Privacy Policy
This Privacy Policy (the "Policy") governs the information processed on the websites lyubarsky.info and lyubarsky.ru (the "Site") and is drafted in accordance with the Russian Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (the "152-FZ") and the European Union General Data Protection Regulation (GDPR).
1. Controller and contacts
The controller determining the purposes and means of data processing on the Site is Sergey N. Lyubarsky (the "Controller"). For any questions related to personal data processing or to exercising your rights, contact: sergey@lyubarsky.info.
2. What data is processed
The Site is a personal business card site and blog. It has no user registration, contact forms, comments or file uploads. Therefore, the Controller does not collect names, email addresses, phone numbers or any other data that could directly identify a user.
The following information is processed automatically by analytics tools:
- cookies and browser local storage data;
- IP address (in a pseudonymized form), session date and time;
- information about devices and browsers used (device type, operating system, screen resolution, interface language);
- information about user actions on the Site (pages viewed, navigation, clicks, scrolling, referral sources);
- approximate geo-location at country/city level.
If a user sends the Controller an email directly, the data provided in that email (email address and message content) is processed solely to respond to the inquiry.
3. Purposes and legal bases of processing
Data is processed for the following purposes:
- ensuring the Site works and renders correctly (technical and functional cookies);
- storing user preferences (theme, consent state) in the browser's local storage;
- improving the Site, determining user preferences and collecting pseudonymized statistics (Yandex.Metrika);
- ensuring the security of the Site and protecting it from abuse.
Legal bases: the user's consent (Art. 6 of 152-FZ; Art. 6(1)(a) GDPR) for cookies and analytics tools; the Controller's legitimate interest (Art. 6(1)(f) GDPR) for technical cookies required for the Site to function.
4. Technologies and counters used on the Site
The Site uses the web analytics service Yandex.Metrika (Yandex LLC, 16 Lva Tolstogo St., 119021 Moscow, Russia), which collects pseudonymized statistics about visits: pages viewed, referral sources, device and browser information, clicks and scrolling (click maps and link tracking are enabled). Session recording (Webvisor) is not used. Data processing by Yandex.Metrika is carried out in accordance with Yandex's privacy policy and terms of use; Yandex servers are located on the territory of the Russian Federation.
Yandex.Metrika starts processing data only after the user gives consent (after clicking "Agree" in the consent notice). Until then, the counter is not loaded on the Site.
The browser's local storage stores: the selected theme and the consent state. This information is not shared with third parties and is deleted together with the site data in the browser settings.
The Site does not use advertising networks, does not show ads and does not share data with advertising partners.
5. Cookies
The Site uses the following types of cookies:
- Strictly necessary — ensure the Site works correctly; do not require consent.
- Functional — store user preferences (theme).
- Analytics — set by Yandex.Metrika (_ym_uid, _ym_d, _ym_isad and others) and used to collect pseudonymized statistics.
You can restrict the Site's use of cookies and delete them, as well as clear local storage, in your browser settings at any time.
6. Processing conditions and third parties
Data is processed by the Controller and, for statistics, by Yandex LLC under a data processing agreement. The Controller does not sell, transfer or disclose user data to third parties, except as required by the legislation of the Russian Federation and/or applicable law.
No cross-border transfer of personal data takes place: the Site is hosted on servers located on the territory of the Russian Federation, and data processing by Yandex is also carried out on the territory of the Russian Federation.
7. Retention periods
Technical and functional cookies are kept until the end of the session or until deleted by the user. Local storage data is kept until deleted by the user in the browser settings. Statistics collected by Yandex.Metrika is processed for the periods set by the service, but no longer than necessary to achieve the purposes of processing.
8. Your rights
Under 152-FZ, you have the right to:
- obtain information about the processing of your data;
- request the rectification, blocking or erasure of your data;
- withdraw your consent to data processing;
- lodge a complaint with the supervisory authority (Roskomnadzor).
Under GDPR, users located in the European Union additionally have the right to access, rectification, erasure, restriction of processing, data portability, objection to processing and the right to lodge a complaint with a supervisory authority in their country of residence.
To exercise your rights, send a request to: sergey@lyubarsky.info. Requests are handled within the period set by applicable law (no more than 30 days).
9. Consent and its withdrawal
By continuing to use the Site, you consent to the processing of your data (cookies, information about your actions and devices) in accordance with this Policy. Consent is given by clicking "Agree" in the consent notice and is valid from the moment it is provided for the entire period of using the Site. If consent is not provided, analytics tools are not started on the Site.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
10. Data protection
Data is transferred between the user and the Site over the secure HTTPS protocol. The Controller applies the necessary organizational and technical measures to protect data from unauthorized access, alteration, disclosure or destruction.
11. Changes to this Policy
The Controller may update this Policy from time to time. The current version is always available on this page. Continued use of the Site after changes to this Policy means acceptance of the updated version.
12. Contacts
Questions, suggestions and requests regarding this Policy: sergey@lyubarsky.info.
