Legal
Personal Data Processing Policy
This is an English translation provided for convenience. In case of any discrepancy, the Russian version prevails.
01 General provisions
This Personal Data Processing Policy (the “Policy”) sets out how personal data of visitors to the portfolio website at https://irina-grigoreva.dev/ (the “Site”) is processed and protected.
The personal data operator (the “Operator”) is:
- Operator
- Sole proprietor Irina Vladimirovna Grigoreva
- Taxpayer ID (INN)
- 463408260553
- Registration No. (OGRNIP)
- 324460000032026
- Email for personal data matters
- hello@irina-grigoreva.dev
The Policy applies to visitors of the Site and to anyone who contacts the Operator using the contacts published on the Site.
The Policy is an informational document and is not in itself consent to the processing of personal data. Where a specific type of processing requires consent, it is requested separately.
The Operator follows Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” and other applicable requirements of the legislation of the Russian Federation.
02 What data may be processed
During a regular visit, technical information may be processed automatically: IP address, date and time of the visit, browser and operating system details, device type, language, referral source, pages viewed, technical identifiers, cookies and similar technologies.
If a visitor contacts the Operator by email, via Telegram or another channel listed on the Site, the Operator may process their name or nickname, email address, Telegram username and any other details the visitor chooses to include in the message.
The Site is not intended to collect special categories of personal data, biometric data, health information, political or religious views, criminal records or other sensitive information. Please do not send such details through the Site contacts unless necessary.
The Site has no user registration, personal accounts or direct payment acceptance. If the Site functionality changes, the Policy will be updated.
When the “Tell me about your project” inquiry form is sent, the following is processed: contact details (an email address or a Telegram username), the description of the task and any details the visitor includes in it, the selected project type and approximate budget, the date and time of sending, and a record of consent to personal data processing with the revision of its text. The sender’s IP address is not stored with the inquiry: to protect the form from abuse it is used only as an irreversible hash in request-rate counters, which are deleted within two days.
03 Purposes of processing
The Operator processes data to:
- keep the Site running and secure;
- respond to inquiries from potential clients and partners;
- prepare proposals and discuss possible cooperation;
- analyse traffic and improve the Site structure;
- with the visitor’s separate permission, measure advertising performance and run retargeting.
Personal data is not used for purposes incompatible with those for which it was collected.
04 Legal grounds for processing
When a visitor reaches out about cooperation, data is processed to take steps at the visitor’s request before entering into a contract and, where needed, to conclude and perform the contract.
Data sent through the inquiry form on the Site is processed on the basis of the visitor’s consent. The consent is a separate document and is given by ticking a box in the form before sending it; the box is not ticked by default. Consent text: https://irina-grigoreva.dev/en/consent
Technical processing required for the secure operation of the Site may be carried out to the extent necessary to keep the information system running and protected.
Analytics and advertising technologies, where applicable law requires consent, are used only after the visitor makes the corresponding choice in the cookie settings.
Withdrawing consent does not stop processing that has another legal basis.
05 Yandex Metrica
Yandex Metrica, provided by YANDEX LLC, may be used to analyse Site traffic. The counter may receive technical information about the visit, device, browser, referral source, pages viewed and visitor actions, and may use cookies and browser identifiers. Under the current Yandex Metrica terms, the site owner acts as the operator of visitors’ personal data and Yandex processes it on the operator’s behalf.
The Yandex Metrica code is loaded only after analytics cookies are allowed, where such prior consent is required. Declining analytics does not restrict access to the main content of the Site.
The Operator does not intend to send names, emails, phone numbers, addresses, message contents or other directly identifying data to Yandex Metrica. Yandex itself also advises against including such details in URLs, events, UTM tags and Metrica parameters.
If Session Replay (Webvisor) is enabled, fields that may contain personal or confidential information must be excluded from recording. Yandex notes that automatic detection of such fields does not guarantee full protection without proper configuration.
06 VK Pixel
If the Operator connects the VK Ads pixel, it may be used to measure advertising performance, build advertising audiences and run retargeting. VK Ads uses cookies, pixels, JavaScript tags and other technologies and may receive technical identifiers and information about how the user interacts with the site.
VK Pixel is loaded only after the user consents to advertising technologies.
The Operator does not pass message contents, emails, phone numbers or other directly identifying data through VK Pixel events unless there is a separate legal basis and the required notice.
While VK Pixel is not connected to the Site, this section does not apply in practice.
07 Google Analytics
The Operator may consider using Google Analytics only after verifying compliance with Russian requirements on data localisation and cross-border transfer of personal data. The Russian Ministry of Digital Development has stated that using Google Analytics, whose functionality involves processing personal data, constitutes a cross-border transfer under Federal Law No. 152-FZ. In addition, since 1 July 2025 stricter requirements apply to the initial collection and storage of Russian citizens’ personal data in databases located in Russia.
Until the applicable organisational and legal requirements are met, Google Analytics may not be used on the Site.
If Google Analytics is connected later, the Policy and cookie consent settings will be updated before such processing begins.
09 Sharing and third parties
To run the Site, the Operator may engage:
- hosting providers: for the Site pages and for the server in the Russian Federation that receives and stores inquiries from the form;
- Telegram — only for technical notifications to the Operator about a new inquiry; the sender’s personal data is not included in them;
- the Yandex Metrica analytics service;
- VK Ads, if the advertising pixel is connected;
- technical specialists, who are given access only to the extent needed for their task.
Each service processes information under its own terms and applicable law. The Operator does not sell visitors’ personal data to third parties.
When a visitor follows links to external sites and services, including Telegram, GitHub and other links in the portfolio, data processing there is governed by the documents of their respective owners.
10 Localisation and cross-border transfer
When collecting personal data of Russian citizens through the Site, the Operator observes Part 5 of Article 18 of Federal Law No. 152-FZ: recording, systematisation, accumulation, storage, clarification and retrieval of such data must not be carried out using databases located outside Russia, except as permitted by law.
Any subsequent cross-border transfer is carried out in line with Article 12 of Federal Law No. 152-FZ and the applicable notification procedures.
Inquiries from the form on the Site are sent from the visitor’s browser over a secure connection directly to a server located in the Russian Federation and recorded in a database on that server. The service that hosts the Site pages does not receive the form contents.
11 Retention periods
Data from cooperation inquiries is kept as long as needed to reply, negotiate, perform a possible contract or protect the Operator’s legitimate interests.
Inquiries sent through the form are destroyed within 30 days of the purpose of processing being achieved or consent being withdrawn, unless the law or an agreement with the sender provides otherwise. An inquiry can also be deleted on request to hello@irina-grigoreva.dev.
Technical and analytics data is kept for the periods set in the relevant services and the lifetime of the identifiers used, after which it is deleted or anonymised.
When consent is withdrawn, further processing based on that consent stops unless there is another legal basis.
12 Data protection
The Operator takes reasonable organisational and technical measures to prevent unauthorised access, alteration, disclosure, blocking, copying, destruction or other unlawful processing of personal data.
Measures include:
- access control;
- a secure HTTPS connection;
- management of access rights and secrets;
- keeping software components up to date;
- other measures appropriate to the nature of the information processed.
13 Visitor rights
A visitor has the right to:
- receive information about the processing of their personal data;
- request its correction, blocking or deletion where legally justified;
- withdraw previously given consent;
- change their choice regarding analytics and advertising cookies;
- appeal the Operator’s actions to Roskomnadzor or a court.
To exercise these rights, send a request to hello@irina-grigoreva.dev.
The Operator may request information needed to verify the applicant’s identity and prevent disclosure to an unauthorised person.
14 Automated decisions
The Site makes no decisions that produce legal effects for a visitor or otherwise significantly affect their rights based solely on automated processing of personal data.
Interactive 2D/3D demos, animations and configurators in the portfolio showcase development capabilities and are not used to profile visitors.
15 Minors
The Site presents professional services and is not specifically aimed at children.
If the Operator learns that a minor’s personal data was obtained without a legal basis, such data will be deleted unless there is another obligation to keep it.
16 Changes to the Policy
The Operator may amend the Policy when legislation, connected services, processing methods or Site functionality change.
The current version is published on this page with its effective date. If new processing requires separate user consent, it does not begin until such consent is obtained.
17 Contacts
For questions about the processing and protection of personal data:
- Operator
- Sole proprietor Irina Vladimirovna Grigoreva