Privacy Policy
1. Introduction
This Privacy Policy explains how Andrey Odintsov, Individual Entrepreneur ("we", "us", "our", or the "Controller") processes personal data collected through our website sprocket.studio and in connection with our web development services.We are committed to protecting your personal data and respecting your privacy rights. This policy complies with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
2. Data Controller Information
Name: Andrey Odintsov, Individual Entrepreneur
Tax ID (INN): 773123320874
Registration Number (OGRNIP): 325774600471494
Address: Office 285, Building 2, 11 Dmitry Donskoy Boulevard, Moscow, 117216, Russian Federation
Phone: +7 (993) 262-98-93
Email: legal@sprocket.studio
Website: sprocket.studio
3. Categories of Personal
Data We Process
3.1. Newsletter Subscription
- Name
- Email address
3.2. Contact Forms
- Name
- Email address
- Telegram username (optional)
- Message content
3.2. Technical Data
- Cookies and similar tracking technologies
- Log files
- Device information
4. Legal Basis for Processing
We process your personal data based on the following legal grounds:
- Consent: For newsletter subscriptions, marketing communications, and analytics cookies.
- Contract: To respond to inquiries, provide web development services, and manage client relationships.
- Legitimate Interests: To improve our website and services, ensure network and information security, prevent fraud, and conduct direct marketing to existing clients (with an opt-out option). We conduct a legitimate interest assessment to balance our interests with your rights.
- Legal Obligations: To comply with tax, accounting, or other legal requirements.
5. Purposes of Processing
We process your personal data for the following purposes:
- Service Delivery: To respond to inquiries, provide quotes, and deliver web development services.
- Communication: To send newsletters, updates about our services, and marketing materials (with your consent).
- Website Improvement: To analyze website usage and enhance user experience (using anonymized data where possible).
- Legal Compliance: To comply with applicable laws and regulations.
- Business Operations: To manage client relationships and internal business processes.
6. Data Recipients
We may share your personal data with the following categories of recipients:
6.1 Service Providers
- Email service providers (e.g., for newsletter distribution)
- CRM systems (e.g., for client relationship management)
- Analytics providers (e.g., Yandex.Metrica, using anonymized data)
- Web hosting providers
- Payment processors (if applicable)
6.2 Professional Advisors
- Legal advisors
- Accountants and auditors
- Business consultants
6.3 Authorities
- Law enforcement agencies
- Regulatory authorities
- Government bodies (when required by law)
All third-party processors are contractually obligated to process your data in accordance with this policy and applicable data protection laws.
7. International Data Transfers
Your personal data is primarily stored and processed in the Russian Federation.
We only transfer personal data outside of Russia in the following cases:
- When necessary to provide services you have requested.
- With your explicit consent.
- When required by law.
For transfers to countries outside the European Economic Area (EEA), we ensure appropriate safeguards, such as standard contractual clauses approved by the European Commission, to protect your data. You may request details of the specific countries or safeguards by contacting us.
8. Data Retention
We retain your personal data for the following periods:
- Newsletter subscriptions: 3 years from last engagement or until you withdraw consent.
- Contact form data: 3 years from last communication or until you request erasure.
- Client data: Duration of the business relationship plus 5 years (for tax/legal requirements).
- Analytics data: As per Yandex.Metrica retention policies (data is anonymized where possible).
- Cookie data: See our Cookie Policy section.
After the retention period expires, we securely delete or anonymize your personal data.
9. Your Rights
Under the GDPR, you have the following rights:
- Right of Access: You can request information about whether we process your personal data and receive a copy of it. |
- Right to Rectification: You can request correction of inaccurate or incomplete personal data.
- Right to Erasure: You can request deletion of your personal data in certain circumstances.
- Right to Restriction: You can request that we limit the processing of your personal data in certain cases.
- Right to Data Portability: You can receive your personal data in a structured, commonly used format and transfer it to another controller.
- Right to Object: You can object to processing based on legitimate interests, including profiling or direct marketing.
- Rights Related to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing that significantly affect you. We do not engage in such automated decision-making.
- Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time without affecting prior processing.
- Right to Complain: You can lodge a complaint with a supervisory authority in your country of residence.
10. Exercising Your Rights
To exercise any of your rights, contact us at:
• Email: legal@sprocket.studio
• Post: Office 285, Building 2, 11 Dmitry Donskoy Boulevard, Moscow, 117216, Russian Federation
We will respond within one month of receiving your request. For complex requests, we may extend this period by up to two months and will inform you of the reasons for the delay. There is no fee unless your request is manifestly unfounded or excessive.
Please provide:
- Your name and contact details
- Specific information about your request
- Any relevant details to help us identify you in our systems
- A copy of your ID (used only to verify your identity)
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:
- Password-protected systems
- Encryption of sensitive data
- Regular security updates and patches
- Access controls and authentication
- Regular backups
13. Children's Privacy
Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware of such data, we will delete it promptly.
14. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for their privacy practices. We encourage you to read their privacy policies before providing personal data.
15. Data Breach Notification
If a personal data breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay, providing:
- The nature of the breach
- The likely consequences
- Measures taken or proposed to address the breach
- Contact details for more information
16. Changes to This Policy
We may update this Privacy Policy from time to time.
We will notify you of material changes by:
- Posting the new policy on our website
- Sending an email notification (for registered users)
- Displaying a notice on our website
17. Contact Us
For questions about this Privacy Policy or our data processing activities, contact us:
• Email: legal@sprocket.studio
• Phone: +7 (993) 262-98-93
• Post: Office 285, Building 2, 11 Dmitry Donskoy Boulevard, Moscow, 117216, Russian Federation
18. Supervisory Authority
If you are not satisfied with our response to your privacy concerns, you can lodge a complaint with your local data protection authority. For EU residents, find your local authority at: https://edpb.europa.eu/about-edpb/board/members_en
Last updated: 27.07.2025
Effective date: 27.07.2025