1. General provisions
This Personal Data Processing Policy (the Policy) is drawn up to meet the requirements of the personal data legislation applicable to the operator, in particular Federal Law No. 152-FZ «On Personal Data» of 27 July 2006 (152-FZ).
The Policy describes how the operator processes personal data, for which purposes, on which legal grounds, for how long, and how the rights of data subjects are protected.
The site astelit.online has no registration and no accounts. Personal data is provided only through the contact form. The form is connected to the operator's backend: the submitted data is stored in the operator's database, and a notification is sent to the operator through the Telegram Bot API.
2. Definitions
- Personal data: any information relating to an identified or identifiable natural person.
- Data subject: the natural person to whom the personal data relates.
- Processing: any operation performed on personal data, including collection, recording, systematisation, accumulation, storage, clarification, extraction, use, transfer, depersonalisation, blocking, deletion and destruction.
- Operator: the person who organises and/or carries out processing and determines the purposes and composition of the processed data. In this Policy the operator is Samusenko Dmitrii Sergeevich, sole proprietor (Individualny Predprinimatel).
- Cross-border transfer: the transfer of personal data to the territory of a foreign state.
- Confidentiality of personal data: the requirement not to disclose personal data without the consent of the data subject or another lawful ground.
3. Operator identity
- Legal form: individual entrepreneur (ИП), registered in the Russian Federation.
- Full legal name: Samusenko Dmitrii Sergeevich, sole proprietor (Individualny Predprinimatel)
- OGRNIP: 325930100027732
- INN: 614029489987
- Registered address: 20 Rechnaya St., apt. 48, Donetsk, 283005, Donetsk People's Republic, Russia
- Contact e-mail: 0xaletic@astelit.online
- Person responsible for personal data processing: the operator himself.
4. Principles of processing
- Processing is carried out lawfully and fairly and only on the legal grounds established by law.
- Processing is limited to achieving specific, predetermined and lawful purposes; processing incompatible with those purposes is not allowed.
- The composition and volume of the processed data correspond to the stated purposes (data minimisation).
- Data is kept accurate and up to date; inaccurate data is corrected or deleted.
- Data is stored no longer than required by the purposes of processing or by law.
- Confidentiality and security of personal data are ensured.
5. Legal grounds
- Consent of the data subject, given through the checkbox in the contact form and the Consent to Personal Data Processing.
- Consent to the processing of analytical data, given through the cookie banner (Yandex.Metrika, Google Analytics 4).
- Performance of a contract or steps taken before a contract at the request of the data subject.
- Compliance with legal obligations of the operator.
- Legitimate interests of the operator, to the extent permitted by law.
6. Purposes of processing and scope
For each purpose the operator determines the categories and list of processed data, the categories of data subjects, the processing methods, the retention period and the procedure for destroying the data once the purpose is achieved or another lawful ground arises.
Purpose: handling enquiries sent through the contact form. Data: name, e-mail address, message text. Data subjects: visitors who fill in the form. Methods: collection, recording, storage, use, deletion. Retention: until the purpose is achieved or consent is withdrawn, but not longer than 12 months from the last interaction. Destruction: by the person responsible for processing.
Purpose: taking steps before a possible contract and keeping a record of business correspondence. Data: name, e-mail address, message text. Retention: until the purpose is achieved or consent is withdrawn. Destruction: by the person responsible for processing.
Purpose: protecting the form from spam and abuse. Data: IP address, User-Agent string, interface language, time of the request and the hidden anti-spam field. Retention: not longer than 12 months. Destruction: together with the request.
Purpose: notifying the operator about a new request. Data: name, e-mail address, message text and interface language. Transfer: through the Telegram Bot API to the operator's Telegram chat. Retention: the notification is deleted from the operator's chat within the retention period, subject to Telegram's own terms.
Purpose: compliance with legal and accounting obligations. Data: the minimum required by law. Retention: for the period prescribed by law.
Purpose: web analytics and site improvement. Data: cookie identifier, shortened IP address, device and browser data, pages viewed and interaction events. Processors: Yandex (Yandex.Metrika), Google (Google Analytics 4). Legal basis: consent given through the cookie banner. Retention: the period set in the analytics service settings (Yandex.Metrika — up to 13 months by default; Google Analytics 4 — 14 months by default), after which the data is deleted or anonymised.
No processing is carried out for advertising, retargeting, profiling, telephone, SMS or push-notification purposes. Informational mailing is a separate, optional consent.
7. Categories of personal data
The data entered in the contact form is processed: name, e-mail address and message text, together with the technical data of the request (IP address, User-Agent string, interface language and time of the request). Special categories of personal data and biometric data are not requested and are not deliberately collected.
The form does not request a telephone number. The backend interface can technically accept a Telegram username as an alternative contact channel; if one is provided, it is processed on the same terms as the e-mail address. The operator does not process the personal data of persons under 18; such persons must obtain the permission of their legal representatives before providing data, and data received in breach of this rule is deleted promptly.
8. Categories of data subjects
Personal data is processed in respect of visitors of astelit.online who voluntarily fill in the contact form and give consent. There are no registered users, because registration does not exist on this site.
9. Processing methods
Personal data may be collected, recorded, systematised, accumulated, stored, clarified (updated, changed), extracted, used, transferred (provided, made accessible) where required by law, depersonalised, blocked, deleted and destroyed, using automated and non-automated means, including mixed processing. Processing is limited to the purposes listed above.
10. Retention and destruction
Contact messages are stored in the operator's database for 12 months from the last interaction, after which they are deleted or anonymised unless a longer period is required by law. The Telegram notification is deleted from the operator's chat within the same period, subject to Telegram's own retention terms.
When the purpose of processing is achieved or another lawful ground arises, the person responsible for personal data processing destroys the data in accordance with the operator's internal procedure.
11. Cross-border transfer
The operator is registered in the Russian Federation and this site's data is processed on servers located in the Republic of Belarus, so the data is stored outside the operator's country. This is a cross-border transfer of personal data from the Russian Federation to Belarus.
The notification sent through the Telegram Bot API is also transferred outside the Russian Federation. The legal basis for this transfer is the consent of the data subject, given by submitting the contact form and described in the Consent to Personal Data Processing.
With your separate consent, Google Analytics 4 may transfer analytical data outside the Russian Federation, including to the United States and the European Union. Yandex.Metrika data is stored on servers located in the Russian Federation and is not part of that transfer.
The site targets the Russian Federation and does not target residents of the European Union; no representative in the European Union is appointed. This Policy is governed by the law of the Russian Federation.
12. Rights of the data subject
The data subject has the right to:
- Access the personal data held about them and receive reliable information about its processing.
- Request rectification of inaccurate or incomplete data.
- Request blocking or erasure of data.
- Request restriction of processing.
- Object to processing.
- Withdraw consent at any time.
- Lodge a complaint with a competent supervisory authority.
- Requests and complaints are considered within a period not exceeding 10 (ten) working days from the date they are received by the operator. Requests are sent to 0xaletic@astelit.online.
13. Withdrawal of consent
Consent may be withdrawn at any time by sending a written notice to 0xaletic@astelit.online. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal; after withdrawal the operator stops processing the data and destroys it, unless retention is required by law.
14. Security measures
Requests are stored in the operator's database, and access to them is limited to the operator and the persons involved in handling them. The operator applies the principles of data minimisation and restricted access, protects access to the database and the notification channel with credentials, and keeps an internal record of processing.
The operator takes the measures required by 152-FZ to protect personal data from unlawful or accidental destruction, loss, alteration, disclosure or access, including restricting access to data to those who need it for the stated purpose, protecting storage media, and keeping an internal record of processing. In the event of an incident involving personal data, the operator notifies the competent supervisory authority within 24 hours and completes an internal investigation within 72 hours, as required by law.
15. Third parties and disclosure
Personal data is not sold or shared with third parties for their own marketing.
With your consent, analytical data is processed by Yandex (Yandex.Metrika) and Google (Google Analytics 4) as independent services acting as data processors; the legal basis, purposes and retention are described in the Cookie Policy.
For the purpose of notifying the operator about a new request, the request data is transferred to Telegram through the Telegram Bot API, as described in section 11 (Cross-border transfer) and in the Consent to Personal Data Processing.
Data may be transferred to: a successor in the event of reorganisation of the operator; state bodies, courts and law-enforcement agencies where the operator is required to provide information by applicable law; and persons protecting the operator's rights in the event of a breach, where such transfer is lawful. Where required, disclosure is made only in accordance with applicable law.
16. Changes
The operator may amend this Policy. A new version takes effect when it is published, unless the new version provides otherwise. Effective date: 2026-10-08, version 1.3. The current version is 1.3 dated 08.10.2026.
17. Contact
E-mail: 0xaletic@astelit.online. This address is the contact for data-subject requests. Effective date: 2026-10-08, version 1.3.