Personal Data Processing Policy

Version of 7 September 2026

This is a translation. The policy is drawn up under Russian Federal Law No. 152-FZ and the Russian text is the only binding version. If anything in this translation differs from the Russian original, the Russian version prevails.

1. General provisions

This Personal Data Processing Policy (the “Policy”) is drawn up in accordance with the requirements of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and defines how personal data is processed and what measures the operator takes to keep it secure.

The personal data operator is: Плательщик налога на профессиональный доход (самозанятый), taxpayer number (INN) 613701345604 (the “Operator”), which owns the website netsecretnet.ru (the “Website”, the “Service”).

2. What data is processed

  • the email address provided when subscribing;
  • technical data: IP address, device and browser type, cookies, page-visit data — collected automatically through the Yandex.Metrica counter;
  • order and payment records (plan, amount, transaction date). Bank card details are neither transmitted to nor stored by the Operator — payments are handled by the Platega and YooKassa payment aggregators@else the YooKassa payment aggregator in accordance with the PCI DSS standard.

3. Purposes of processing

  • performance of the public offer agreement — providing access to the “NetSecret” service and generating the connection configuration automatically;
  • processing and confirming payments;
  • sending notifications related to the service (configuration, subscription expiry);
  • improving the Website and analysing user activity;
  • compliance with the legislation of the Russian Federation.

4. Legal grounds for processing

Processing is carried out on the basis of the consent of the personal data subject, expressed by making a payment on the Website (acceptance of the offer) and/or by other implied actions, and also for the purpose of performing an agreement to which the personal data subject is a party.

5. Disclosure to third parties

To deliver the service the Operator engages the following third parties:

  • Platega — processing payments for subscription plans;
  • YooKassa — processing payments for the franchise;
  • Yandex.Metrica (Yandex LLC) — web analytics;
  • the hosting provider that supplies the technical infrastructure of the Service.

Personal data is not disclosed to any other third parties, except in cases expressly provided for by the legislation of the Russian Federation.

6. Retention period

Personal data is stored for the term of the subscription and for 3 (three) years after it ends — for accounting, dispute resolution and statutory compliance — after which it is deleted or anonymised.

7. Rights of the data subject

The personal data subject has the right to obtain information about the processing of their data, to demand that it be corrected, blocked or deleted, and to withdraw consent to processing, by sending a request to conf@netsecretnet.online. Requests are reviewed within the period established by Article 20 of Law 152-FZ.

8. Security measures

The Operator applies organisational and technical measures to protect personal data against unlawful access, destruction, alteration and distribution, including encryption of data transmission channels (HTTPS/TLS) and restricted access to the data.

9. Amendments to the Policy

The Operator may amend this Policy. The current version is always available at https://netsecretnet.ru/privacy.

10. Contacts

For any questions about the processing of personal data, please write to conf@netsecretnet.online.