Personal data processing policy

Edition of 23 July 2026

1. General provisions

This personal data processing policy has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 «On personal data» (the «Personal Data Law») and sets out how personal data are processed and the measures taken to keep them secure by Индивидуальный предприниматель Крицкая Мария Михайловна (the «Operator»).

1.1. The Operator regards respect for human and civil rights and freedoms when processing personal data — including the right to privacy and to personal and family confidentiality — as its most important goal and as a condition of carrying on its activity.

1.2. This policy on personal data processing (the «Policy») applies to all information the Operator may obtain about visitors to the website https://sports-talk.online.

2. Key terms used in the Policy

2.1. Automated processing of personal data — processing personal data by means of computing equipment.

2.2. Blocking of personal data — the temporary suspension of processing (except where processing is needed to correct the personal data).

2.3. Website — the body of graphic and informational materials, computer programs and databases that make them available on the Internet at the network address https://sports-talk.online.

2.4. Personal data information system — the body of personal data contained in databases together with the information technology and technical means that process them.

2.5. Anonymisation of personal data — actions after which it is impossible, without additional information, to attribute the personal data to a particular User or other data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data with or without automation, including collection, recording, systematisation, accumulation, storage, correction (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, erasure and destruction of personal data.

2.7. Operator — a state body, a municipal body, or a legal or natural person that, alone or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of the processing, the categories of personal data to be processed and the actions (operations) performed on them.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://sports-talk.online.

2.9. Personal data authorised by the data subject for distribution — personal data to which the data subject has given access to an unlimited group of persons by giving consent to the processing of personal data authorised for distribution in the manner set out in the Personal Data Law (the «personal data authorised for distribution»).

2.10. User — any visitor to the website https://sports-talk.online.

2.11. Provision of personal data — actions aimed at disclosing personal data to a particular person or a particular group of persons.

2.12. Distribution of personal data — any action aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data known to an unlimited group of persons, including publishing personal data in the mass media, posting them in information and telecommunications networks, or providing access to them in any other way.

2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign public authority, or to a foreign natural or legal person.

2.14. Destruction of personal data — any action after which the personal data are irreversibly destroyed, so that the content of the personal data in the personal data information system cannot be recovered, and/or the material carriers of the personal data are destroyed.

3. Principal rights and obligations of the Operator

3.1. The Operator has the right to:

• receive accurate information and/or documents containing personal data from the data subject;
• continue processing personal data without the data subject's consent, where the grounds set out in the Personal Data Law exist, if the data subject withdraws consent to the processing of personal data or sends a request that the processing be stopped;
• determine independently the composition and the list of measures needed and sufficient to discharge the obligations imposed by the Personal Data Law and the regulations adopted under it, unless the Personal Data Law or other federal laws provide otherwise.

3.2. The Operator shall:

• provide the data subject, at their request, with information concerning the processing of their personal data;
• organise the processing of personal data in the manner established by the applicable law of the Russian Federation;
• respond to enquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law;
• provide the authorised body for the protection of data subjects' rights, at that body's request, with the necessary information within 10 days of receiving the request;
• publish this personal data processing Policy or otherwise provide unrestricted access to it;
• take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision and distribution, and against other unlawful acts in relation to personal data;
• stop transferring (distributing, providing, giving access to) personal data, stop processing them and destroy them in the manner and in the cases set out in the Personal Data Law;
• discharge the other obligations set out in the Personal Data Law.

4. Principal rights and obligations of data subjects

4.1. Data subjects have the right to:

• receive information concerning the processing of their personal data, except in the cases provided for by federal laws. The Operator provides this information to the data subject in an accessible form, and it must not contain personal data relating to other data subjects, unless there are lawful grounds for disclosing them. The list of information and the way to obtain it are set out in the Personal Data Law;
• require the operator to correct, block or destroy their personal data where those data are incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take the measures provided by law to protect their rights;
• make prior consent a condition of processing personal data for the purposes of promoting goods, works and services;
• withdraw consent to the processing of personal data and send a request that processing be stopped;
• appeal against unlawful acts or omissions of the Operator in processing their personal data to the authorised body for the protection of data subjects' rights or in court;
• exercise the other rights provided by the law of the Russian Federation.

4.2. Data subjects shall:

• provide the Operator with accurate information about themselves;
• inform the Operator when their personal data are corrected (updated, changed).

4.3. Persons who have provided the Operator with inaccurate information about themselves, or with information about another data subject without that person's consent, bear liability under the law of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. Processing is limited to achieving specific, predetermined and lawful purposes. Processing that is incompatible with the purposes for which the personal data were collected is not permitted.

5.3. It is not permitted to combine databases containing personal data that are processed for purposes incompatible with each other.

5.4. Only personal data that match the purposes of processing are processed.

5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Personal data processed must not be excessive in relation to the stated purposes.

5.6. When personal data are processed, their accuracy and sufficiency are ensured and, where necessary, their relevance to the purposes of processing. The Operator takes, or ensures that others take, the necessary measures to erase or correct incomplete or inaccurate data.

5.7. Personal data are stored in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless the retention period is established by federal law or by an agreement to which the data subject is a party, beneficiary or guarantor. Personal data processed are destroyed or anonymised once the purposes of processing have been achieved, or where achieving them is no longer necessary, unless federal law provides otherwise.

6. Purposes of personal data processing

6.1. To develop and analyse its services, the Operator may anonymise well-being and self-assessment indicators and other data generated through use of the platform, and use them for statistical, analytical and research purposes, including calculating and publishing the aggregate athlete well-being index «PULSE». Results are published only in aggregate form and must not contain names, contact details, diary texts, the content of consultations or other information making it possible to identify a particular User.

7. Conditions for processing personal data

7.1. Personal data are processed with the data subject's consent to the processing of their personal data.

7.2. Processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the operator by the law of the Russian Federation.

7.3. Processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official that is enforceable under the law of the Russian Federation on enforcement proceedings.

7.4. Processing is necessary to perform an agreement to which the data subject is a party, beneficiary or guarantor, and to conclude an agreement on the data subject's initiative or an agreement under which the data subject will be a beneficiary or guarantor.

7.5. Processing is necessary to exercise the rights and legitimate interests of the operator or of third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not infringed.

7.6. Personal data are processed to which the data subject has given access to an unlimited group of persons, or has asked for such access to be given (the «publicly available personal data»).

7.7. Personal data are processed that are subject to publication or mandatory disclosure under federal law.

8. How personal data are collected, stored, transferred and otherwise processed

The security of the personal data processed by the Operator is ensured by implementing the legal, organisational and technical measures needed to comply in full with the applicable legislation on the protection of personal data.

8.1. The Operator keeps personal data safe and takes every possible measure to prevent unauthorised persons from accessing them.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except where this follows from applicable law or where the data subject has given the Operator consent to transfer the data to a third party in order to perform obligations under a civil-law agreement.

8.3. If inaccuracies are found in the personal data, the User may correct them themselves by sending the Operator a notice to the Operator's email address info@sports-talk.ru with the subject line «Personal data update».

8.4. The processing period is determined by the achievement of the purposes for which the personal data were collected, unless another period is set by an agreement or by applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice to the Operator's email address info@sports-talk.ru with the subject line «Withdrawal of consent to the processing of personal data».

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those persons (Operators) in accordance with their own terms of use and privacy policies. The data subject and/or User must read those documents themselves and in good time. The Operator is not liable for the acts of third parties, including the service providers referred to in this clause.

8.6. Prohibitions set by the data subject on the transfer (other than granting access) of personal data authorised for distribution, and on their processing or the conditions of processing (other than obtaining access), do not apply where personal data are processed in state, public and other public interests defined by the law of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing them.

8.8. The Operator stores personal data in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless the retention period is established by federal law or by an agreement to which the data subject is a party, beneficiary or guarantor.

8.9. Processing may be stopped because the purposes of processing have been achieved, because the data subject's consent has expired, because the data subject has withdrawn consent or requested that processing stop, or because unlawful processing has been identified.

9. Actions the Operator performs on the personal data it receives

9.1. The Operator collects, records, systematises, accumulates, stores, corrects (updates, modifies), retrieves, uses, transfers (distributes, provides, gives access to), anonymises, blocks, erases and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained over information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before beginning any cross-border transfer of personal data, the Operator shall notify the authorised body for the protection of data subjects' rights of its intention to carry out such a transfer (this notice is sent separately from the notice of intention to process personal data).

10.2. Before submitting that notice, the Operator shall obtain the relevant information from the foreign public authorities, foreign natural persons and foreign legal persons to whom the cross-border transfer is planned.

10.3. When the services of Google LLC (USA), Telegram FZ-LLC (United Arab Emirates), Zoom Communications, Inc. (USA), Agora Lab, Inc. (USA) and Apple Inc. (USA) are used, personal data are transferred to the territory of foreign states. The transfer is made for tag management on the site and the collection of anonymised statistics, for playing back video, for holding video consultations and webinars, for delivering notifications and for signing in with the account chosen by the User.

10.4. Questions about cross-border transfers are sent to info@sports-talk.ru.

11. Confidentiality of personal data

The Operator and other persons who obtain access to personal data shall not disclose them to third parties or distribute them without the data subject's consent, unless federal law provides otherwise.

12. Rights of the data subject

12.1. The data subject is entitled to obtain information about the processing of their data, to demand that it be corrected, blocked or destroyed, to withdraw consent, and to appeal against the operator's actions to Roskomnadzor or to a court.

12.2. Such a request is sent to info@sports-talk.ru. The Operator considers it within the period set by the Personal Data Law.

12.3. Withdrawal of consent to personal data processing and withdrawal of consent to the use of cookies are sent to the same address.

13. Who personal data are transferred to

13.1. The Operator entrusts the processing of personal data to the persons listed below. A processing instruction providing for confidentiality has been concluded with each of them:

• Yandex LLC (Russia) — anonymised visit statistics (Yandex Metrica), maps on specialists' pages, sign-in with Yandex ID, storage of uploaded files;
• Prodamus LLC (Russia) — collection of payments for services;
• Unisender LLC (Russia) — delivery of email;
• Konsol LLC (Russia) — settlements with specialists;
• SKB Kontur JSC (Russia) — video calls during consultations;
• Google LLC (USA) — the Google Tag Manager tag manager, sign-in with a Google account, playback of YouTube video embedded in the site;
• Telegram FZ-LLC (UAE) — notifications and the diary in the Telegram bot;
• Zoom Communications, Inc. (USA) — webinars;
• Agora Lab, Inc. (USA) — video calls during consultations;
• Apple Inc. (USA) — sign-in with Apple ID.

13.2. Each of them receives only what the service cannot work without: the payment service — the name, contacts and contents of the order; the email service — the email address and the text of the message; the visit counter — anonymised information about the visit. The contents of diaries, consultation records and correspondence with a specialist are not passed to third parties.

13.3. Some of these services are enabled at the Operator's discretion and may be switched off. The current list of recipients is published in this section.

14. Use of cookies

14.1. The Site uses cookies — small files the browser stores at the site's request — as well as entries in the browser's local storage.

14.2. They serve three purposes: the technical operation of the site (sign-in, keeping the session, the settings chosen), remembering the User's preferences, and collecting anonymised visit statistics.

14.3. Technical cookies are set by Индивидуальный предприниматель Крицкая Мария Михайловна: the visit identifier and an anonymous device identifier, the partner-link tag and advertising campaign parameters, and the service cookies of the sign-in. Analytics cookies are set by the third-party services listed in the section «Who personal data are transferred to» — Yandex Metrica and Google Tag Manager.

14.4. Cookies that are not required for the site to work are set only after the User's consent, given in the notice shown on the first visit. That decision can be refused or changed at any time through the «Cookie settings» link at the bottom of the site, as well as in the browser settings; on refusal, analytics cookies and browser-storage entries set earlier are deleted. Withdrawal of consent to the use of cookies is sent to info@sports-talk.ru.

14.5. Recording of the User's actions and input (session replay, form recording) is not carried out.

15. Final provisions

15.1. The User may obtain any clarification on questions concerning the processing of their personal data by contacting the Operator by email at info@sports-talk.ru.

15.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

15.3. The current version of the Policy is freely available on the Internet at https://sports-talk.online/privacy.

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