This Privacy Policy explains what personal data we collect when you visit empetrum.dev or contact us, why we collect it, how long we keep it and what rights you have. In short: we collect very little, we use it only to run the website and answer you, and we never sell it.
1. Who is responsible for your data
The controller (operator) of your personal data is [Legal entity name], registration number [OGRN / OGRNIP / company number], tax ID [INN / VAT number], registered at [Registered address] (“Empetrum”, “we”, “us”).
For anything related to privacy, write to hello@empetrum.dev [or a dedicated address such as privacy@empetrum.dev]. The person responsible for organising personal data processing is [Name / role of the responsible person].
2. What this policy covers
This policy applies to visitors of the website and to people who contact us about a possible project. It does not cover personal data we process on behalf of our clients while building or supporting their products. That processing follows the client’s instructions and is governed by our agreement with the client, including a data processing agreement where one is required.
3. What we collect and why
| Data | Purpose | Legal basis | Kept for |
|---|---|---|---|
| Your messages. Name, email address, company, the content of your message and any files you attach, when you write to us. | To reply, discuss your project and prepare a proposal. | Steps taken at your request before entering into a contract; our legitimate interest in answering enquiries; your consent where the law requires it. | Up to 12 months after our last exchange if no project follows. If we work together, see “Client correspondence”. |
| Client correspondence. Contact details and communications of client representatives. | To perform the contract, invoice and keep business records. | Performance of a contract; legal obligations (accounting and tax). | For the duration of the contract and then as long as accounting, tax and limitation periods require, typically [5 years]. |
| Technical logs. IP address, browser and device type, date and time of the request, requested page and referring page, recorded automatically by our web server. | To deliver the website, keep it secure, and detect and investigate abuse. | Our legitimate interest in operating a secure website. | [14] days, unless needed longer to investigate a specific incident. |
We do not ask for, and ask you not to send, special categories of data such as health information, political or religious views, or biometric data.
Cookies and analytics
The website currently sets no cookies and uses no analytics, advertising or tracking tools. If we add any in future, we will update this policy first and, where the law requires it, ask for your consent through a banner before any non-essential cookie is set.
Fonts
[Choose one and delete the other.] Option A: The website’s fonts are hosted on our own server, so loading them sends no data to third parties. Option B: The website loads fonts from Google Fonts. When your browser requests them, Google receives your IP address and browser information. Google’s privacy policy is available at policies.google.com/privacy.
4. What we don’t do
- We do not sell or rent your personal data.
- We do not use your data for advertising or share it with advertisers.
- We do not add you to a mailing list without your separate, explicit consent.
- We do not make decisions about you based solely on automated processing.
5. Who we share data with
We share personal data only where necessary and only with:
- Service providers who process data on our behalf under contract and confidentiality obligations: hosting, [Hosting provider, country]; email, [Email provider, country]; [other tools, e.g. task tracker, accounting service].
- Professional advisers such as accountants and lawyers, where needed for our business.
- Authorities, where we are legally required to disclose data, or to establish, exercise or defend legal claims.
- A successor, if our business is reorganised or transferred, subject to the same protections as this policy.
6. Where your data is stored
[Data localisation: if Empetrum is a Russian operator, state that the recording, systematisation, accumulation, storage, clarification and retrieval of personal data of Russian citizens is carried out using databases located in the Russian Federation, and name where.]
Some of our service providers may be located outside your country. Where we transfer personal data internationally, we do so only as permitted by applicable law, for example to countries recognised as providing adequate protection, or with appropriate safeguards such as standard contractual clauses, or with your consent where required.
7. How we protect it
We use appropriate technical and organisational measures to protect personal data, including encrypted connections (HTTPS), access limited to people who need it, strong authentication on our accounts, and regular updates of the software we use. No method of transmission or storage is completely secure, but if a breach affecting your data occurs we will notify you and the competent authority where the law requires it.
8. Your rights
Depending on where you live, you have some or all of the following rights:
- to know whether we process your data and to receive a copy of it;
- to have inaccurate data corrected or incomplete data completed;
- to have your data deleted, or its processing restricted;
- to object to processing based on our legitimate interests;
- to receive data you gave us in a portable format;
- to withdraw consent at any time, without affecting processing that took place before;
- to complain to a data protection authority: [e.g. Roskomnadzor (rkn.gov.ru) in Russia, or your local authority in the EU/EEA or UK].
To exercise any of these rights, email hello@empetrum.dev. We may ask you to confirm your identity. We will reply within [10 working days] and in any case within the period set by applicable law.
9. Children
The website and our services are intended for businesses and adults. We do not knowingly collect personal data from anyone under 16. If you believe a child has sent us personal data, please contact us and we will delete it.
10. Changes to this policy
We may update this policy when our practices or the law change. The current version is always on this page with its date at the top. If a change materially affects how we use data we already hold, we will tell the people concerned directly where we can.
11. Contact
Questions or requests about your personal data: hello@empetrum.dev, or by post to [Postal address].