Personal data processing policy
Version of 28 July 2026. This document applies to the website https://www.re-panel.ru and describes what data RePanel processes, why it is needed and how individuals can exercise their rights.
This is an English translation provided for convenience. In case of any discrepancy, the Russian version prevails.
01
General provisions
This Policy has been drawn up in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable laws and regulations of the Russian Federation.
The Policy applies to personal data that the operator receives through the website when orders are placed, paid for and delivered, when the operator is contacted, and when the website’s technical features are used. The operator does not process special categories of personal data or biometric personal data through the website.
02
Personal data operator
- Operator
- Individual Entrepreneur Nikita Igorevich Kuznetsov
- INN
- 770470443780
- OGRNIP
- 324774600411399
- Address
- apt. 22, bldg. A, 14 Ulansky Lane, Moscow, Russia
- Email for data enquiries
- panels@recycleobject.com
03
Processing principles
The operator processes only the data necessary for specific, predefined and lawful purposes, does not merge databases whose processing purposes are incompatible, ensures that the data are accurate and keeps them no longer than the purposes of processing or the law require. Access is granted only to persons who need it for their work.
04
Purposes, categories of data and retention periods
| Purpose | Data | Retention period |
|---|---|---|
| Responding to enquiries and preparing proposals | name, company, phone number or Telegram, email, city, content of the enquiry | until the communication is complete and no longer than 3 years after the last contact |
| Placing and fulfilling orders | first name, surname, phone number, email, city, delivery address, order contents and value, comment, delivery details and payment status | for the duration of the contract and thereafter for the periods established by accounting and tax legislation, as a rule at least 5 years |
| Payment, refunds and handling of claims | order number and amount, payment status, contact details, refund details. The operator does not receive bank card details | for the duration of the obligations and the applicable document retention periods |
| Website operation and security | IP address, date and time of the request, page address, browser and device type, technical error logs and security events | no more than 12 months, unless a longer period is needed to investigate an incident |
05
Legal grounds
The grounds for processing are: the consent of the personal data subject; the need to conclude or perform a contract at the subject’s initiative; the performance of obligations imposed on the operator by law; and the operator’s legitimate interest in ensuring the security of the website and protecting its rights, provided that the rights and freedoms of the subject are not violated.
Consent to the processing of personal data is drawn up separately from other documents and is confirmed by a separate action of the user. Consent to receive advertising messages is not requested through the website’s forms, and no advertising mailings are sent on that basis.
06
Processing operations and methods
The operator may carry out the collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, provision to authorised recipients, blocking, deletion and destruction of data. Processing is carried out using automated means and, where necessary to fulfil an order, without them.
The operator does not disseminate or publish personal data and does not make decisions that produce legal consequences solely on the basis of automated processing.
07
Data recipients
To the extent necessary for a specific operation, data may be provided to:
- Bank Tochka LLC and Tochka JSC — to process and confirm payments;
- CDEK-Global LLC — to calculate and arrange the chosen delivery;
- a Russian hosting, database and backup provider acting on the operator’s instructions;
- public authorities — only in the cases and to the extent provided for by law.
The operator enters into contracts with persons processing data on its instructions that set out requirements for confidentiality, security, localisation and deletion of data.
08
Localisation and cross-border transfer
When personal data of citizens of the Russian Federation are collected via the internet, their recording, systematisation, accumulation, storage, clarification and retrieval are carried out using databases located in the territory of the Russian Federation.
The operator does not carry out cross-border transfer of personal data collected through the website’s forms. A service involving such transfer may be connected only after the requirements of Article 12 of Federal Law No. 152-FZ have been met, this Policy has been updated and, where required, separate consent has been obtained.
09
Cookies and local storage
The website uses only strictly necessary cookies and browser local storage entries: for the cart, an applied promo code, remembering the choice made in the cookie notice, and secure staff access to restricted sections. They are not used for advertising profiling or cross-site tracking.
Users can delete such data in their browser settings. After deletion, some website features, such as the cart or signing in to a restricted section, may need to be set up again.
10
Data protection and deletion
The operator applies legal, organisational and technical protection measures: access control, secure data transmission, logging of actions in information systems, backups, software updates, incident monitoring and confidentiality obligations for persons with access to the data.
Once the purpose of processing has been achieved, the data are destroyed or depersonalised within no more than 30 days, unless a contract or the law provides another ground for retaining them. If unlawful processing is identified, the operator stops it and takes action within the time limits set by Article 21 of Federal Law No. 152-FZ.
11
Rights of the personal data subject
The subject has the right to obtain information about the processing of their data, to demand that the data be clarified, blocked or destroyed, to withdraw consent, to demand that processing be stopped, and to appeal against the operator’s actions to Roskomnadzor (the Federal Service for Supervision of Communications, Information Technology and Mass Media) or in court.
Requests can be sent to panels@recycleobject.com. A request should state the sender’s full name, contact details for the reply, information confirming their relationship with the operator, and the substance of the request. The operator responds within the time limits established by law; a request to stop processing is, as a rule, considered within 10 working days.
12
Changes to the Policy
The operator may update the Policy when its processes, services or legislation change. A new version takes effect from the moment it is published on this page. The version date is shown at the beginning of the document.