Personal data processing and privacy policy
Effective date: 17.08.2026. Last revised: 17.08.2026.
1. General provisions
1.1. This Personal Data Processing and Privacy Policy (the «Policy») sets out how personal data of users of the k-publishing.ru website (the «Website») is processed and protected. It has been drawn up in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27.07.2006 «On Personal Data» («FZ-152»), Federal Law No. 149-FZ of 27.07.2006 «On Information, Information Technologies and Information Protection», and other regulations of the Russian Federation.
1.2. The personal data operator (the «Operator») is:
- Full name: Traffic Limited Liability Company (OOO «Trafik»)
- OGRN 1027806866724, INN 7813175200, KPP 781301001
- Registered address: office 1, room 12, premises 40-N, 1-3 letter A Lva Tolstogo St., Aptekarsky Ostrov municipal district, Saint Petersburg, 197022, Russia
- Telephone: +7 931 577-02-26
- E-mail for enquiries: info@k-publishing.ru
1.3. The Website is the corporate website of the Kinoafisha internet publishing house. It contains information about the company, its media projects, services, terms of cooperation and job openings. The Website has no user registration, personal accounts, comments, subscriptions or advertising.
1.4. By using the Website, the User confirms that they have read this Policy, agree to the terms on which their personal data is processed and accept them unconditionally. A User who does not agree with the Policy should refrain from using the Website.
1.5. This Policy applies to all personal data processed by the Operator in connection with the Users’ use of the Website.
2. Terms and definitions
Personal data — any information relating to a directly or indirectly identified or identifiable natural person (the personal data subject).
Processing of personal data — any action or set of actions performed on personal data with or without the use of automation, including collection, recording, organisation, accumulation, storage, rectification, retrieval, use, transfer, depersonalisation, blocking, deletion and destruction of personal data.
User — a natural person using the Website, including a visitor to the Website and a person submitting an enquiry through a contact form.
Cookie — a small text file stored on the User’s device when they visit the Website.
Information product — the Website and its materials; the age rating is set at «16+».
3. Categories of personal data processed
3.1. The Operator processes the following categories of Website Users’ data:
3.1.1. Technical data transmitted automatically by the User’s device when accessing the Website and recorded in the web server logs:
- IP address;
- browser information (type, version), language settings;
- operating system and device information;
- the source of the visit (referrer);
- the address of the requested page, the date and time of the request.
3.1.2. Data voluntarily provided by the User when making an enquiry through the Website’s contact forms or by e-mail:
- name, organisation name or alias — at the User’s discretion;
- the contact details supplied by the User: e-mail address, messenger username or telephone number;
- the subject and content of the enquiry.
3.1.3. Behavioural data collected by the web analytics system (see clause 3.4): pages viewed, source of the visit, visit duration, on-page actions — clicks, scrolling, pointer movement, interaction with form fields excluding their content — and the anonymous visitor identifier assigned by the analytics service.
3.2. The Operator does not request or process special categories of personal data (data on health, political views, racial or ethnic origin and the like), nor biometric personal data. Users should not include such data in the text of an enquiry.
3.3. The Operator does not process personal data of minors under 14 years of age. The age rating of the Website as an information product is 16+.
3.4. Web analytics. The Website runs a Yandex Metrica counter (YANDEX LLC, Russian Federation), including the on-page session recording feature («Webvisor»). The service collects and processes depersonalised visit data in accordance with the Yandex Metrica Terms of Use and the Yandex Privacy Policy. No advertising systems are connected to the Website and no advertising is displayed.
4. Purposes of processing
4.1. The Operator processes personal data for the following purposes:
- operating the Website and displaying its materials correctly;
- collecting depersonalised traffic statistics, analysing visitor behaviour and assessing the usability of the Website by means of web analytics;
- receiving, reviewing and answering Users’ enquiries submitted through the contact forms or by e-mail, including enquiries about advertising, cooperation, the sale of projects and employment;
- reviewing applications from candidates who have responded to a job opening;
- preventing automated mailings, fraud and attacks on the Website;
- complying with the requirements of the legislation of the Russian Federation.
4.2. The Operator does not use Users’ personal data for marketing mailings and does not pass it to third parties for such purposes.
5. Legal grounds for processing
5.1. Personal data is processed on the following grounds:
- the User’s consent to the processing of personal data (art. 6, part 1, cl. 1 of FZ-152), given by ticking the box in the contact form and submitting the enquiry;
- the necessity of exercising the rights and legitimate interests of the Operator, provided that the rights and freedoms of the personal data subject are not infringed (art. 6, part 1, cl. 7 of FZ-152);
- the necessity of performing a contract to which the personal data subject is a party, or of entering into such a contract at the subject’s initiative (art. 6, part 1, cl. 5 of FZ-152);
- the fulfilment of obligations imposed on the Operator by the legislation of the Russian Federation.
6. Methods and retention periods
6.1. Personal data is processed both with and without the use of automation. Users’ personal data is recorded, organised, accumulated, stored, rectified and retrieved using databases located in the territory of the Russian Federation.
6.2. Retention periods:
- technical data in the web server logs — up to 6 (six) months from the moment it is recorded;
- depersonalised web analytics data — for the periods established by the rules of the Yandex Metrica service;
- data relating to Users’ enquiries — for 3 (three) years from the date of the last enquiry, unless the law provides otherwise;
- data of candidates who have responded to a job opening — for 1 (one) year from the date the response was received, unless the User withdraws consent earlier.
6.3. Once the retention period expires, personal data is depersonalised or destroyed.
7. Transfer to third parties and cross-border transfer
7.1. The Operator may transfer personal data or grant access to it to the following categories of parties, to the extent necessary to achieve the purposes set out in section 4:
- The Yandex Metrica web analytics service (YANDEX LLC, Russian Federation) — to the extent of depersonalised data about visits to the Website. Processing rules: https://yandex.ru/legal/metrica_termsofuse/.
- Hosting and infrastructure providers engaged by the Operator to run the Website and its mail service.
- Public authorities and officials — in the cases expressly provided for by the legislation of the Russian Federation.
7.2. Personal data is transferred to third parties in cases other than those listed in clause 7.1 only with the User’s consent.
7.3. Cross-border transfer. The Operator does not carry out cross-border transfer of Website Users’ personal data. The third-party services used — Yandex Metrica and the Yandex Maps widget — belong to YANDEX LLC and process data in the territory of the Russian Federation in accordance with the documents at https://yandex.ru/legal/confidential/.
7.4. The Operator does not sell personal data to third parties.
8. Cookies
8.1. Cookies on the Website are set by the Yandex Metrica web analytics service and by the third-party Yandex Maps service when the map widget in the «Contacts» section is loaded. No advertising identifiers are used.
8.2. A detailed description of the cookies used, their purposes, storage periods and the ways to refuse them is given in the Cookie Policy, which forms an integral part of this Policy.
8.3. The User may restrict or block the use of cookies in their browser settings at any time. This does not affect access to the main materials of the Website.
9. Rights of the personal data subject
9.1. Under FZ-152 the User has the right to:
- obtain information concerning the processing of their personal data;
- demand that their personal data be rectified, blocked or destroyed if the data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
- withdraw consent to the processing of personal data;
- appeal against the Operator’s acts or omissions to the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) and in court;
- protect their rights and legitimate interests, including claiming damages and compensation for moral harm in court.
9.2. To exercise the rights listed in clause 9.1 the User sends an enquiry to info@k-publishing.ru with the subject line «FZ-152 request», stating: their surname, first name and patronymic or another identifying set of data; the substance of the request; and contact details for the reply.
9.3. The Operator reviews the enquiry within 30 (thirty) calendar days of receipt and sends a reasoned reply.
9.4. Consent to the processing of personal data is withdrawn at the same address. Once the withdrawal is received, the Operator ceases processing and ensures that the data is destroyed within 30 (thirty) days, except where continued processing is expressly required by law.
10. Personal data protection measures
10.1. The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, dissemination and other unlawful acts.
10.2. Such measures include: the use of information protection tools (SSL/TLS, firewalls, anti-virus protection); separation of data access rights; regular audits and software updates; and keeping a record of enquiries from personal data subjects.
10.3. The Operator is not liable for the unlawful acts of third parties who have obtained access to the User’s data as a result of the User breaching information security rules.
11. Amendments to the Policy
11.1. The Operator may amend this Policy unilaterally. The current version of the Policy is always available on the Website, stating the date of the last revision.
11.2. The Operator notifies the User of material amendments to the Policy by publishing a corresponding notice on the Website at least 7 (seven) calendar days before the amendments take effect.
11.3. Continued use of the Website after amendments to the Policy take effect means that the User agrees to those amendments.
12. Contacts
For all matters relating to the processing of personal data:
- E-mail: info@k-publishing.ru (subject line: «FZ-152 request»)
- Postal address: OOO «Trafik» (OGRN 1027806866724, INN 7813175200), office 1, room 12, premises 40-N, 1-3 letter A Lva Tolstogo St., Aptekarsky Ostrov municipal district, Saint Petersburg, 197022, Russia
The authority responsible for protecting the rights of personal data subjects is the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor).
This is an English translation provided for convenience. The document is legally binding in its Russian version.
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