As a visitor to the website https://complex.moscow/ (hereinafter the Website), I freely, of my own will and in my own interest grant Individual Entrepreneur Andrei Viktorovich Svirin, Taxpayer Identification Number (INN) 772872317733, Primary State Registration Number of the Individual Entrepreneur (OGRNIP) 322774600176722 (hereinafter the Controller), specific, purpose-specific, informed, conscious and unambiguous consent to the processing of personal data relating to my visits to the Website using the Yandex Metrica service on the terms set out below. For the purposes of this consent, the Personal Data Law means Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.
Controller’s postal address: P.O. Box 15, Moscow, 117647, Russian Federation.
Contact for personal data matters: privacy@complex.moscow.
Terms used in this document: INN — Taxpayer Identification Number; OGRNIP — Primary State Registration Number of the Individual Entrepreneur; LLC — limited liability company; IP address — the network address from which a request originates; cookies — small records that a website stores in the browser.
1. Purpose of Processing and Service Used
1.1. The purpose of processing is to assess Website traffic, referral sources, page use and Website usability, and to compare the corresponding metrics over different periods.
1.2. Processing uses the Yandex Metrica service, including Webvisor when that function is enabled. The service is provided by OOO “YANDEX”, address: 16 Lev Tolstoy Street, Moscow. Within the scope of this consent, that entity may receive data necessary for the operation of the relevant functions.
1.3. The visitor's choice is recorded and saved using the Website's tools. The question bank also uses its own aggregated interaction statistics, without including the free text of search queries.
2. Categories of personal data
2.1. Consent covers the following data about visits to the Website:
- the IP address when the service receives a request;
- cookie, browser and visit identifiers;
- technical information about the browser and device;
- addresses of pages visited;
- the date, time and duration of the visit;
- the referral source;
- navigation, clicks, scrolling and other website usage events.
2.2. When Webvisor is enabled, the visitor's sequence of actions and the display of the Website's pages are additionally recorded.
2.3. The content of enquiries, contact details entered in forms and uploaded documents are not included in the data processed under this consent. The Controller ensures that they are excluded from transmission as analytics parameters and from recording by Session Replay through the appropriate Website and service settings.
3. Processing Methods and Retention Periods
3.1. Processing is carried out using automated means and includes the collection, recording, systematization, accumulation, storage, retrieval, use for analysis, transfer (provision, access) to YANDEX LLC to the extent necessary, blocking, deletion and destruction of personal data.
3.2. The processing and retention period for analytics data that makes it possible to associate visits with a specific visitor or browser is limited to the period necessary to analyze and compare metrics over different periods and may not exceed three years from the date the relevant data was collected. Upon expiry of that period, the data must be deleted or converted into aggregate statistics that make it impossible to identify a specific visitor. If the purpose of processing is achieved earlier or consent is withdrawn, the provisions on early termination of processing apply. Aggregate metrics that do not permit identification of a specific visitor may be retained for statistical purposes.
3.3. The specific features of processing and the retention periods for data within Yandex's infrastructure are determined by the Terms of Use of the Yandex Metrica Service (https://yandex.ru/legal/metrica_termsofuse/ru/), section 8 of the Yandex Privacy Policy (https://yandex.ru/legal/confidential/ru/) and the documentation for the relevant functions. The three-year maximum period established by the Controller limits processing for the stated purpose and does not change the service terms. The Controller ensures compliance with this maximum period by deleting the data or converting it into aggregate statistical indicators that exclude the possibility of identifying a particular visitor. Reference to the service terms does not override the retention limit established by this document.
3.4. Webvisor recordings are stored in the service for 15 days, including the current day, in accordance with Yandex documentation: https://yandex.ru/support/metrica/ru/webvisor/requirements.html. This period applies separately from the overall maximum retention period for analytics data. Cookie lifetimes are determined by the Personal Data Processing Policy and service documentation and do not determine the data retention periods on the service's servers.
3.5. Consent remains valid until withdrawn, but for no more than 180 days from the date the choice is saved. The technical details of local storage and deletion of the entry after expiry are described in section 6 of the Personal Data Processing Policy. New consent is requested when that period expires. Changes to the purposes of processing or categories of data do not change the scope of previously given consent.
3.6. A minimal record confirming receipt of consent may be retained on a separate lawful basis with the contents and for the periods provided for in the Personal Data Processing Policy: https://complex.moscow/legal/privacy-policy/.
4. Procedure for Giving and Withdrawing Consent
4.1. Consent is expressed by clicking the Allow analytics button in the Website banner, or by enabling analytics and then clicking Save choice in the Analytics settings panel. Visitors are able to read this document before giving consent.
4.2. Continuing to use the Website, closing the banner and submitting an inquiry do not constitute consent to analytics.
4.3. Refusing to grant this consent does not restrict the ability to use the Website and inquiry forms.
4.4. The choice may be changed and consent withdrawn using the “Analytics settings” control available on the Website. After refusal or withdrawal of consent, no new analytics requests are sent.
4.5. Requests relating to previously processed data should be sent to the email address privacy@complex.moscow or to the Controller's mailing address.
4.6. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal was received. Processing is terminated and previously obtained data is destroyed in the manner and within the periods established by the Personal Data Law, taking account of any other applicable lawful bases for processing.
4.7. This consent does not cover receipt of advertising and does not replace separate consent to the processing of personal data in connection with submission of an inquiry.