Privacy policy and personal data processing

1. General provisions

This Policy describes how personal data of users of the website nugu.pro (the “Site”) is processed and protected by the personal data operator.

The Policy is prepared in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and Information Protection”, and other applicable laws of the Russian Federation. The operator is established and acts in Russia; 152-FZ continues to apply even when this English version is shown to foreign visitors.

By using the Site, submitting forms, or sending messages, you confirm that you have read this Policy. If you disagree with its terms, please do not submit personal data through the Site.

2. Personal data operator

• Operator: Nafis Nugumanov (brand NUGU / NUGU Digital Agency)
• Address: Sochi, Konstitutsii SSSR St., 44v, office 1
• Email: info@nugumanova.ru
• Phones: +7 918 209-40-42, +7 900 260-26-05

For questions about personal data processing, opting out of messages, withdrawing consent, or exercising other data-subject rights, write to the email above.

3. What data we process

Depending on how you interact with us, the Operator may process:

• name / preferred form of address;
• phone number;
• email address;
• messenger username (Telegram and others);
• content of your enquiry / brief / request;
• technical data: IP address, device and browser type, visit date and time, referral sources, and actions on the Site;
• cookie and similar technology data (see section 8).

We do not request special categories of personal data and do not process biometric data through the Site.

4. Purposes of processing

• handling requests and responding to your enquiry;
• preparing commercial proposals and entering into contracts;
• providing digital-agency services and project support;
• improving the Site, UX, and service quality;
• traffic statistics and analytics (where you have consented to the relevant cookies);
• complying with Russian Federation law.

5. Legal bases

• consent of the data subject (Art. 6(1)(1) of 152-FZ) — when submitting forms and accepting cookies;
• performance of a contract or steps at the subject’s request before entering into a contract (Art. 6(1)(5) of 152-FZ);
• the Operator’s legitimate interests, subject to the rights of the data subject (keeping the Site running, security, basic enquiry logging).

6. How we process data

Processing may be automated or manual and may include collection, recording, systematisation, accumulation, storage, updating, use, transfer (disclosure, access), anonymisation, blocking, deletion, and destruction.

Personal data is not sold and is not shared with third parties for their marketing. Transfer is possible:

• to contractors and services needed to run the Site and communications (hosting, email, messengers), limited to what the purpose requires;
• upon a lawful request from public authorities.

Cross-border transfer of personal data is not a processing purpose. If some technical services are hosted outside Russia, the Operator takes measures required by 152-FZ.

7. Retention periods

Enquiry data is stored until the processing purposes are achieved or until consent is withdrawn / a deletion request is made — unless a longer period is required by law (for example, accounting or contract records). Technical logs and cookie data are kept for as long as needed for analytics and security, or until the cookie expires / consent is withdrawn.

8. Cookies and similar technologies

Cookies are small files stored on your device. The Site may use:

• Necessary — basic Site operation, remembering your cookie choice, session security;
• Analytics — help us understand how the Site is used (for example, Yandex Metrica) and improve content and interface;
• Marketing — may be used to measure advertising effectiveness if such tools are connected.

On the first visit a cookie notice is shown. You may accept all cookies or stick to necessary ones. Your choice is stored in the browser’s local storage. To change it, clear the site data in browser settings and reload the page.

Most browsers let you disable cookies in settings. Disabling necessary cookies may limit some Site features.

9. Rights of the data subject

You have the right to:

• obtain information about processing of your personal data;
• request rectification, blocking, or destruction of data;
• withdraw consent to processing;
• appeal the Operator’s actions to Roskomnadzor or in court;
• request termination of processing in cases provided by law.

To exercise these rights, send a request to info@nugumanova.ru. Include your name (or preferred address), a contact method, and the substance of the request. The Operator responds within the time limits set by 152-FZ.

10. Security measures

The Operator takes organisational and technical measures to protect personal data against unlawful access, destruction, alteration, blocking, copying, disclosure, and distribution: access control, HTTPS where configured on the domain, contractor oversight, current passwords, and reasonable backups.

11. Consent when submitting forms

By submitting a request through a Site form or opening a messenger with a pre-filled enquiry text, you consent to processing of the data you provide for feedback and preparing a commercial proposal under this Policy.

12. Changes to this Policy

The Operator may update this Policy. The current version is always available on this page. The revision date is shown at the top. Material changes may also be announced on the Site.