Privacy Policy and Personal Data Processing Policy

Version dated September 24, 2026

1. General Provisions

1.1. This Privacy Policy and Personal Data Processing Policy (the Policy) sets out the procedures for processing and protecting the personal data of users of https://turbo-suslik.ru/en/ (the Site).

1.2. The personal data operator is:

Individual Entrepreneur Dmitry Evgenyevich Leushkin
Taxpayer Identification Number (INN): 470517568518
Primary State Registration Number of the Individual Entrepreneur (OGRNIP): 308470508600042
(the Operator).

1.3. This Policy has been prepared in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006, “On Personal Data,” and other applicable laws and regulations of the Russian Federation.

1.4. This Policy applies to all personal data processed by the Operator in connection with the operation of the Site, including its public pages, authentication functions, personal sections, and access to materials of the Turbo-Suslik System.

1.5. By using the Site and providing personal data to the Operator, the User confirms that they have read this Policy. If the User does not agree with its provisions, they must stop using any Site functions that require the processing of personal data.

2. Definitions

2.1. Personal Data means any information relating to an identified or identifiable individual, directly or indirectly.

2.2. Processing of Personal Data means any operation or set of operations performed on personal data, including collection, recording, organization, accumulation, storage, correction, retrieval, use, transfer where permitted by law, anonymization, restriction, deletion, and destruction.

2.3. User means an individual who visits the Site or uses its functions and materials.

2.4. Account means a set of data and technical identifiers used to authenticate the User and determine the level of access granted to them.

2.5. Cookies means small pieces of data stored by the User’s browser and required for authentication, user sessions, preferences, and Site security mechanisms.

3. Personal Data We Process

3.1. The Operator may process the following Account data:

  • email address;

  • display name, nickname, or pseudonym;

  • internal User identifier;

  • Account status and access level;

  • technical authentication and session data;

  • information concerning the granting, modification, suspension, or termination of access.

3.2. Account data is provided by the User when creating an account in the Turbo-Suslik System and is used on the Site for authentication, management of access to materials, security, and technical operation of the service.

3.3. When the User visits and uses the Site, the following information may be processed automatically:

  • IP address;

  • date and time of access;

  • address of the requested page;

  • browser, operating system, device type, and interface-language information;

  • referring source, where transmitted by the browser;

  • session identifiers and technical cookies;

  • records of logins, errors, suspicious activity, and other security events.

3.4. If the User contacts the Operator on their own initiative, the Operator may process the User’s contact details, the contents of the communication, and information required to prepare a response.

3.5. The Operator does not intentionally collect biometric data, information concerning health or diagnoses, political opinions, religious beliefs, sex life, or other special categories of personal data. Users should not send such information to the Operator unless necessary.

3.6. The Site does not require a legal name for ordinary Account use. A display name may be the User’s real name, a nickname, or a pseudonym. If identification of a party is required for a separate paid agreement, the relevant data will be requested and documented separately.

4. Purposes of Processing

4.1. Personal data is processed for the following purposes:

  • authenticating the User and maintaining the User’s session;

  • providing access to public and restricted sections of the Site;

  • managing Account status and access level;

  • maintaining the availability and security of the Site;

  • preventing unauthorized access, abuse, and technical attacks;

  • diagnosing errors and resolving technical problems;

  • responding to User communications;

  • performing the User Agreement and any other agreements entered into with the User;

  • complying with obligations imposed by the laws of the Russian Federation;

  • protecting the lawful rights and interests of the Operator and Users.

4.2. The Operator does not sell personal data, provide it to advertising networks, or use it for automated decision-making that produces legal effects for the User.

5. Legal Grounds for Processing

5.1. The Operator processes personal data on the following grounds:

  • the User’s consent to the processing of personal data;

  • the need to perform the User Agreement or another agreement to which the User is a party;

  • the Operator’s obligations under the laws of the Russian Federation;

  • the need to exercise the rights and lawful interests of the Operator or third parties, provided that the User’s rights and freedoms are not thereby violated;

  • other grounds provided by the laws of the Russian Federation.

5.2. Where permitted by law, consent may be expressed through actions that clearly indicate the User’s intent, including checking the relevant box in an electronic form, creating or using an Account, or submitting data to the Operator.

6. Cookies and Technical Logs

6.1. The Site uses technical and session cookies required for authentication, maintenance of the User’s session, protection against unauthorized access, and correct operation of the interface.

6.2. The User may restrict or delete cookies through their browser settings. In that case, authentication, restricted sections, and certain Site functions may operate incorrectly or become unavailable.

6.3. Server and security logs may contain the User’s IP address, the date and time of a request, the requested address, information about the User’s software, the result of the request, and security events.

6.4. If the Site introduces optional analytics, advertising, or other tracking tools that require separate consent, the Operator will update this Policy and arrange for such consent to be obtained where required by law.

7. Processing Procedures and Conditions

7.1. Personal data may be processed by automated or non-automated means through collection, recording, organization, accumulation, storage, correction, retrieval, use, restriction, deletion, and destruction.

7.2. Processing is limited to the data necessary for the stated purposes. The Operator does not permit processing that is incompatible with the purposes for which the data was obtained.

7.3. The Operator may engage service providers that supply hosting, email, technical maintenance, information security, or other Site infrastructure. Such providers receive access only to the data necessary to perform their respective functions and must comply with confidentiality and personal-data protection requirements.

7.4. Personal data may be disclosed to government authorities, courts, and other authorized persons in the cases and manner prescribed by the laws of the Russian Federation.

7.5. The Operator does not disclose personal data to the general public and does not provide it to third parties for their independent marketing purposes.

7.6. When personal data of citizens of the Russian Federation is collected, its recording, organization, accumulation, storage, correction, and retrieval are carried out using databases located within the Russian Federation, except where expressly permitted by law.

7.7. Personal data is not transferred across national borders unless such transfer is required for a service separately enabled by the User or the Operator and the requirements of Russian law have first been satisfied.

8. Retention and Termination of Processing

8.1. Personal data is retained no longer than required by the purposes of processing, the User Agreement, and the laws of the Russian Federation.

8.2. Account data may be retained for the lifetime of the Account and, after access has ended, for the period necessary to comply with legal obligations, resolve disputes, maintain security, and protect the Operator’s lawful interests.

8.3. Technical logs and security-event data are retained for the period necessary to diagnose problems, prevent abuse, and investigate incidents.

8.4. Processing ends when its purposes have been achieved, the applicable retention period has expired, the legal basis has ceased to apply, or a lawful request has been received from the User, unless continued retention is required on another lawful ground.

8.5. Data is removed from backups within the ordinary backup-rotation cycle, provided that further use of such data is restricted.

9. Protection of Personal Data

9.1. The Operator takes the legal, organizational, and technical measures necessary to protect personal data against unlawful or accidental access, destruction, alteration, restriction, copying, distribution, and other unlawful actions.

9.2. Such measures may include access controls, identification and authentication systems, secure connections, backups, event logging, software updates, and security monitoring.

9.3. Access to personal data is granted only to persons who require it to perform duties connected with the operation of the Site.

9.4. Despite the measures taken, no method of transmitting or storing information can guarantee absolute security. The User must also keep their Account credentials confidential and must not provide them to third parties.

10. User Rights

10.1. The User has the right to:

  • obtain information about the processing of their personal data;

  • request the correction, restriction, or deletion of data that is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purposes;

  • withdraw consent to the processing of personal data;

  • request termination of processing where provided by law;

  • challenge the Operator’s actions or omissions before Roskomnadzor, the Russian data protection authority, or a court;

  • exercise other rights provided by the laws of the Russian Federation.

10.2. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal was received and does not require the deletion of data that the Operator must or may continue to process on another lawful ground.

10.3. To protect personal data against unauthorized access, the Operator may request information sufficient to verify the identity of the applicant and their connection with the relevant Account.

11. User Requests

11.1. Requests concerning the processing of personal data must be sent to the Operator using the contact details published in the Contact section of the Site.

11.2. A request should contain information sufficient to identify the User and the relevant Account, the substance of the request, and an address for the response. Users should not send passport copies or other excessive documents unless the Operator separately requests them for lawful identity verification.

11.3. The Operator reviews and responds to requests in the manner and within the time limits established by the laws of the Russian Federation.

12. Minors

12.1. The Site and the Turbo-Suslik System are intended only for persons aged 18 or older.

12.2. If the Operator becomes aware that an Account is being used by a minor, access may be terminated and the related personal data deleted unless continued retention is required by law.

13. Changes to This Policy

13.1. The Operator may amend this Policy in response to changes in law, data-processing practices, or Site functions.

13.2. A new version takes effect when published on the Site unless it specifies a different effective date.

13.3. The date of the current version appears at the beginning of this document. Users are advised to review the Policy periodically for changes.

14. Final Provisions

14.1. This Policy and the relationship between the User and the Operator are governed by the laws of the Russian Federation.

14.2. If any provision of this Policy is found invalid, the remaining provisions remain in effect.

14.3. The current version of this Policy is publicly available on the Site.