Personal Data Processing Policy

Individual Entrepreneur Elena Ivanovna Kabasser

INN 340303213756

OGRNIP 326508100599062

Website: elenakabasser.com

Effective date: 29 October 2026

1. General provisions

1.1. This Personal Data Processing Policy (the “Policy”) describes how Individual Entrepreneur Elena Ivanovna Kabasser (the “Operator”) collects, uses, stores, protects, transfers, deletes and otherwise processes personal data in connection with the website elenakabasser.com, including its English-language pages, and in connection with enquiries, booking, payment and provision of information and consulting services.
1.2. The Policy is prepared with regard to Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”, Federal Law No. 149-FZ dated 27 July 2006 “On Information, Information Technologies and Information Protection”, and other applicable laws of the Russian Federation.
1.3. The Operator respects the rights to privacy, personal and family secrecy and seeks to process only personal data that are reasonably necessary for the relevant purpose.

1. 1.4. This English-language Policy is intended for users of the English-language version of the Website and international clients. Mandatory rights granted to a data subject by applicable law are not limited by this Policy.

2. Operator and Contact Details

Status / Статус: Individual Entrepreneur / Индивидуальный предприниматель
Full Name / ФИО: Elena Ivanovna Kabasser / Кабассер Елена Ивановна
INN / ИНН: 340303213756
OGRNIP / ОГРНИП: 326508100599062
Website / Сайт: https://elenakabasser.com/
Email / Электронная почта: elena@kabasser.ru
Contact Phone / Телефон: +79955013183


3. Categories of Data Subjects and Personal Data

3.1. The Operator may process personal data relating to Website visitors, prospective clients, current and former clients, payers, participants in individual or couple consultations, and persons who contact the Operator in connection with the Services.
3.2. Depending on the interaction, the Operator may process:
·  name and, where provided, surname;
·  telephone number;
·  email address;
·  messenger username and contact details;
·  information contained in an enquiry or message voluntarily submitted by the user;
·  information necessary to schedule and organize consultations, including agreed date, time and format;
·  information relating to an order, package of consultations, payment status, amount, currency, refund or correction; the Operator does not intentionally collect or store full bank-card details;
·  technical data generated when using the Website, such as IP address, cookies, device/browser information, referral source and Website interaction data, where such processing is enabled and lawful;
·  other information voluntarily provided by the data subject and reasonably necessary for the relevant purpose.
3.3. If one participant in a couple provides personal data relating to another person, the person providing such data must have a lawful basis to do so and should not provide more information than is reasonably necessary.


4. Special Categories of Personal Data

4.1. The Website enquiry form is not intended for the collection of medical diagnoses, medical records or other special categories of personal data. Users are requested not to include unnecessary information about health, intimate life, political views, religious or philosophical beliefs or other specially protected information in an initial Website enquiry.
4.2. In the course of psychological consulting, a client may voluntarily disclose information concerning emotional wellbeing, relationships, health or other sensitive matters. Where such information constitutes a special category of personal data under applicable law, it is processed only where an appropriate legal basis exists and only to the extent reasonably necessary for provision of the Service or compliance with law.
4.3. Professional notes, if maintained outside the Website, are not collected through the Website form and are subject to the Operator’s confidentiality and information-security procedures.


5. Purposes of ProcessingThe Operator processes personal data for the following separate purposes:

·  receiving and responding to enquiries;
·  booking and organizing individual and couple consultations;
·  taking steps at the request of a prospective client before entering into an agreement;
·  concluding and performing agreements for information and consulting services;
·  communicating with clients in connection with scheduled consultations and ongoing Services;
·  accepting payments, processing refunds, issuing fiscal receipts and maintaining tax and accounting records;
·  complying with legal, tax, accounting, consumer-protection and other mandatory requirements;
·  ensuring security, stable operation and technical administration of the Website;
·  obtaining aggregated Website statistics and improving the Website, subject to applicable consent requirements;
·  sending promotional, informational or marketing communications only where a separate lawful basis or separate consent exists.


6. Legal Grounds for ProcessingDepending on the purpose, the Operator processes personal data on one or more of the following grounds:

·  the data subject’s consent to the processing of personal data;
·  the need to take steps at the data subject’s request before entering into an agreement;
·  the conclusion and performance of an agreement to which the data subject is a party;
·  the need to comply with obligations imposed on the Operator by Russian law;
·  other grounds expressly permitted by applicable law.
Consent to receive advertising or promotional communications, where required, is obtained separately from consent to process personal data for the provision of Services.


7. Methods and Operations with Personal Data

The Operator may perform the following operations with personal data, with or without automation: collection, recording, systematization, accumulation, storage, clarification (updating and modification), retrieval, use, provision and access where lawful, depersonalization, blocking, deletion and destruction.


8. Website Forms, Service Providers and Recipients

8.1. The Website is created and operated using the Tilda website platform. Website forms may be processed through Tilda’s technical infrastructure. The Operator configures the Website and its integrations with the aim of complying with the data-localization requirements applicable to personal data of Russian citizens.
8.2. The Operator may use Yandex services, including Yandex Metrica for Website analytics and Yandex email services for business communications. Analytics services may process technical and behavioral data in accordance with their terms and the Website’s cookie settings. The content of consultation enquiries should not be intentionally transmitted to analytics services.
8.3. Depending on the payment method selected by the client, payment and fiscal-processing services may include T-Bank, Prodamus and Robokassa. Such providers may process payment-related data in accordance with their own terms and applicable law. The Operator does not receive or store full payment-card details.
8.4. For accounting, tax reporting, legal compliance, technical support or communication, the Operator may provide the minimum necessary personal data to service providers acting under contract or other lawful basis, including accounting providers, payment providers, fiscal-data operators, IT/hosting providers and communication services.
8.5. Personal data may also be disclosed to state authorities, courts or other persons where such disclosure is required by law or a legally binding request.


9. Cookies and Analytics

9.1. The Website may use cookies and similar technologies necessary for technical operation, security, saving user preferences and obtaining Website statistics.
9.2. Yandex Metrica may collect information about visits, devices, browsers, IP addresses, cookies and Website interactions. The Operator seeks to configure analytics so that directly identifying information submitted through consultation forms is not intentionally transmitted to the analytics service.
9.3. Where applicable law requires consent for non-essential analytics or similar technologies, such technologies are used on the basis of the user’s consent and/or settings selected through the Website’s cookie interface.
9.4. Users may restrict or delete cookies through browser settings. Disabling certain cookies may affect Website functionality.


10. Data Localization and Storage

10.1. When collecting personal data of citizens of the Russian Federation through the Internet, the Operator ensures that the initial recording, systematization, accumulation, storage, clarification and retrieval of such personal data are carried out using databases located in the Russian Federation, to the extent required by applicable Russian law.
10.2. Personal data are stored only for as long as necessary for the stated purposes or for the period required by applicable law.
10.3. As a general rule:
·  enquiries that do not result in the provision of Services may be deleted or anonymized after they are no longer reasonably required for communication, subject to technical backup cycles and legal requirements;
·  data relating to contracts, payments, fiscal receipts, refunds, accounting and tax records are retained for the statutory retention periods applicable to the relevant records;
·  marketing-contact data are processed until consent is withdrawn or another applicable termination event occurs;
·  technical and analytics data are retained according to the relevant service settings and applicable legal requirements.


11. Cross-Border Transfers

11.1. The Operator does not intentionally transfer personal data collected through Website forms outside the Russian Federation unless such transfer is necessary, lawful and carried out in compliance with applicable Russian requirements governing cross-border transfers.
11.2. Where a specific third-party service, payment route or communication method may involve processing outside the Russian Federation, the Operator will take the steps required by applicable law before carrying out a cross-border transfer for which the Operator is responsible.
11.3. International card payments may involve the client’s bank, payment networks and payment providers. Such entities may process payment data independently under their own legal obligations and privacy terms.


12. Confidentiality and Security

12.1. The Operator takes legal, organizational and technical measures reasonably necessary to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful processing.
12.2. Access to personal data is limited to the Operator and persons who require such access for a lawful business purpose and are subject to appropriate confidentiality or contractual obligations.
12.3. The Operator seeks to apply the principle of data minimization and not to collect personal data that are excessive in relation to the stated purpose.


13. Rights of Data SubjectsSubject to applicable law, a data subject may:

·  request information about the processing of their personal data;
·  request clarification, updating or correction of inaccurate or incomplete data;
·  request blocking or deletion of data where the legal grounds for processing no longer exist;
·  withdraw consent where processing is based on consent;
·  object to or stop receiving promotional communications;
·  exercise other rights provided by applicable law, including the right to complain to a competent supervisory authority or seek judicial protection.
Requests relating to personal data may be sent to: elena.kabasser@gmail.com. The Operator may request information reasonably necessary to verify the identity of the person making the request.
If mandatory data-protection law of the data subject’s country applies to a particular processing activity, the data subject may also have additional rights under that law. Nothing in this Policy is intended to waive mandatory rights that cannot lawfully be waived.


14. Withdrawal of Consent and Deletion

14.1. A data subject may withdraw consent by sending a request to elena.kabasser@gmail.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
14.2. After withdrawal, the Operator will cease processing based on that consent and delete or anonymize the relevant data unless another lawful basis or statutory retention obligation permits or requires continued processing.


15. Changes to This Policy

15.1. The Operator may update this Policy when legislation, Website functionality, business processes, service providers or data-processing practices change.
15.2. The current version is published on the Website. The version effective on the date of the relevant processing applies, subject to mandatory law.


16. Applicable Law and Language

16.1. This Policy and the Operator’s processing of personal data are governed primarily by the laws of the Russian Federation, subject to mandatory provisions of other applicable laws that may apply to a particular data subject or processing activity.
16.2. This Policy is issued in English for the English-language version of the Website and may be used as an independent operative privacy document for international users.