This document “Privacy Policy” (hereinafter – the “Policy”) represents the rules for the use of data of Internet users (hereinafter “you” and/or the “User”) by /insert website owner/ (hereinafter – “we” and/or the “Administration”) collected through the website /insert website URL/ (hereinafter – the “Website”).
Processed data
1.1. We do not collect your personal data through the Website.
1.2. All data collected on the Website is provided and received in anonymized form (hereinafter – “Anonymized Data”).
1.3. Anonymized Data includes the following information that does not allow your identification:
1.3.1. Information you provide voluntarily via online forms and software modules of the Website, including name, phone number and/or email address.
1.3.2. Data transmitted automatically in anonymized form depending on the settings of the software you use.
1.4. The Administration has the right to set requirements for the content of Anonymized Data collected through the Website.
1.5. If certain information is not marked as mandatory, its provision or disclosure is at the User’s discretion. At the same time, you give informed consent to make such data available to an unlimited number of persons. This data becomes publicly available from the moment of its submission and/or disclosure in any form.
1.6. The Administration does not verify the accuracy of the information provided and the availability of the User’s necessary consent for its processing according to this Policy, assuming that the User acts in good faith, carefully, and makes every effort to keep such information up to date and to obtain all required consents for its use.
1.7. You acknowledge and accept the possibility that third-party software may be used on the Website, as a result of which such parties may receive and transmit the data specified in clause 1.3 in anonymized form.
Example: such third-party software may include visitor analytics systems like Google Analytics and Yandex.Metrica.
1.8. The content and conditions for collecting anonymized data using third-party software are determined directly by their rights holders and may include:
browser data (type, version, cookies);
device and location data;
operating system data (type, version, screen resolution);
request data (time, referral source, IP address).
1.9. The Administration is not responsible for how third parties use the User’s Anonymized Data.
Purposes of data processing
2.1. The Administration uses the data for the following purposes:
2.1.1. Processing incoming requests and communicating with the User;
2.1.2. Providing information services, including sending promotional and informational materials;
2.1.3. Conducting marketing, statistical, and other research;
2.1.4. Targeting advertising materials on the Website.
Data protection requirements
3.1. The Administration stores data and protects it from unauthorized access and distribution in accordance with internal rules and regulations.
3.2. The data remains confidential except when made publicly available by the User or when the technologies and third-party software used on the Website or the User’s software settings provide for open data exchange with such parties and/or other Internet users.
3.3. To improve service quality, the Administration may store log files of actions performed by the User while using the Website for 1 (one) year.
Data transfer
4.1. The Administration may transfer data to third parties in the following cases:
The User has given consent for such actions, including through software settings that do not restrict the provision of certain information;
The transfer is necessary for the User to use the Website’s functionality;
The transfer is required in accordance with the purposes of data processing;
In connection with the transfer of the Website to the ownership, use, or possession of such third party;
Upon request of a court or other authorized government body in accordance with legal procedures;
To protect the rights and legitimate interests of the Administration in connection with violations committed by the User.
Changes to the Privacy Policy
5.1. This Policy may be changed or terminated by the Administration unilaterally without prior notice to the User. The new version of the Policy becomes effective upon its publication on the Website unless otherwise provided by the new version.
5.2. The current version of the Policy is available on the Website at the following address.
Effective version of the Policy as of __________ 20__.
The Policy was developed by the IT-Lex Law Firm
Note: This sample Privacy Policy is not suitable for websites that include registration and/or contact forms requiring personal data beyond a phone number and/or email address. Therefore, we do not recommend using this sample for online stores, classifieds, marketplaces, or any other websites that process users’ personal data.
If personal data is being processed, the Privacy Policy must be supplemented with mandatory provisions regarding the types, legal grounds, methods, and purposes of processing such data and obtaining the subject’s consent under the Policy terms.