1. General provisions
1.1. This policy sets out how personal data of visitors of erikmarkovsky.com (the “Website”) and of people who contact the controller through the Website is processed in accordance with Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
1.2. The controller is Erik Iosifovich Markovsky, self-employed (professional income tax payer, Russia), taxpayer ID (INN) 100128971344 (the “Controller”). The Controller is personally responsible for organising the processing of personal data. Contact: hello@erikmarkovsky.com, +7 905 023 58 63.
2. Whose data and what data
- People who send a request through the form: name; phone and/or email; the subject and text of the request; anything entered in the additional form fields (instrument, child’s age, event date and venue, demo link, deadlines, etc.); the page the request was sent from, the first page opened on the Website, the site the visitor came from, campaign tags (UTM); the date and time of the request.
- People who write to or call the Controller directly (email, phone, messengers): the data they provide.
- Students and clients: name, contacts, schedule and the details needed for lessons or performances.
- Visitors who allowed analytics cookies: cookies, IP address, browser and device information, actions on the Website (pages viewed, clicks, scrolling) — via Yandex Metrica.
The Controller does not process special categories of personal data (health, beliefs, etc.) or biometric data. Information about a child (for example, their age) is received only from their parent or another legal guardian.
3. Purposes and legal grounds
- Replying to requests and questions — the data subject’s consent (Clause 1, Part 1, Article 6 of Law No. 152-FZ). The consent text is on the Consent to personal data processing page.
- Concluding and performing a services contract (lessons, performances, recording) — Clause 5, Part 1, Article 6 of Law No. 152-FZ.
- Analysing traffic and improving the Website — the visitor’s consent to analytics cookies, given in the banner on the Website.
4. How and how long data is processed
4.1. Processing is mixed: with and without automation. Operations: collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer (provision, access) to the parties in section 5, blocking, deletion, destruction.
4.2. Retention: request data — until the purpose is achieved, but no longer than 3 years after the last contact; student and client data — for the duration of the services and 3 years after (the limitation period); Yandex Metrica data — for the period set by the service’s rules.
4.3. Once the purposes are achieved, consent is withdrawn or processing is unlawful, the Controller destroys the data within 30 days unless there is another legal ground to process it.
5. Who else processes the data
The Controller does not sell or disclose personal data to third parties. The following process data on the Controller’s instructions:
- Yandex.Cloud LLC (INN 7704458262) — website hosting, receiving and storing requests, sending request notifications (Yandex Cloud);
- Yandex LLC (INN 7736207543) — the Controller’s email (Yandex 360) and web analytics (Yandex Metrica).
Databases with personal data of Russian citizens are located in Russia (Part 5, Article 18 of Law No. 152-FZ). Data is disclosed to public authorities only where the law requires it.
6. Cross-border transfer and external services
6.1. The Controller does not transfer personal data across borders.
6.2. YouTube videos on the Website load only after the visitor clicks them. At that moment the visitor’s browser connects to the servers of Google LLC (USA), and Google receives technical data (including the IP address) under its own rules. If you do not want this, do not play YouTube videos on the Website.
6.3. Links to Telegram, WhatsApp, VK, YouTube, TikTok, Instagram and other external services lead to third-party sites; data there is processed under those services’ rules.
7. Cookies and Yandex Metrica
7.1. Necessary — used without consent, because without them the Website cannot do what the visitor asks:
em_consent(localStorage) — your choice in the cookie banner, kept for 12 months;em_visit(sessionStorage) — the first page you opened, the site you came from and UTM tags; kept until the tab is closed and sent to the Controller only together with a request.
7.2. Analytics — only with your consent: Yandex Metrica (Yandex LLC), including click maps and Webvisor (session recording). Metrica uses its own cookies (for example, _ym_uid, _ym_d, _ym_isad) and receives the IP address, browser and device information and actions on the Website. Webvisor does not record the text you type into the form fields.
7.3. Until you click “Accept”, Metrica is not loaded. You can change your choice at any time with the “Cookie settings” link at the bottom of every page. You can also delete or block cookies in your browser settings.
8. How data is protected
The Website uses HTTPS. Requests are stored in private Yandex Cloud storage in Russia; only the Controller has access to them and to the mailbox that receives them. The request server checks consent and does not store a request without it.
9. Data subject rights
You may: obtain information about the processing of your data; ask for it to be corrected, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not needed for the stated purpose; withdraw your consent; complain about the Controller to Roskomnadzor or a court. Send requests to hello@erikmarkovsky.com. The Controller replies within 10 working days; this may be extended by up to 5 working days with reasons given.
10. Changes to this policy
The Controller may update this policy. The current version is always available on this page; the version date is shown at the top.