Datenschutzerklärung

Version dated August 2, 2026
Effective date: August 2, 2026

General Provisions

1.1. This Personal Data Processing Policy (the "Policy") determines the procedure and conditions for processing the personal data of visitors to https://bulava.digital (the "Website").

1.2. The personal data operator is Ilya Evgenievich Melman, a professional income tax payer (self-employed), Taxpayer Identification Number 552813021711, address: 22 Mayorova Street, Apartment 49, Luzino, Omsk Region, Omsk, Russia, email: hello@bulava.digital (the "Operator").

1.3. This Policy has been prepared in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ dated 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 received by the Operator through the Website, by email, and during communications concerning a user's request.

1.5. This Policy is publicly available on the Website. A user may review it before submitting any personal data.

Key Terms

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

2.2. Personal data processing means any action or set of actions performed on personal data, with or without automated means, including collection, recording, organization, accumulation, storage, updating, retrieval, use, transfer, anonymization, restriction, deletion, and destruction.

2.3. User means an individual who visits the Website or sends a request to the Operator.

2.4. Cookie means a small piece of data stored by a browser on a user's device when the Website is visited.

Processing Principles

3.1. The Operator processes personal data lawfully, fairly, and only for predetermined purposes.

3.2. The content and volume of the personal data processed are proportionate to the stated purposes. The Operator does not request excessive data.

3.3. The Operator takes measures to maintain data accuracy and deletes or corrects incomplete or inaccurate data when necessary.

3.4. Personal data is stored no longer than required by the processing purposes or the laws of the Russian Federation.

Data Categories, Purposes, and Retention

Requests and Enquiries

The Operator may process:

name;
telephone number, email address, messenger username, or another contact provided by the user;
project details and user requirements;
selected or estimated budget;
the Website language and page from which the request was sent;
subsequent correspondence;
submission date and time, IP address, browser and device information to the extent necessary to confirm submission and maintain security.

Purposes of processing:

receiving and handling a request;
contacting the user;
discussing a project, preparing a proposal, and conducting negotiations;
entering into and performing a contract at the user's initiative;
protecting the Website and requests against misuse.

Processing continues until the purpose is achieved or consent is withdrawn, but no longer than 12 months after the last substantive communication if no contract is concluded. If a contract is concluded, relevant data may be stored during the contract term and thereafter for the periods required by tax, accounting, and other applicable laws.

Technical Data and Analytics

The following data may be processed when the Website is used:

IP address;
browser, operating system, device type, and screen resolution information;
cookies and similar identifiers;
referral source, pages viewed, time and duration of the visit;
clicks, scrolling, and other interface interactions;
approximate location derived from the IP address.

Purposes of processing:

maintaining correct and secure Website operation;
identifying technical errors and misuse;
analysing Website traffic and improving the interface;
evaluating the effectiveness of advertising and informational materials.

Optional analytics cookies and web analytics services are used only after the user has given consent. Further information is provided in the Cookie Policy.

Special Categories and Biometric Data

The Operator does not request information about health, race or ethnicity, political opinions, religious or philosophical beliefs, private life, criminal records, or biometric personal data through the Website form. Users should not include such information in free-text fields.

Legal Grounds for Processing

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

the user's consent to personal data processing;
the need to take steps at the user's request before entering into a contract or to perform a contract to which the user is a party;
compliance with obligations imposed by the laws of the Russian Federation;
the Operator's legitimate interest in maintaining the functionality and security of the Website, provided that the user's rights and freedoms are not infringed.

5.2. Consent covering data submitted through the form is obtained separately from other information and documents. Before selecting the checkbox, the user is provided with links to the consent form and this Policy.

5.3. Consent to analytics cookies is requested separately through the cookie preferences interface.

Processing Procedure and Methods

6.1. Processing is performed with and without automated means.

6.2. The Operator may collect, record, organize, accumulate, store, update, retrieve, use, provide to authorized processors, anonymize, restrict, delete, and destroy personal data.

6.3. Access is granted only to the Operator and persons who require the data to perform specific duties and are bound by confidentiality obligations.

6.4. The Operator does not publish or otherwise disseminate a user's personal data without a separate legal basis or separate consent where required by law.

Data Collection

7.1. The user is the primary source of personal data.

7.2. Technical data may be transmitted automatically by the browser and web analytics tools when the Website is visited, subject to the user's cookie preferences.

7.3. The user decides whether to provide data. Without the required data, the Operator cannot receive or respond to a request.

7.4. The user confirms that the information provided is accurate and that the user has a lawful basis for providing information about any other individual included in a request.

Data Localization and Storage

8.1. When collecting personal data of Russian citizens through the Website, the Operator complies with the data localization requirements of the Russian Federation.

8.2. The initial recording, organization, accumulation, storage, updating, and retrieval of request data are performed using a database located in the Russian Federation.

8.3. The Operator takes reasonable legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, restriction, copying, provision, and other unlawful actions.

Service Providers and Data Transfers

9.1. The Operator may engage service providers under a contract or another lawful basis. Only the data required for a specific purpose is provided to them.

9.2. As of the date of this Policy, the following services may be used:

REG.RU for corporate email services;
Yandex LLC for Yandex Metrica, provided that the user has consented to analytics cookies;
Timeweb Cloud for technical Website hosting;
other contractors, whose details will be added to this Policy before personal data is transferred to them.

9.3. After initial recording in a database located in the Russian Federation, a request may be delivered to the Operator through Resend, provided by Plus Five Five, Inc., USA, and Telegram, provided by Telegram Messenger Inc. and related entities whose infrastructure may be located outside the Russian Federation. Such transfers are performed only on a lawful basis, after the Operator has complied with the requirements governing cross-border personal data transfers, and subject to decisions of the competent authority. The user is informed in advance about the countries and recipients in a separate consent form.

9.4. The Operator does not sell users' personal data.

Termination of Processing and Data Destruction

10.1. Processing is terminated when its purpose is achieved, the applicable period expires, the legal basis ceases to apply, a valid withdrawal of consent or request is received, or in other cases provided by law.

10.2. If retention is no longer necessary and no other lawful basis applies, the Operator destroys personal data within the periods established by the laws of the Russian Federation.

10.3. Withdrawal of consent does not affect the lawfulness of processing performed before the withdrawal was received. In cases expressly provided by law, the Operator may continue processing without consent.

User Rights

11.1. A user has the right to:

obtain information about the processing of their personal data;
request correction, restriction, or destruction of incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary data;
withdraw consent to personal data processing;
object to processing in cases provided by law;
lodge a complaint with Roskomnadzor or a court concerning the Operator's actions or inaction;
exercise other rights provided by the laws of the Russian Federation.

11.2. To exercise these rights, a user should email hello@bulava.digital with the subject "Personal Data". The request should include the user's full name, the nature of the request, and contact details for the response. The Operator may request information necessary to verify the applicant's identity and connection with the relevant data.

11.3. The Operator responds to requests in accordance with the procedure and periods established by the laws of the Russian Federation.

Personal Data Protection

12.1. The Operator assesses potential harm to data subjects and implements proportionate safeguards, including access restrictions, secure communication channels, credential management, backups, software updates, and oversight of processors.

12.2. If an incident is discovered, the Operator takes measures to stop the violation, reduce its consequences, and notify the competent authority in the cases and within the periods required by law.

Amendments

13.1. The Operator may update this Policy when the law, the data processed, the processing purposes, or the services used change.

13.2. A new version becomes effective when published on the Website unless otherwise stated. The date and version are specified at the beginning of the document.

Operator Details

Operator: Ilya Evgenievich Melman
Status: professional income tax payer (self-employed)
Taxpayer Identification Number: 552813021711
Address: 22 Mayorova Street, Apartment 49, Luzino, Omsk Region, Omsk, Russia
Email: hello@bulava.digital
Website: https://bulava.digital