breach itself) and 72 hours (as regards the results of the internal investigation) — in accordance with the amendments to 152-FZ that entered into force on 1 March 2023.

11. Operator contact information

For all matters relating to the processing of personal data, and in order to exercise the rights of data subjects, please contact:

Operator IE Ezepenko Sergey Nikolaevich

INN 772774965944 / OGRNIP 315774600130049

Website potokmarketing.ru

Phone +7 (985) 272-74-37

E-mail [email protected]

The person responsible for organising the processing of personal data: Ezepenko Sergey Nikolaevich.

12. Amendments to the Policy

12.1. The Operator reserves the right to amend this Policy without prior notice to data subjects.

12.2. The current version of the Policy is always available on the Website at potokmarketing.ru/privacy-policy (Russian) and at potok-marketing.com/privacy-policy-en.html (English).

12.3. The date of the last update is indicated in the header of the document. We recommend checking the Policy periodically.

12.4. Continued use of the Website after amendments to the Policy have been made constitutes acceptance of the amended terms.