PRIVACY AND PERSONAL DATA PROCESSING POLICY1. GENERAL PROVISIONS
1.1. This Privacy and Personal Data Processing Policy (the “Policy”) has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and establishes the procedure for processing personal data and the measures taken to protect such data by TACHYON Limited Liability Company.
1.2. Personal Data Operator:
Full legal name: TACHYON Limited Liability Company
Short legal name: TACHYON LLC
Taxpayer Identification Number (INN): 9722012523
Tax Registration Reason Code (KPP): 772201001
Primary State Registration Number (OGRN): 1217700602943
Registered address: Office 243, Floor 6, Building 9, 41 Talalikhina Street, Moscow, 109316, Russian Federation
Email address for personal data inquiries: support@ishiki.pro
Email address for partnership and business inquiries:
Info@ishiki.proWebsite: https://ishiki.pro/
1.3. The Operator’s principal objective in processing personal data is to respect and protect the rights and freedoms of individuals, including the rights to privacy and personal and family confidentiality.
1.4. This Policy applies to all information that the Operator may obtain about visitors to https://ishiki.pro/, including its English-language pages.
1.5. The English-language version of the website is an informational corporate website and does not provide online purchasing, payment, delivery, user registration or personal account functionality.
1.6. This English translation is provided for informational purposes. If there is any discrepancy between this English version and the Russian-language version, the Russian-language version shall prevail.
2. KEY TERMS
2.1. Automated processing of personal data means processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is required to clarify such data.
2.3. Website means the collection of graphic and informational materials, software and databases made available online at https://ishiki.pro/.
2.4. Personal data information system means a set of personal data contained in databases together with the information technologies and technical means used to process such data.
2.5. Depersonalisation means actions that make it impossible to determine, without additional information, whether personal data relates to a specific User or other personal data subject.
2.6. Processing of personal data means any action or set of actions performed on personal data, whether by automated means or otherwise, including collection, recording, organisation, accumulation, storage, clarification, updating, alteration, retrieval, use, transfer, provision, access, depersonalisation, blocking, deletion and destruction.
2.7. Operator means a legal entity that independently or jointly with other persons organises and/or carries out the processing of personal data and determines the purposes of processing, the categories of personal data to be processed and the actions performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the Website.
2.9. User means any visitor to the Website.
2.10. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.11. Distribution of personal data means actions aimed at disclosing personal data to an indefinite group of persons.
2.12. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, a foreign public authority, a foreign individual or a foreign legal entity.
2.13. Destruction of personal data means actions resulting in the irreversible destruction of personal data so that its content cannot subsequently be restored.
3. RIGHTS AND OBLIGATIONS OF THE OPERATOR
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the data subject;
— continue processing personal data after consent has been withdrawn or a request to cease processing has been received where permitted by the laws of the Russian Federation;
— independently determine the measures necessary and sufficient to fulfil its obligations under applicable personal data legislation, unless otherwise provided by law.
3.2. The Operator shall:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organise personal data processing in accordance with the laws of the Russian Federation;
— respond to requests from personal data subjects and their legal representatives;
— provide the competent authority with the required information within the period prescribed by law;
— provide unrestricted access to this Policy;
— take appropriate legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution or other unlawful actions;
— cease processing and destroy personal data in the cases and manner prescribed by law;
— fulfil all other obligations imposed by applicable law.
4. RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided by federal law;
— request clarification, blocking or destruction of personal data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose;
— withdraw consent to personal data processing and request that processing cease;
— object to the processing of personal data for marketing purposes;
— challenge unlawful actions or omissions of the Operator before the competent authority or a court;
— exercise other rights provided by the laws of the Russian Federation.
4.2. Personal data subjects shall provide accurate information and notify the Operator when their personal data needs to be updated or corrected.
4.3. Persons who provide inaccurate information about themselves or personal data relating to another person without proper authority may be held liable under the laws of the Russian Federation.
5. PRINCIPLES OF PERSONAL DATA PROCESSING
5.1. Personal data shall be processed lawfully and fairly.
5.2. Processing shall be limited to specific, predetermined and legitimate purposes. Personal data shall not be processed in a manner incompatible with the purposes for which it was collected.
5.3. Databases containing personal data processed for incompatible purposes shall not be combined.
5.4. Only personal data relevant to the stated processing purposes shall be processed.
5.5. The content and volume of processed personal data shall be proportionate to the stated purposes. Excessive processing is not permitted.
5.6. The Operator shall take reasonable measures to ensure that personal data is accurate, sufficient and, where necessary, up to date.
5.7. Personal data shall be stored in a form that allows the data subject to be identified for no longer than required by the purposes of processing, unless a longer period is required by law. Personal data shall be deleted, destroyed or depersonalised when the processing purposes have been achieved or the need to achieve them no longer exists, unless otherwise required by law.
6. PURPOSES OF PERSONAL DATA PROCESSING
6.1. PROCESSING PARTNERSHIP AND BUSINESS INQUIRIES
Categories of personal data subjects: representatives of existing or potential partners, contractors, distributors and other persons contacting the Operator.
Personal data processed: name, surname, email address, telephone number where voluntarily provided, company, position, the content of the inquiry, attached documents and other information voluntarily included in the correspondence.
Purpose of processing: receiving, reviewing and responding to partnership and business inquiries; discussing potential cooperation; maintaining business correspondence; preparing, concluding and performing agreements at the initiative of the personal data subject or the organisation represented by that person.
Legal grounds: the data subject’s voluntary action in contacting the Operator; the taking of steps at the data subject’s request before entering into an agreement; performance of an agreement; the Operator’s legitimate interests, provided that the rights and freedoms of the data subject are not violated; and consent where required by law.
Processing operations: collection, recording, organisation, accumulation, storage, clarification, retrieval, use, provision to persons involved in processing the inquiry, blocking, deletion and destruction.
Retention period: for the time required to review and respond to the inquiry and thereafter for up to three years from the end of the correspondence, unless a longer period is required by law or is necessary for the conclusion or performance of an agreement or the resolution of a dispute.
6.2. OPERATION AND SECURITY OF THE WEBSITE
Categories of personal data subjects: Website visitors.
Personal data processed: IP address, browser, operating system and device information, date and time of access, pages viewed, referral source, technical logs, session identifiers and necessary cookies.
Purpose of processing: ensuring the proper and secure operation of the Website, maintaining user-selected settings, preventing technical failures and detecting or preventing unlawful activity.
Legal grounds: the Operator’s legitimate interests in operating and protecting the Website, provided that the rights and freedoms of Users are respected.
Retention period: for the lifetime of the relevant necessary cookie or technical log and no longer than is reasonably required for the stated purposes.
6.3. WEB ANALYTICS
Categories of personal data subjects: Website visitors who have consented to analytics cookies.
Personal data processed: IP address, cookie identifiers, browser, operating system and device information, referral source, pages viewed and actions performed on the Website.
Purpose of processing: measuring Website traffic, evaluating the performance of pages and interfaces, understanding how the Website is used and improving the Website and user experience.
Legal ground: the User’s consent to analytics cookies.
Data recipient and processor: YANDEX LLC, in connection with the use of the Yandex Metrica service.
Retention period: for the lifetime of the relevant analytics cookies, but no longer than 24 months, or until consent is withdrawn, whichever occurs first.
7. CONDITIONS FOR PROCESSING PERSONAL DATA
7.1. The Operator processes personal data where at least one lawful ground applies, including:
— the personal data subject has provided consent;
— processing is required to comply with an obligation imposed on the Operator by the laws of the Russian Federation;
— processing is required to enter into or perform an agreement to which the personal data subject is a party, beneficiary or guarantor, or to take steps at the personal data subject’s request before entering into an agreement;
— processing is required to exercise the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the personal data subject are not violated;
— the personal data is subject to publication or mandatory disclosure under federal law.
7.2. The Operator does not process special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, health or intimate life through the Website.
7.3. The Operator does not make decisions based solely on automated processing that produce legal consequences for Users or otherwise significantly affect their rights and legitimate interests.
8. PROCESSING AND TRANSFER OF PERSONAL DATA
8.1. The Operator processes personal data using automated and non-automated means and takes appropriate legal, organisational and technical measures to protect it.
8.2. For the purposes stated in this Policy, the Operator may engage or provide the necessary personal data to:
— the provider of the Tilda website platform, for hosting and technical operation of the Website;
— YANDEX LLC, for the operation of Yandex Metrica, but only after the User has consented to analytics cookies;
— the Operator’s email service provider, for receiving, storing and sending business correspondence;
— hosting providers and technical contractors, for maintaining the availability and security of the Website;
— professional advisers and public authorities where disclosure is required by law or reasonably necessary to protect legal rights.
8.3. The specific recipients depend on the services actually used by the Operator and the applicable agreements. Each recipient or processor receives only the data reasonably required to perform its relevant task.
8.4. Personal data may be disclosed to public authorities only in the cases and manner prescribed by the laws of the Russian Federation.
8.5. The Operator remains responsible for organising the processing and protection of personal data entrusted to persons acting on its instructions to the extent prescribed by law.
8.6. A User may request access, clarification, blocking or deletion of their personal data, withdraw consent or request that processing cease by contacting support@ishiki.pro. The request should contain sufficient information to identify the applicant and the relevant processing activity.
8.7. When the processing purposes have been achieved, consent has been withdrawn or another lawful ground for ending processing has arisen, personal data shall be deleted or destroyed within the periods prescribed by law, unless continued storage is required to comply with a legal obligation, perform an agreement or protect legitimate interests.
9. ACTIONS PERFORMED WITH PERSONAL DATA
9.1. The Operator may collect, record, organise, accumulate, store, clarify, update, alter, retrieve, use, transfer, provide access to, depersonalise, block, delete and destroy personal data to the extent necessary for the purposes stated in this Policy.
9.2. The Operator may carry out automated personal data processing with or without receiving and/or transmitting information through information and telecommunications networks.
10. COOKIES AND WEB ANALYTICS
10.1. The Website uses cookies, which are small data files stored on the User’s device.
10.2. The Website may use the following categories of cookies:
— necessary cookies, which support the operation, security and user-selected settings of the Website and cannot be disabled through the Website’s cookie settings;
— analytics cookies, which are used to measure traffic, understand User activity and improve the Website and are activated only after the User has provided consent.
10.3. The Website uses Yandex Metrica, an analytics service provided by YANDEX LLC. The service may process an IP address, cookie identifiers, browser, operating system and device information, referral source, pages visited and actions performed on the Website.
10.4. Yandex Metrica shall not be activated until the User has consented to analytics cookies.
10.5. A User may select “Accept All” to allow both necessary and analytics cookies or “Reject All” to allow only necessary cookies. Refusing analytics cookies does not restrict access to the Website.
10.6. A User may withdraw consent through the “Cookie Settings” control on the Website and may also delete previously stored cookies through their browser settings.
10.7. The lifetime of cookies depends on their purpose and the settings of the relevant service. Analytics cookies shall be retained for no longer than 24 months unless the User deletes them or withdraws consent earlier.
11. CROSS-BORDER TRANSFER AND DATA LOCALISATION
11.1. The Operator does not carry out cross-border transfers of personal data through the English-language Website.
11.2. The initial collection, recording, organisation, accumulation and storage of personal data relating to citizens of the Russian Federation through the Internet are carried out using databases located within the Russian Federation.
11.3. If the Operator intends to begin any cross-border transfer of personal data, this Policy shall be updated and the Operator shall complete the procedures required by the laws of the Russian Federation before such transfer begins.
12. CONFIDENTIALITY AND SECURITY
12.1. The Operator and other persons who obtain access to personal data shall not disclose or distribute such data without the consent of the personal data subject unless otherwise provided by federal law.
12.2. The Operator applies appropriate legal, organisational and technical measures designed to protect personal data against accidental or unlawful access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions.
13. FINAL PROVISIONS
13.1. Questions and requests concerning personal data processing may be sent to support@ishiki.pro.
13.2. The Operator may amend this Policy when the Website, processing activities, service providers or applicable legislation change. The Policy remains in effect until replaced by a new version.
13.3. The current version of this Policy is publicly available at https://ishiki.pro/privacy_eng
13.4. Last updated: 5 August 2026.