General provisions
1.1. This Policy has been prepared under Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (“152-FZ”) and sets out how personal data is processed and protected by Yulia Sergeyevna Samarina (Самарина Юлия Сергеевна, the “Operator”).
1.2. The Operator is an individual who pays the Russian professional income tax, tax ID (INN) 645318253580. The Operator provides consultations and one-to-one training in applying artificial intelligence.
1.3. This Policy covers personal data processed by the Operator through the website https://samarina-ai.ru (including www.samarina-ai.ru) and its request form, and in email, phone and messenger correspondence about such requests.
1.4. This Policy is publicly available on the Operator’s website and is provided on request under Article 14 of 152-FZ.
Key terms
The terms of Article 3 of 152-FZ apply:
Personal data — any information relating to a directly or indirectly identified individual.
Operator — a person who organises and/or carries out personal data processing and determines its purposes and the data processed.
Processing — any action with personal data: collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer, depersonalisation, blocking, deletion and destruction.
Data subject (the “Subject”) — the individual whose data is processed.
Consent — a free, specific, informed and conscious expression of the Subject’s will permitting processing of their data.
Purposes of processing
3.1. Receiving and reviewing consultation requests submitted through the website form.
3.2. Contacting the Subject through the contact they provided or a channel they chose — to reply to the request, clarify the task and agree the time, terms and payment of a consultation.
3.3. Concluding and performing a consultation services contract if the Subject decides to use the service.
3.4. Keeping track of requests: marking that the Operator has contacted the Subject, within the period set out in section 8. The Operator does not send advertising or information mailings.
3.5. Performing obligations imposed on the Operator by Russian law, including tax law.
3.6. Responding to the Subject’s requests, including under Article 14 of 152-FZ.
3.7. Keeping the website working and secure: protecting the form against bulk and automated submissions.
Legal grounds
4.1. The Subject’s consent (Article 6(1)(1) and Article 9 of 152-FZ) — given by ticking the separate consent checkbox and submitting the request form.
4.2. Concluding and performing a contract to which the Subject is a party (Article 6(1)(5) of 152-FZ) — when the Subject orders a consultation on their own initiative. A request does not by itself conclude a contract or create an obligation to pay.
4.3. Performing obligations imposed on the Operator by Russian law (Article 6(1)(2) of 152-FZ) — tax obligations and responses to Subjects’ requests.
4.4. Exercising the Operator’s rights and legitimate interests (Article 6(1)(7) of 152-FZ) — protecting the form against abuse, provided the Subject’s rights and freedoms are not infringed.
Categories of subjects and personal data
5.1. Categories of subjects: people who submitted a request through the website form; clients who ordered a consultation; people who contacted the Operator about processing of their personal data; website visitors — only to the extent of technical request information.
5.2. Categories of data processed:
Name or another designation provided by the Subject.
Contact for the reply — phone number, email address or messenger username.
Task description, if the Subject filled in this optional field, and the content of later correspondence about the request.
Date and time of receipt, form language, internal number and status of the request.
Consent evidence: the fact of consent, server receipt time, version and checksum of the consent text, language and form page.
Information needed to conclude and perform the contract and to pay for the consultation, to the extent required for these purposes.
Technical information of requests to the website: IP address and request parameters needed to process the request. To limit how often the form can be submitted, an identifier derived from the IP address with a secret key is used; the original IP address is not stored in the request.
5.3. Data that is not processed:
The Operator does not request or intentionally process special categories of personal data (Article 10 of 152-FZ); information disclosed by accident is deleted.
Biometric personal data (Article 11 of 152-FZ) is not processed.
Data of minors — consultations are intended for adults.
Full bank card details — the Operator neither receives nor stores them.
Processing methods and data localisation
6.1. Actions with data: collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer (provision), depersonalisation, blocking, deletion and destruction.
6.2. Methods: mixed processing — automated (website, form, request database, private requests page, email, messengers, phone) and without automation.
6.3. Localisation (Article 18(5) of 152-FZ). When personal data is collected, including via the internet, recording, systematisation, accumulation, storage, clarification (updating, changing) and retrieval of personal data of Russian citizens are carried out by the Operator using a database located in the Russian Federation (Yandex Cloud, ru-central1 region). The website, form processing and the private requests page are hosted there as well. The Operator does not use databases located outside the Russian Federation.
If communication with the Subject takes place in an external messenger or email service chosen by the Subject, the Operator does not use that platform as a database for collecting, systematising, accumulating or storing requests: requests are stored in the database in the Russian Federation. Information the Subject posts on an external platform is processed by the platform owner under its own rules.
6.4. Backups of the request database are created automatically by Yandex Cloud in the Russian Federation and kept for 7 days. After data is deleted from the database, it is removed from backups within 7 calendar days. Backups are used only to recover from failures.
Transfer of personal data to third parties
7.1. The Operator does not sell personal data, pass it to advertising networks, publish it, use it for advertising mailings or pass it to artificial intelligence models.
7.2. Transfer is possible in the following cases.
7.2.1. Service signal about a new request. Via the Telegram Bot API the Operator receives only a message that a new request has arrived and when, with a link to the private requests page. The message contains no name, contact, task description, request number or other information that would link it to a specific requester. The signal is delivered through a technical server of Vercel Inc. (USA), which also receives no personal data of requesters. The Operator views the content of requests only on the private website page whose data is stored in the Russian Federation. No personal data is transferred through this channel.
The Operator’s Telegram bot is used only for such notifications. It does not accept requests and does not process incoming messages: messages sent to the bot do not reach the Operator’s servers.
7.2.2. Communication through an external platform chosen by the Subject — a messenger, email service, video call service or another channel. When such a channel is used, data is also processed by the platform owner under its rules. The Subject’s choice of an external channel does not replace a legal basis for processing and does not release the Operator from the requirements for cross-border transfer of personal data: before using a service that stores data outside the Russian Federation, the Operator determines the data to be transferred, the recipient and the country of processing, and complies with the applicable requirements of Article 12 of 152-FZ.
7.2.3. The Operator’s email is Yandex Mail, provided by YANDEX LLC (ООО «ЯНДЕКС»), OGRN 1027700229193, 16 Lva Tolstogo Street, Moscow, 119021. Sender and recipient addresses, message content and necessary delivery information are processed.
7.2.4. Infrastructure provider — Yandex.Cloud LLC (ООО «Яндекс.Облако»), INN 7704458262, OGRN 1187746678580, 16 Lva Tolstogo Street, premises 528, Moscow, 119021: website hosting, form processing and storage of the request database in the Russian Federation under a contract and data processing agreement.
7.2.5. Authorised state bodies — in the cases and to the extent provided by law.
7.3. Where processing is entrusted to another person, a processing agreement is concluded (Article 6(3) of 152-FZ). The Operator remains responsible to the Subject to the extent provided by law.
7.4. Personal data of requesters is not transferred across borders.
Processing and retention periods
8.1. Personal data is processed no longer than the purpose requires, within the validity of consent or another applicable legal basis. Achieving the purpose or withdrawing consent results in termination of processing and destruction of the data within thirty days, unless there is another legal basis for processing (Article 21(4) and (5) of 152-FZ).
8.2. Request data is processed until work on the request is completed, but for no more than 90 calendar days from its receipt. After this period the name, contact, task description and consent evidence are deleted from the database automatically; only the date, language, status and internal record number remain, without information about the requester.
8.3. After consent is withdrawn, processing stops and the data is destroyed within 30 days, unless there is another legal basis for keeping it.
8.4. Client data is processed for the term of the contract. After it is performed, only the information and documents needed to comply with legal obligations and to protect the Operator’s rights within the period in which contractual claims may be brought are kept (the general limitation period is three years, Article 196 of the Russian Civil Code).
8.5. Personal data enquiries are processed until they have been reviewed and fulfilled. Documents confirming destruction of personal data are kept for three years from destruction (Roskomnadzor Order No. 179 of 28 October 2022).
8.6. Technical records used to limit submission frequency are deleted after the 15-minute interval ends.
Security measures
9.1. The Operator applies the necessary legal, organisational and technical safeguards appropriate to the processing: access control, access to requests only through a password-protected private page, storing the password as a hash, limiting login attempts and form submissions, HTTPS connections, no logs containing request content, and regular automatic deletion of data that is no longer needed.
9.2. The Operator, Yulia Sergeyevna Samarina, is responsible for organising personal data processing. Enquiries about personal data processing are accepted at the addresses in section 13.
9.3. If an incident results in unlawful or accidental transfer of personal data, the Operator notifies Roskomnadzor within 24 hours, and of the results of the internal investigation within 72 hours (Article 21(3.1) of 152-FZ).
Rights of the Subject
10.1. Under Article 14 of 152-FZ the Subject may: obtain confirmation of processing and information on its conditions; know which data is processed and where it was obtained; demand clarification, blocking or destruction of data; withdraw consent at any time (Article 9(2) of 152-FZ); appeal against the Operator’s actions to Roskomnadzor or a court.
10.2. Procedure: send a request to samarina.iulya@yandex.ru with details that help find the request (name, contact from the request, approximate date) and the substance of the request. The reply is given within 10 working days. This period may be extended by no more than 5 working days with a reasoned notice (Article 20 of 152-FZ). Please do not send a passport scan unless the Operator asks for it.
10.3. Withdrawal of consent — by email to samarina.iulya@yandex.ru with the subject “Withdrawal of consent to personal data processing”, or by letter to the postal address in section 13.
Changes to this Policy
12.1. The current version of this Policy is always available on the Operator’s website with its date and version number. Changes to this Policy do not extend consent already given: if new terms require consent, it is requested separately.
Operator contact details
Operator: Yulia Sergeyevna Samarina (Самарина Юлия Сергеевна), professional income tax payer.
Tax ID (INN): 645318253580.
Address: 175-3 Shelkovichnaya Street, Saratov, 410071, Russia (410071, г. Саратов, ул. Шелковичная, 175-3).
Email for personal data enquiries: samarina.iulya@yandex.ru
Roskomnadzor: rkn.gov.ru
Version date: 15 September 2026.