Personal Data Processing Policy
This is a placeholder for the mock-up. Before the site launches, a lawyer will adapt the text to the applicable legislation, and the operator's details will be added. Places that need to be filled in are marked [like this].
Who processes the data
The personal data operator is Artem Zernov, the owner of the website [site domain].
Operator details: [legal form: individual, sole proprietor or organization; taxpayer identification number (INN); address]. For questions about your data: hello@artemzernov.me.
What data is collected
Only what you enter into the forms on the website yourself. Nothing is collected covertly.
Subscription to my thoughts: your email address.
Getting acquainted: your name, your email or Telegram username, and, if you wish, a few words about yourself.
Writing directly: whatever you write on Telegram or by email. This data reaches me through those services themselves, not through the website.
The website does not request passport details, phone numbers, addresses, information about health or beliefs, or other special categories of personal data. Please do not include them in the “About you” field.
For what purpose
The email address from the subscription is used to send you emails with new texts and thoughts. There is no fixed schedule and no third-party advertising.
Your name, contact details and the text about yourself are used so that I can read it and reply to you personally and, if there is reason to, arrange a conversation.
The data is not used for advertising, is not sold and is not used for automated decision-making about you.
Legal basis
The legal basis is your consent. You give it by ticking the “I consent to the processing of personal data” checkbox before submitting a form. The form cannot be submitted without the checkbox.
Processing is carried out in accordance with Federal Law No. 152-FZ “On Personal Data” [the lawyer will clarify the applicable law and, where necessary, the requirements of the GDPR].
Where and how the data is stored
The data is stored on a server [hosting provider and country of location] and in the mailing service [name of the service]. Only I have access to it.
Data is transmitted from the website over a secure connection (HTTPS). Access to the server and the mailing service is protected by passwords and two-factor authentication [to be confirmed before launch].
How long the data is stored
The subscription email address: for as long as you remain subscribed. After you unsubscribe, the address is deleted within 30 days.
Messages from the acquaintance form: for as long as the correspondence continues, and no longer than [period, for example three years] after the last message, unless you ask for earlier deletion.
To whom the data is disclosed
To no one except the technical services without which the website cannot operate: the hosting provider and the mailing service. They store the data on my instructions and do not use it for their own purposes.
Data may be disclosed to government authorities only in cases expressly provided for by law.
What the website stores in your browser
The website stores one setting in your browser: your chosen theme, light or dark. This is not personal data, and it is not transmitted to the server.
There are currently no analytics systems or advertising trackers on the website. [If analytics is connected before launch, the lawyer will describe it here.]
Your rights
To find out what data about you I hold.
To ask for it to be corrected if it is inaccurate.
To ask for it to be deleted in full.
To withdraw your consent at any time.
To file a complaint with the authorized body for the protection of the rights of personal data subjects [for Russia, Roskomnadzor].
I respond to requests within 10 business days [the lawyer will check this period against the law].
How to withdraw consent
For the newsletter, click “Unsubscribe” in any email. That is sufficient.
For everything else, write to hello@artemzernov.me or on Telegram to @artprog: “Please delete my data.” You do not need to give a reason.
After consent is withdrawn, I stop processing the data and delete it within 30 days, unless the law requires it to be kept longer.
Newsletter
The “Thoughts” newsletter consists of emails with new texts from the website. There is no fixed schedule and no third-party advertising.
Two separate consents. When subscribing, you tick two checkboxes: consent to the processing of your email address and consent to receiving emails. Without either of them, the subscription is not created. The text of each consent, the date, time, IP address and browser are recorded so that I can confirm that consent was given.
Address confirmation. After you submit the form, you receive an email with a link. The subscription takes effect only when you click the “Confirm subscription” button on the website page. An unconfirmed subscription is deleted after [30] days.
Unsubscribing. Every email contains an “Unsubscribe or manage your subscription” link; email clients that support it also show a one-click unsubscribe button. Unsubscribing takes effect immediately.
Who sends the emails. Emails are sent from the website's mail server [if a mailing service is connected, its name and country; the service receives the address only at the moment of sending and on my instructions].
How long the address is stored. For as long as you remain subscribed. [30] days after you unsubscribe, the address is anonymized: only the texts and dates of the consents remain in the database, without the address, IP address or browser.
Email opens and link clicks are not tracked.
Changes to this policy
If the policy changes, the new version will appear on this page with a new date. If the changes affect how data that has already been collected is used, I will notify subscribers separately.