Privacy policy

English translation for reference. Russian original.

Current as of 14 September 2026

A person's (User's, Personal Data Subject's) provision of personal data when using https://tribracelet.ru, messenger chats or another platform where services and access to intellectual property (IP) are provided, or other websites, chats and digital platforms, including when purchasing information and consulting services from Individual Entrepreneur Nikolay Nikolayevich Panasyuk (registration no. 319344300119954, tax ID 344113879070), hereinafter the Operator, constitutes the User's unconditional agreement to this Privacy Policy and its conditions for processing personal data. If the User disagrees, they must refrain from using https://tribracelet.ru, messenger chats or other platforms providing services or access to IP, and other websites, chats and digital platforms, and must not enter into or continue any relationship with the Operator.

1. GENERAL PROVISIONS

1.1. This Policy for the commercial project of Individual Entrepreneur Nikolay Nikolayevich Panasyuk, registration no. 319344300119954, tax ID 344113879070 (the Policy), has been developed in accordance with the Constitution and Civil Code of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 ‘On Personal Data’ (the Personal Data Law), Federal Law No. 149-FZ of 27 July 2006 ‘On Information, Information Technologies and Information Protection’, and regulations adopted under them.

This Privacy Policy (the Policy) is available at https://tribracelet.ru/privacy/ and forms an integral part of the Offer published at https://tribracelet.ru/offer/ and other civil-law agreements, in any form, between the Operator and individuals or legal entities obtaining the Operator's services or products.

1.2. Under this Policy, the User's (Personal Data Subject's) personal information (personal data) means:

1.2.1. Personal information provided by the User, including through mobile devices, when purchasing the Operator's goods and services on https://tribracelet.ru or other websites and digital platforms used to sell or promote the Operator's services and products, including their domains, subdomains, pages and content, and online services and software offered by the Operator on those websites or platforms (the Website); when registering an account (Personal Account); or when using messenger chats and their functions, including messages, calls and file exchange, or other platforms on which services are provided (the Chats), including the User's personal data.

1.2.2. Personal data automatically transmitted to Chat and Website services during use by software installed on the User's device, including IP address, cookie data, browser information (or other software used to access online services), hardware and software specifications, access dates and times, requested page addresses and similar information.

1.3. This Policy applies to all personal data received and processed by the Operator when providing services and products or otherwise interacting with Users.

1.4. This Policy applies to personal-data processing relationships arising before and after its approval, provided the User previously reviewed and accepted those provisions in earlier versions of the Policy.

2. PURPOSES OF PROCESSING PERSONAL INFORMATION

2.1. This Policy defines procedures for collecting, recording, organizing, accumulating, storing, clarifying (updating or changing), retrieving, using, transmitting (distributing, providing or granting access to), anonymizing, blocking, deleting and destroying personal data processed by the Operator in commercial or non-commercial activities.

2.2. The Operator processes Users' personal information for the following purposes:

2.2.1. Identifying Users when entering into and performing agreements, including granting access to personalized or restricted Chat or Website resources, communicating with Users, sending notifications and requests, and processing applications.

2.2.2. Creating an account (Personal Account or similar) or another corresponding section within the Chats or Websites.

2.2.3. Promoting the Operator's services, including advertising or other communications sent to the User.

2.2.4. Protecting Users' rights and freedoms when processing their personal data, including privacy and personal and family confidentiality.

2.2.5. Detecting, preventing, mitigating and investigating fraudulent or unlawful actions against the Operator.

2.2.6. Complying with legal requirements, including tax and currency legislation.

2.2.7. Maintaining accounting, financial, tax and other reporting.

2.3. The Operator processes personal data solely for the purposes defined in clause 2.2 of this Policy.

3. PERSONAL DATA CATEGORIES

3.1. The Operator processes data of Users who purchase its goods or services (or for whose benefit they are purchased), use Chat or Website services, otherwise interact with the Operator to obtain services or goods, and have consented to personal-data processing, including email, SMS and social-network communications.

3.2. The main personal data processed by the Operator includes:

surname, first name and patronymic;

email address;

phone number;

bank card details and bank account number.

3.3. The Operator may additionally process the following personal data if supplied by the User:

- passport details;

- tax identification number;

age (date, month and year of birth);

registered or residential address;

evaluative information about professional and other personal qualities;

ID, login or nickname on social networks or messengers;

- other personal data the Personal Data Subject chooses to provide.

3.4. With separate User consent, the Operator processes:

- a color digital photograph of the face;

- a color digital video image of the face;

- a voice recording.

These data are not biometric because the Operator does not use them to identify the User.

3.5. The Websites use cookies and visitor data from traffic-statistics services: IP address, cookie and browser information, Website access time, the address of a page containing an advertising block, referrer (previous-page address), browser user-agent data to identify spam, and other data. These data provide information about visitor actions to improve Website content and functionality and create quality content and services for visitors.

The Personal Data Subject may change browser settings at any time to block all cookies or receive notifications when they are sent. Some functions and services used by the Operator may then fail to operate properly.

3.6. The Operator does not intentionally process minors' personal data. Their legal representatives are responsible for minors' actions, including purchases on the Websites. If the Operator learns it has received a minor's personal information without the consent of their legal representatives, it will delete it as soon as possible.

4. CONDITIONS FOR RECEIVING, PROCESSING AND TRANSFERRING PERSONAL INFORMATION TO THIRD PARTIES

4.1. Chats and Websites store Users' personal information in accordance with this Policy and any internal rules of the digital services used by the Operator, under agreements between the Operator and those services.

4.2. Users' personal information remains confidential, except where a User voluntarily makes information publicly available to an unrestricted audience or personal data is provided on grounds established by law.

4.3. The Operator processes personal data upon obtaining the User's consent.

4.4. Consent under clause 4.3 also signifies consent to transfer data to third parties, entrust its processing to third parties and transfer it across borders through the Internet where needed to provide the Operator's services effectively or achieve other Policy purposes; receive email, SMS and social-network communications under a paid-services agreement or advertising and marketing materials for the Project; and distribute personal data under this Policy's procedure. Cross-border transfer includes transfer to third parties in countries with and without an adequate level of data protection. In all cases, the Operator ensures the required protection by complying with this Policy.

4.5. The User provides consent when completing forms on the Operator's Websites to apply for a services agreement (accept the Offer), paying under such an agreement or otherwise submitting personal data to the Operator. Consent is provided by ticking ‘I consent to the processing of my personal data’, or pressing a button that initiates payment or data submission (‘buy a ticket’, ‘submit an application’, ‘ask a question’, ‘reserve a place’, ‘I'm in’, ‘I want this too’, ‘participate’, etc.), or another notification of similar meaning, provided the full Policy is available at each data-collection point, including through an active link. This procedure also applies to paper services agreements, including digital copies, except where signing requires independently reviewing the Policy on the Websites.

4.6. The Personal Data Subject provides written consent, on paper or electronically, for distribution of the data listed in clause 3.4, in accordance with Article 10.1 of the Personal Data Law.

4.7. Upon receiving withdrawal of consent, the Operator stops processing the User's personal data within 10 working days, unless the law specifies otherwise. Send withdrawal to hello@tribracelet.ru with the subject ‘Withdrawal of consent to personal data processing’.

Where consent is withdrawn:

- the Operator cannot guarantee proper delivery of services not yet provided at the time the withdrawal is received;

- deleted personal data may remain in third-party systems, including caches, search engines and interconnected proxy servers.

4.8. Chats, Websites and other digital services used by the Operator to provide goods or services may transfer the User's personal information to third parties, unless prohibited by law or relevant service rules, in these cases:

4.8.1. The User consents under clause 4.5.

4.8.2. Transfer is needed for the User to use a specific service (Website, Chat, etc.) or to accept and perform the Offer, including access to video materials and information and consulting services. To facilitate use or receipt of goods or services, personal data may be obtained automatically through specialized software, including from third parties such as social networks.

4.8.3. Transfer is required by Russian or other applicable law under a prescribed procedure, including to regulators, law-enforcement bodies, central or local authorities, official or public bodies or courts to which the Operator must provide information on request, or to persons protecting the Operator's or third parties' rights where those rights are violated or threatened, including violations of laws or governing documents. The Operator must warn recipients that the data may be used only for the stated purposes and require its confidentiality.

4.8.4. If the Chats or Websites are sold, assigned or otherwise transferred, the acquirer assumes all obligations under this Policy regarding the personal information received.

4.9. The Operator transfers Users' personal data to third parties (contractors, employees and staff) solely to perform obligations under agreements governing their cooperation.

4.10. Personal data is processed for the time necessary to achieve the purposes for which it was collected, except for the period covered by consent or other legally or properly established periods, by any lawful means, including automated personal-data information systems, the Internet, or non-automated processing.

4.11. If personal data is lost or disclosed, the Operator informs the User and takes comprehensive measures to minimize resulting harm.

4.12. The Operator takes necessary organizational and technical measures to protect personal information from unlawful or accidental access, destruction, alteration, blocking, copying, distribution and other unlawful third-party actions.

4.13. The Operator and User take all necessary measures to prevent losses or other adverse consequences caused by loss or disclosure of personal data.

5. PERSONAL DATA STORAGE

5.1. Personal data is stored electronically in the relevant personal-data information systems as required by applicable Russian law.

5.2. Personal data is retained in an identifiable form for periods that ensure compliance with and achievement of the processing purposes established by this Policy.

5.3. Access to stored personal data is restricted, including through defined access levels.

5.4. Personal data held in different electronic databases and processed for different purposes is stored separately.

5.5. Processing and storage end upon receipt of the Personal Data Subject's request to stop processing or withdrawal of consent, or three years after the contractual relationship between the Operator and the Personal Data Subject ends.

6. TERMINATION OF PROCESSING AND DESTRUCTION OF PERSONAL DATA

6.1. If inaccurate data is identified following a User's request, the Operator must block that User's data from the time of the request while checking it, provided blocking does not infringe the Subject's or third parties' rights and legitimate interests.

6.2. If inaccuracy is confirmed, the Operator must correct the data using the User's information within seven working days of receiving it and remove the block.

6.3. If unlawful processing by the Operator is identified, the Operator must stop it within three working days.

If processing cannot be made lawful, the Operator must destroy the data within ten working days of identifying the unlawful processing and notify the User of the remedy or destruction.

6.4. Upon withdrawal of consent, the Operator must stop processing and, if retention is no longer necessary for the processing purposes, destroy the data within thirty working days of receiving the withdrawal.

6.5. Following withdrawal, the Operator may retain the data in archive form for three years from withdrawal, ensuring its security and anonymization.

7. PERSONAL DATA PROTECTION

7.1. The Operator takes necessary legal, organizational and technical measures against unlawful or accidental access, destruction, alteration, blocking, copying, provision or distribution of personal data, and other unlawful actions.

7.2. Data security is achieved, in particular, through:

- assessing the effectiveness of security measures before using them;

- detecting unauthorized access and taking corrective and preventive measures;

- restoring data altered or destroyed through unauthorized access;

- establishing access rules for data in information systems and recording all actions performed with that data;

- checking the Project's agreements and adding confidentiality clauses where necessary;

- monitoring security measures and the protection level of personal-data information systems.

7.3. Third parties accessing data on the Operator's behalf must take necessary organizational and technical confidentiality measures on the personal devices used to process it.

7.4. Personal data may be disclosed only under applicable Russian law at the request of courts or law-enforcement bodies, or in other cases provided by law.

8. RIGHTS AND OBLIGATIONS OF THE PARTIES

8.1. The User must:

8.1.1. Review this Policy before submitting personal data to the Operator.

8.1.2. Provide accurate personal information needed to use the Chats or Websites. The Operator does not verify its accuracy or Users' legal capacity, and assumes that the Subject supplies accurate, sufficient information in registration, subscription or payment forms and keeps it current. The User bears the risk of providing inaccurate data.

8.1.3. Update and supplement personal data when it changes.

8.2. The Operator must:

8.2.1. Use received information solely for the purposes stated in this Policy.

8.2.2. Process only data covered by this Policy or other data for which additional or separate consent has been obtained.

8.2.3. Keep confidential information secret, not disclose it without prior written User permission, and not sell, exchange, publish or otherwise disclose the User's data except as provided by this Policy.

8.2.4. Take legally required organizational, technical and legal measures to protect data from unauthorized, unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions.

8.2.5. Block the relevant User's data from the time of a request by the User, their legal representative or the authorized data-protection authority while checking identified inaccuracies or unlawful actions.

8.3. The User has the right to:

8.3.1. Full information about and unrestricted free access to their personal data, except where applicable law provides otherwise.

8.3.2. Information concerning the processing of their personal data.

8.3.3. Require correction, blocking or destruction where data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose, and take legally provided measures to protect their rights.

8.3.4. Withdraw consent to personal-data processing.

8.3.5. Other rights under Russian law.

8.4. The Subject may request changes to their data or withdraw consent by sending an application to hello@tribracelet.ru.

8.5. The Operator must provide free access to the User's data and make necessary changes when the User supplies evidence that it is incomplete, outdated, inaccurate or unlawfully obtained. The Operator must notify the Subject or representative of changes and measures taken and take reasonable steps to notify third parties that received the data.

8.6. Requests for correction, blocking or destruction are fulfilled within seven working days of receipt.

8.7. Other applications and requests concerning personal data are reviewed within thirty calendar days of receipt, unless this Policy specifies otherwise. Correspondence is handled by the Operator's support service through the email address supplied in the User's request.

9. LIABILITY

9.1. An Operator failing to perform its obligations is liable under Russian law for User losses caused by unlawful use of personal data.

9.2. The Operator is not liable for loss or disclosure of confidential information if it:

9.2.1. Became public before the loss or disclosure.

9.2.2. Was obtained from a third party before the Operator received it.

9.2.3. Was disclosed with the User's consent.

9.3. Third parties that access Users' data and breach its confidentiality are liable under Russian law and the agreements granting that access.

9.4. The Operator is not liable for misuse of data or harm to the User arising from:

Software, hardware or network failures outside the Operator's control.

Intentional or unintentional use of Chats or Websites by the User or third parties for purposes other than their intended use.

The User's failure to keep access passwords confidential, or intentional disclosure to unauthorized persons of passwords or other information granting Chat or Website access when receiving services or otherwise interacting with the Operator.

Unlawful third-party access to Chat or Website data, including the User's personal data, where the Operator has taken comprehensive protective measures.

9.5. The Operator is not liable for processing third-party personal data supplied by the User as their own. The User providing inaccurate data bears the risk of liability.

9.6. The Operator does not control and is not responsible for processing by third-party websites and services reached through Chat or Website links.

9.7. A User who has not reviewed the Policy but submits data under clause 4.5 is solely responsible for that action and may not claim that the Operator failed to obtain consent.

10. DISPUTE RESOLUTION

10.1. Before bringing a court claim arising from the relationship between User and Operator, a written proposal for voluntary settlement must be submitted.

10.2. The recipient must notify the claimant in writing of the review outcome within thirty calendar days of receiving the claim.

10.3. If no agreement is reached, the dispute is referred to a court at the Operator's place of registration under applicable Russian law.

10.4. Applicable Russian law governs this Privacy Policy and the relationship between User and Operator.

11. ADDITIONAL TERMS

11.1. The Operator may amend this Policy without User consent.

11.2. This Policy takes effect when published on the Websites.

11.3. Send proposed changes or comments to hello@tribracelet.ru.

11.4. If a court or authorized body invalidates individual provisions, the Policy remains valid as a whole.

11.5. The Operator does not specifically check for special personal-data processing regimes under the laws governing individual recipients or persons providing data through Website subscription forms. If a Subject resides in a jurisdiction with a special regime, such as the European Economic Area (EEA), and accesses the Website from Europe, the Operator takes all reasonable measures to meet that jurisdiction's data-protection requirements. The Subject must inform the Operator of the special regime by contacting hello@tribracelet.ru.

12. OPERATOR DETAILS:

Individual Entrepreneur Nikolay Nikolayevich Panasyuk. Address: apartment 49, 9 Parkovaya Street, Saburovo settlement, Krasnogorsk, Moscow Region, Russia. Phone: +7 499-490-75-94. Email: hello@tribracelet.ru.