ZARYA · Legal Documents
Privacy Policy
Version 2.0 · Effective date: 6 July 2026
1. General Provisions
This Privacy Policy (the “Policy”) is issued in accordance with Clause 2, Art. 18.1 of Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006, as amended (“152-FZ”), and governs the processing of personal data of users of ZARYAINTEL.COM (the “Site”).
The data controller is ZARYA, operating as a sole proprietor registered under Russian law. A separate legal address is not required by law for an individual entrepreneur; for contact details, see Section 9. Full registration details of the controller are disclosed to the client individually as part of the contracting process.
This Policy is governed by Russian Federal Law No. 152-FZ. Where we process personal data of individuals located in the European Union, we additionally apply the general data protection principles reflected in the EU General Data Protection Regulation (GDPR) — such as purpose limitation, data minimisation, and transparency — as a matter of good practice, without this constituting a formal representation of full GDPR compliance.
2. Data We Collect
When using the Site's contact form, we collect:
- full name;
- email address;
- phone number;
- the name of the organisation you represent (if provided);
- the content of your inquiry.
Technical data (IP address, browser type, visit time) is processed as part of standard web server logging. Special categories of personal data and biometric data are not requested or processed via the Site.
3. Purposes of Processing
Collected data is used exclusively for:
- establishing and maintaining contact regarding your inquiry;
- preparing a commercial proposal;
- concluding and performing a contract.
Processing for other purposes is not permitted without the separate consent of the data subject. Data is not used for marketing purposes without separate consent and is not disclosed to third parties, except as expressly provided by contract or law.
4. Legal Basis for Processing
Processing is carried out on the following legal bases:
- consent of the data subject (Art. 6 152-FZ);
- performance of a contract to which the data subject is a party;
- requirements of Russian law.
5. Storage, Security & Retention Period
Personal data is stored on secure servers located in the Russian Federation. The following measures are applied:
- encryption of data in transit (TLS);
- role-based access control;
- logging of operations involving personal data;
- regular backups.
The retention period for contact form data is no more than 3 (three) years from the date of last interaction or until consent is withdrawn, whichever occurs first, unless otherwise required by contract or law.
6. Cookies
The Site uses Yandex.Metrica, a web analytics system that sets cookies to analyse traffic and visitor behaviour (pages viewed, time on site, referral source). Processing of data within Yandex.Metrica is carried out in accordance with Yandex's own privacy policy. The data collected is used exclusively to improve the Site and is not shared with third parties, except as required by the legislation of the Russian Federation. Separately from the analytics cookie, a strictly technically necessary cookie is used: it is used exclusively for authentication in the Site's restricted administrative panel, is set only when an administrator logs in, lasts 15 minutes, and is protected by the httpOnly, Secure, and SameSite=Lax attributes (not accessible to browser JavaScript).
7. Cross-Border Data Transfer
Personal data collected via the Site's contact form is not transferred outside the Russian Federation: the server hosting the Site and the hosting and email services used by the Controller are physically located in the territory of the Russian Federation.
8. Data Subject Rights
You have the right to:
- obtain information about the processing of your personal data;
- request correction of inaccurate data;
- request deletion of data where there is no lawful basis for its retention;
- withdraw consent to processing at any time;
- lodge a complaint with Roskomnadzor.
To exercise these rights, send a request to: hello@zaryaintel.com. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its receipt.
9. Changes to the Policy & Contact
The Controller may update this Policy unilaterally. The current version is published on the Site and takes effect upon publication. For questions regarding personal data processing: hello@zaryaintel.com, +7 (977) 449-22-68.
This document does not constitute legal advice. For questions relating to a specific situation, please consult a qualified legal professional.