Controller and scope
The personal data controller is Pavel Valeryevich Kladov (Кладов Павел Валерьевич), Russian taxpayer identification number (INN) 164510316803, registered under the professional income tax regime. Kladov Production is the name used to present the controller’s services.
This policy covers kladovproductions.ru, including its Russian and English versions, and enquiries sent using the contact details on the website. For personal data enquiries, email pavelkladov@gmail.com.
The policy is based on Russian Federal Law No. 152-FZ of 27 July 2006 on Personal Data. It provides information about processing. Opening or reading it, or continuing to use the website, does not replace separate consent where consent is required.
Data processed
The website has no enquiry forms. You can contact me by email, Telegram, WhatsApp or LinkedIn, or download a project brief and send the completed document through your chosen channel.
- Enquiries: the name you provide; email, phone number, username or profile link; company and role where relevant; and personal data contained in correspondence, the project brief and attachments.
- Preparing and performing a contract: information about the client or their representative, contact details, contractual particulars and payment information necessary for that contract and legal obligations. These details are requested separately when needed.
- Website visits: IP address, request date and time, page address, browser and device information, technical events and cookie identifiers. Where analytics is used, processing may also include referral sources, page views, link clicks, scrolling and other interaction events.
Please do not send health information, biometric data, passwords, copies of identity documents or other people’s personal data unless they are necessary for an agreed task and there is a separate lawful basis for providing them.
Purposes and legal bases
Responding to enquiries and estimating projects
Contact details and enquiry content are used to respond, discuss requirements and prepare an estimate or proposal. Where you initiate a contract concerning yourself, processing is based on Article 6(1)(5) of Law No. 152-FZ. Where consent is required for other processing, it is requested separately using the consent for handling enquiries.
Contractual work
Data is used to agree and deliver work, communicate with the client, prepare documents and handle payments. The bases are contract performance and legal obligations. Representatives’ data is processed where an applicable basis exists, including legitimate communication with a client while respecting the representative’s rights.
Website operation and security
Technical logs and necessary cookies support page delivery, sessions, troubleshooting and protection against abuse. Processing is limited to these tasks and is based on the legitimate interest in operating and protecting the website while respecting visitors’ rights.
Visit statistics
Yandex Metrica and Google Analytics are used to assess visits and improve website structure and content. Optional analytics requires separate prior consent. See the Cookie policy for details.
Consent to handle an enquiry does not cover visit tracking, promotional messages or publication of personal data. Additional purposes require their own lawful basis.
Hosting and external services
- Timeweb: website hosting and infrastructure services. The provider may process technical request data as part of hosting.
- Yandex Metrica and Google Analytics: visit data processing where the corresponding analytics is permitted. If Session Replay (Webvisor) is enabled in Metrica, it may record pointer movements, clicks and scrolling. The data collected depends on counter settings.
- Gmail: the email service used for pavelkladov@gmail.com.
- Telegram, WhatsApp and LinkedIn: external communication channels chosen by the visitor. Their own service rules also apply after following a link.
Using a service does not authorise unlimited use of personal data. Disclosure and delegated processing require a lawful basis and are limited to what is necessary. The controller remains responsible for the processing they organise.
Google and other foreign services may involve processing outside Russia. This requires a separate assessment of recipients, storage locations and applicable localisation and cross-border transfer requirements. A visitor’s consent does not by itself remove those requirements.
Data may be provided to competent authorities where, and to the extent, required by law.
Processing and retention
Data may be processed electronically and manually. Operations may include collection, recording, organisation, storage, correction, retrieval, use, necessary access or disclosure, blocking, deletion and destruction. The operations used depend on the purpose.
- Enquiries and briefs: until the discussion and preparation of the response or proposal are complete. Where consent is the basis, its maximum duration is one year from the date it is given; an earlier completion of the purpose or withdrawal takes precedence. Continued processing afterwards requires another valid basis.
- Contract and payment records: during contract performance and subsequently for the mandatory retention periods applicable to the relevant records.
- Technical data: for the period necessary to operate the website and diagnose or investigate particular errors and abuse. Log and backup settings must correspond to these purposes.
- Analytics data: within the permitted purpose and valid consent, taking service retention settings into account. A browser cookie’s lifetime is different from the retention of information already sent to reports.
Once the purpose is complete or consent is withdrawn, data is deleted or destroyed within the statutory period, generally within 30 days, unless another basis allows continued processing. If immediate destruction is technically impossible, blocking and subsequent destruction follow the procedure required by law.
Your rights and requests
You may request information about processing, seek correction, blocking or deletion where the legal conditions apply, withdraw consent and complain to Roskomnadzor, the Russian data protection authority, or a court.
Email pavelkladov@gmail.com with the subject “Personal data”. Describe your request and provide information that helps link it to your correspondence or visit. Proportionate verification of identity or authority may be requested to avoid disclosing information to someone else.
Information about processing is provided within 10 working days after receipt of a duly submitted request. A legally permitted extension is limited to 5 working days, with an explanation. Correction, cessation and destruction follow the corresponding deadlines under Law No. 152-FZ.
Withdrawal does not stop processing that the controller is entitled or required to continue on another lawful basis, such as contract performance or mandatory record retention.
Security and policy updates
The controller arranges safeguards appropriate to the data and risks, including restricted access, software maintenance, an encrypted website connection and measures to detect and address incidents. Access to working materials is limited to what is needed.
The current version is published here. Changes do not automatically broaden consent already given. New consent is required where purposes or the scope of processing based on consent change materially.