Revision of {{ DATE }}. The current revision is always published at predicalendar.ru/privacy-policy/ (Russian) and predicalendar.com/privacy-policy/ (English).

1. General provisions

1.1. This Policy sets out how personal data is processed and what measures are taken to keep it secure by the individual (физическое лицо) {{ FULL NAME OF THE OPERATOR }} (the “Operator”, “we”). It is published pursuant to Part 2 of Article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.

1.2. The personal data operator (оператор персональных данных) within the meaning of Item 2 of Article 3 of Federal Law No. 152-FZ is the individual named above. Contact for any matter related to personal data processing: [email protected].

1.3. The Policy covers two products:

• the Website — the websites predicalendar.ru and predicalendar.com (lunar calendar);
• the App — the PrediApp mobile application (com.predicalendar.app) and the service api.predicalendar.ru that serves it.

Together — the “Services”. Processing in each Service is described separately, because the sets of data differ.

1.4. The Policy applies to users of the Services. The Operator is not an employer and does not process employees’ personal data.

1.5. Terms are used in the meanings given in Article 3 of Federal Law No. 152-FZ.

1.6. This Policy is not a consent to personal data processing. Where processing requires consent, it is requested separately and by a separate action — using the Services does not by itself constitute consent.

1.7. The Policy is published in Russian and in English. In case of any discrepancy, the Russian text prevails.

2. Processing principles

We process personal data in accordance with Article 5 of Federal Law No. 152-FZ; in particular, we:

• process only the data needed for the stated purposes and do not collect excessive data;
• do not merge databases processed for incompatible purposes;
• do not keep data longer than the purpose requires, unless a different period is set by law or contract;
• take reasonable steps to keep the data accurate and up to date.

3. What data we process

3.1. Website: data processed always (the Website does not work without it)

The Website does not determine your location. The lunar calendar on the Website is calculated for a fixed city (Moscow on the Russian version), not for where you are. We do not derive a city from your IP address, do not request browser geolocation and do not receive GPS data. If you choose a city yourself on certain pages, that choice is part of the page address and is not linked to you.

The Website collects nothing else about you: there is no registration, no forms with personal details, no subscriptions or mailing lists.

3.2. Website: data processed only with your consent (web analytics)

This data is processed only if you have given consent in the banner shown on your first visit. If consent is not given or is withdrawn, the analytics tools are not loaded and the data is not collected.

The consent request is shown in the language of the version of the Website you are viewing.

Session recording (Webvisor) is switched off. We do not record or replay visitor sessions: mouse movements, contents of input fields and the sequence of your actions on a page are not stored and are not available to us.

No advertising networks, advertising pixels or tag managers are used on the Website.

3.3. App: data processed always

The App does not request location permission and does not receive the precise location of the device: the only permission it uses is internet access. Location is determined approximately from the IP address or set by you manually.

Settings (city, country, coordinates, time zone, language) are stored on your device and are not sent to our servers. You can delete them by uninstalling the App or clearing its data in the operating system settings.

The service api.predicalendar.ru does not keep a history of your requests: it performs an astronomical calculation and returns the result. Server logs contain only technical service records without coordinates.

If you choose a location on the map, the map is displayed using the Mapbox service; the place name for the coordinates is obtained from the geocoder of your operating system.

3.4. App: analytics

The App includes a tool for usage statistics and crash reports, but data sending to it is switched off: as of the revision date above, the App does not send statistics and does not collect data about your use of it. Collection will be enabled only after you give a separate consent; until then the data does not leave your device. Automatic collection of location, advertising identifiers and purchase data is disabled.

3.5. Contacting us

If you write to [email protected], we process your e-mail address, the content of your message and any details you attach — to reply and, where required, to fulfil your request as a personal data subject.

3.6. Paid features and purchases

Not active at present. All features of the Services are free, no payments are accepted and no payment data is processed. If paid features appear in the App, this Policy will be updated before their launch to describe the data processed; bank card data will in any case be processed by the app store, not by us.

3.7. What we do not do

We do not process:

• special categories of personal data (health, racial or ethnic origin, political opinions, religious beliefs, intimate life) — Article 10 of Federal Law No. 152-FZ;
• biometric personal data — Article 11;
• bank card data or other payment details.

Lunar calendar recommendations (including favourable days for particular activities) are generated identically for all users from an astronomical calculation for the given date and location. This is the content of the Service, not information about you: we do not ask for or store information about your plans, health or procedures you have had.

We do not send newsletters, do not use social network or messenger services, do not collect contact details for marketing and do not place social network buttons or widgets on the Website.

We do not take decisions that produce legal consequences for you solely on the basis of automated processing of personal data (Article 16 of Federal Law No. 152-FZ).

4. Purposes and legal grounds

5. Consent: how it is given and withdrawn

5.1. Consent is required only for analytics (section 3.2). It is requested as a separate document and by a separate action — on your first visit the Website shows a banner in which analytics can be accepted or declined. Until you choose, the analytics tools are not loaded.

5.2. No answer, closing the banner, continuing to browse the Website or scrolling the page do not count as consent.

5.3. You may withdraw consent at any time: click the “Cookie settings” link at the bottom of any page of the Website and choose “Decline”. The analytics tools stop loading as soon as the page reloads, and we delete the Yandex Metrica cookies set on the Website’s domain. We are technically unable to delete cookies set on Yandex domains — you can delete them in your browser settings or block them with the Yandex Metrica Blocker (yandex.ru/support/metrica/general/opt-out.html). Consent may also be withdrawn by e-mail to [email protected]. Withdrawal does not affect the lawfulness of processing carried out before it.

5.4. Withdrawing consent to analytics does not limit your use of the Services: the whole lunar calendar is available without consent to analytics.

5.5. The fact of your choice, its date and the version of the consent text are stored in the pc_analytics_consent cookie in your browser only — this information is not sent to and not stored on our server. The cookie is valid for 12 months; if you delete it or it expires, we will show the consent request again on your next visit.

6. Who else processes the data

We do not sell personal data and do not pass it to third parties for their own purposes. Certain operations are carried out by parties we have engaged to process data under a contract (Part 3 of Article 6 of Federal Law No. 152-FZ), or by services your browser or device connects to:

Personal data may also be provided to state authorities on the grounds and in the manner established by the laws of the Russian Federation.

7. Place of processing. Cross-border transfer

7.1. The databases in which we record, systematise, accumulate, store, update and retrieve personal data of citizens of the Russian Federation are located in the Russian Federation, as required by Part 5 of Article 18 of Federal Law No. 152-FZ.

7.2. When you use the Website, your browser connects to foreign static-file delivery networks (section 6), which receive your IP address. The Website initiates no other connections to foreign services.

7.3. When you use the App, your device connects to foreign services in the cases listed in section 6 (map, geocoder, IP geolocation).

8. Retention periods

In all cases we stop processing and destroy personal data when the purpose is achieved or consent is withdrawn — within no more than 30 days (Parts 3 and 5 of Article 21 of Federal Law No. 152-FZ), unless the law provides otherwise.

9. Your rights

Under Articles 14–17, 20 and 21 of Federal Law No. 152-FZ you have the right to:

• obtain confirmation that your personal data is being processed and the information listed in Part 7 of Article 14 (legal grounds and purposes, methods used, retention periods, the list of data processed, the parties to whom data is transferred, and more);
• demand that your personal data be corrected if it is incomplete, inaccurate or out of date;
• demand that personal data be blocked or destroyed if it was obtained unlawfully or is not necessary for the stated purpose;
• withdraw consent to processing;
• object to processing for the purpose of promoting goods and services (Part 1 of Article 15) — we do not carry out such processing;
• appeal against our actions or inaction to Roskomnadzor or in court (Article 17).

10. How to exercise your rights

10.1. Send your request to [email protected] {{ or by post to: CORRESPONDENCE ADDRESS — at the Operator’s discretion }}.

10.2. Under Part 3 of Article 14 of Federal Law No. 152-FZ, a request must contain: the number of the principal identity document of the applicant (or their representative), its date of issue and the issuing authority; information confirming your relationship with us or otherwise confirming that we process your data; your signature (or your representative’s). The request may be sent electronically and signed with an electronic signature.

We understand this is inconvenient, so: if your request concerns data linked to a particular session on the Website or a particular installation of the App, it is enough to give us the details that identify that data unambiguously (for example, the value of the sessionid cookie together with the date and approximate time of the visit). We do not require an identity document to fulfil a request to delete such data.

10.3. Our response times:

10.4. If we refuse a request, we give a reasoned reply citing the legal provision on which the refusal is based.

11. Data protection measures

We take the legal, organisational and technical measures provided for in Articles 18.1 and 19 of Federal Law No. 152-FZ, including:

• data in transit between your device and our servers is encrypted (HTTPS);
• access to the servers on which data is processed is restricted;
• we do not collect data the Services can work without and do not keep data longer than necessary;

12. Minors

The Services are not aimed specifically at children and do not require registration or entry of any details about yourself. We do not knowingly collect personal data of persons below the age at which they may give consent on their own. Consent to processing a minor’s personal data is given by their legal representative (Part 1 of Article 9 of Federal Law No. 152-FZ). If you are a legal representative and believe we have processed your child’s data, write to [email protected] — we will delete it.

13. Changes to the Policy

We may amend the Policy. The current revision, with its date, is always published at predicalendar.ru/privacy-policy/ and predicalendar.com/privacy-policy/. If changes affect the set of data processed or purposes that require consent, we will request consent again before such processing begins. The consent request has its own version, shown in the request itself; when the set of data or recipients changes materially, we ask for consent anew.

14. Details and contacts

Operator: individual {{ FULL NAME }}
Taxpayer ID (ИНН): {{ … }}
Correspondence address: {{ … — at the Operator’s discretion; publishing an address is not mandatory if enquiries are accepted by e-mail }}
E-mail for personal data matters: [email protected]

The Operator is an individual; the requirement to appoint a person responsible for organising personal data processing (Part 1 of Article 18.1 of Federal Law No. 152-FZ) applies to legal entities. Enquiries are handled by the Operator personally.

Roskomnadzor — the authorised body for the protection of the rights of personal data subjects: rkn.gov.ru, pd.rkn.gov.ru