Revision date: 17 July 2026
This Policy is issued under Russian Federal Law No. 152-FZ “On Personal Data”. The Russian-language version is the legally binding one; this English translation is provided for information only. In case of any discrepancy, the Russian version prevails.
1.1. This document (the “Policy”) defines the policy of the self-employed person (payer of the professional income tax) Margarita Evgenievna Polyakova (INN 771821200326) (the “Operator”) regarding the processing of personal data of users of the website on the Internet at: https://clctd.pro (the “Site”).
1.2. This Policy is developed pursuant to clause 2 of part 1 of Art. 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (“152-FZ”) and the related official recommendations.
1.3. In compliance with part 2 of Art. 18.1 of 152-FZ, the Policy is published for free access on the Internet at: https://clctd.pro/privacy-policy.
1.4. This Policy applies only to the Site. The Operator does not control and is not responsible for third-party websites the User may access via links on the Site.
1.5. Terms defined in Art. 3 of 152-FZ are used in this Policy with the same meaning.
1.6. The following terms are also used:
User — any person visiting the Site and using its information, materials and services; a personal data subject within the meaning of 152-FZ.
Site Services — interactive software components of the Site: registration and authentication, the Personal account, uploading and cataloguing of digital images of art objects, creation of albums, export of the collection to PDF, and subscription checkout and payment (the “Services”).
1.7.1. The Operator shall: process personal data solely for the purposes stated in the Policy; not distribute personal data without the User’s consent unless otherwise provided by law; observe the principles and rules of 152-FZ; organise the protection of personal data; consider the User’s requests and provide reasoned responses; grant the User free access to their personal data; and take measures to update, block and destroy personal data in the cases established by 152-FZ.
1.7.2. The Operator may: independently determine the protection measures; entrust processing to another party with the User’s consent under a contract; continue processing without consent where grounds under 152-FZ exist; obtain accurate information from the User and require its timely update.
1.8.1. The User shall: provide accurate personal data necessary for the purposes of processing; and update the provided data where necessary.
1.8.2. The User may: receive full information about the processing of their personal data; have their data updated, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary for the purpose of processing; withdraw consent; and protect their rights, including by appealing the Operator’s actions to the authorised body or in court.
2.1. Processing is limited to the achievement of specific, predefined and lawful purposes. Processing incompatible with the purposes of collection is not permitted; the data processed must not be excessive.
2.2. The Operator processes the User’s personal data for the following purposes:
4.1. The Operator processes the personal data of visitors and registered users of the Site.
4.2. The processed personal data include:
4.3. The Operator ensures that the content and scope of the processed data correspond to the stated purposes of processing.
4.4. The Operator does not process biometric personal data or special categories of personal data.
4.5. Digital images and information about collection items uploaded by the User constitute user content. The User is responsible for holding the rights to such content and for the lawfulness of its placement, in accordance with the Public Offer.
5.1. Processing is carried out by non-automated, automated and mixed means in accordance with the requirements of Russian law.
5.2. Actions performed with personal data: collection, recording, systematisation, accumulation, storage, updating (revision, modification), retrieval, use, transfer (provision to the YooKassa payment service to the extent necessary to process payments), blocking, deletion, destruction.
5.3. Processing is carried out subject to the User’s consent, except where the law permits processing without consent.
5.4. The User decides to provide their personal data and gives consent freely, of their own will and in their own interest.
5.5. The processing period is determined by the achievement of the purposes of processing, unless another period is provided by contract or law.
5.6. Consent may be withdrawn by sending a message to support@clctd.pro or by deleting the account in the Personal account.
5.7. The Operator does not distribute personal data (disclosure to an indefinite range of persons).
5.8. The Operator takes the necessary legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision or distribution.
5.9. Data is stored in a form allowing identification of the User for no longer than the purposes of processing require. Data is stored within the Yandex Cloud infrastructure (Russian Federation) — on a virtual machine and in S3-compatible object storage; backups are encrypted. Personal data is stored for the term of the account and for up to 12 months after its deletion or the last payment, unless another period is established by law or contract.
5.10. In processing, the Operator observes the requirements of Art. 18 of 152-FZ.
5.11. The Operator undertakes to maintain the confidentiality of personal data.
5.12. The Operator does not carry out cross-border transfer of personal data.
5.13. In the event of unlawful or accidental transfer of personal data, the Operator provides notice thereof within 24 (twenty-four) hours of detection.
5.14. The Operator, together with the User, takes measures to prevent adverse consequences of such transfer.
6.1. Upon detecting unlawful processing or inaccuracy of personal data following a request by the User (their representative) or the authorised body, the Operator blocks the relevant data for the period of verification.
6.2. Upon confirming inaccuracy, the Operator updates the data within seven business days of receiving the relevant information.
6.3. Upon detecting unlawful processing, the Operator ceases it within no more than three business days and, if lawfulness cannot be ensured, destroys the data within no more than ten business days of detection.
6.4. Upon achieving the purpose of processing, the Operator destroys the data within no more than thirty days, unless otherwise provided by contract or law.
6.5. Upon withdrawal of consent, the Operator destroys the data within no more than thirty days, if its retention is no longer required and unless otherwise provided by law.
6.6. Processed data is subject to destruction upon loss of the need to achieve the purposes of processing.
6.7. The Operator responds to the User’s requests regarding processing, sent to support@clctd.pro, within 10 business days of receiving the request.
7.1. The Operator is liable for breach of the requirements of 152-FZ in accordance with the laws of the Russian Federation.
7.2. The User may seek compensation for losses and/or moral harm through the courts.
8.1. Disputes and disagreements between the User and the Operator are resolved in accordance with the current legislation of the Russian Federation.
9.1. The Operator may amend the Policy without the User’s consent.
9.2. A new version of the Policy takes effect upon its publication on the Site and applies to relations arising after it takes effect.
9.3. Any suggestions or questions about the Policy should be sent to support@clctd.pro.
Self-employed (professional income tax payer)
Name: Margarita Evgenievna Polyakova
INN: 771821200326
E-mail: support@clctd.pro
Website: https://clctd.pro
Moscow