Personal data processing policy
Effective date: 23 August 2026. Version 1.2
This Policy sets out how personal data of Kanyman Platform users is processed and protected by GR ATTRACTOR Limited Liability Company (the “Controller”).
It is based on Russian Federal Law No. 152-FZ of 27 July 2006 on Personal Data and other applicable Russian personal-data rules.
1. Personal-data controller
- Controller: GR ATTRACTOR Limited Liability Company
- Tax ID: 313127023
- Personal-data email: Gr22attract@gmail.com
2. Categories of personal data
2.1. Data supplied by the user
- full name
- email address
- telephone number
- organisation details, including name, tax and registration numbers, address and bank details
- job title and place of work
- profile photograph, if uploaded
2.2. Data collected automatically
- IP address
- cookies
- browser and device information, including User-Agent
- date and time of access
- actions on the Platform
- city-level location inferred from IP
2.3. Payment data
Card data is processed only by the payment provider. The Controller stores only the last four card digits, payment-system type and expiry date to identify the payment method.
3. Purposes and legal grounds
- registration and identification — performance of the agreement under paragraph 5, part 1, Article 6 of Law 152-FZ
- access to Service features, payment and invoicing, technical support and service notices — performance of the agreement
- quality improvement and analytics — legitimate interest under paragraph 7, part 1, Article 6
- marketing communications — the data subject’s consent under Article 9
- compliance with legal requirements — paragraph 2, part 1, Article 6
4. Processing operations
4.1. Processing may be automated or non-automated and includes collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer, anonymisation, blocking, deletion and destruction.
4.2. The initial collection and recording of personal data of Russian citizens takes place in the Russian Federation under part 5 of Article 18 of Law 152-FZ.
5. Disclosure to third parties
- payment providers — payment processing
- hosting providers — data storage
- analytics services — anonymised service improvement
- public authorities — legal requirements
5.2. Confidentiality
Third parties must keep the data confidential under their agreements with the Controller.
6. Cookies
6.1. The Platform uses:
- necessary cookies for authentication, settings and security
- analytics cookies for usage analysis and UX improvement
- functional cookies for user preferences
6.2. Browser settings
Cookies can be managed in the browser. Disabling necessary cookies may limit functionality.
7. Retention
- account data — period of use plus 30 days
- payment data — five years under the Russian Tax Code
- cookies — up to 12 months
- support requests — three years
- anonymised analytics — up to 24 months
8. Data protection
The Controller uses organisational and technical measures including:
- encryption in transit using TLS/SSL and at rest
- access controls
- regular backups
- access monitoring and logging
- personnel training on personal-data rules
9. Rights of the data subject
- receive information about processing under Article 14 of Law 152-FZ
- request correction, blocking or destruction
- withdraw consent under Article 9
- complain to Roskomnadzor or a court under Article 17
- export data from the Platform
How to exercise these rights
Write to Gr22attract@gmail.com. The response period is 10 business days.
10. Children
The Platform is not intended for anyone under 18. The Controller does not knowingly collect children’s data.
11. Changes to this Policy
11.1. The Controller may amend this Policy; a new version takes effect when published.
11.2. Material changes are announced by email and/or through the Platform interface.
11.3. Continued use means acceptance of the new version.
12. Contact
- GR ATTRACTOR Limited Liability Company
- Tax ID: 313127023
- Address: 254, 1st Lane, Usta Shirin Street, Miskin MFY, Almazar District, Tashkent, Republic of Uzbekistan
- Personal-data enquiries: Gr22attract@gmail.com