Privacy Policy

Personal Data Processing Policy

Version: 1.0

Effective date: July 12, 2026

1. General provisions

This Privacy Policy explains how personal data may be processed and protected when a visitor uses olegzemtsov.com, including its Russian and English versions.

The website owner and data controller is:

Oleg Zemtsov, an individual entrepreneur registered in Georgia.

Contact for personal data enquiries:

Email: oleg9175495330@gmail.com

Website: olegzemtsov.com

This Policy applies to information that may be processed:

• when a visitor accesses the website;
• when website preferences are stored;
• when the visitor gives consent to analytics;
• when the visitor contacts the Controller by email or through a third-party communication service linked from the website.

Visitors may access and read this Policy without registering or providing their contact details.

2. Data processing principles

The Controller processes personal data lawfully and fairly and seeks to comply with the following principles:

• data is processed only for specified purposes;
• only data necessary for the relevant purpose is collected;
• data is not stored longer than necessary;
• data should be accurate and kept up to date where required;
• data should be protected against unauthorised access, alteration, disclosure or destruction;
• visitors should be informed about the processing of their data;
• consent may be withdrawn where processing is based on consent.

3. Data that may be processed

3.1. Technical data

When a visitor opens a website page, the web server and hosting provider may automatically process technical information required to deliver the website and maintain its security.

This information may include:

• IP address;
• date and time of the request;
• requested page address;
• referring page address;
• browser type and version;
• device type;
• operating system;
• browser language;
• server response code;
• information about technical errors.

This information may be included in web server and hosting logs.

3.2. Local website preferences

The website may store the following information in the visitor’s browser:

• the selected light or dark theme;
• the visitor’s analytics decision;
• the date of the decision;
• the version of the consent mechanism.

The website may use localStorage or another similar browser storage technology for this purpose.

3.3. Analytics data

After the visitor gives consent, the website may enable:

• Google Analytics 4;
• Yandex Metrica;
• Microsoft Clarity.

These services may process information including:

• pages visited;
• duration and sequence of page views;
• traffic source;
• browser and device information;
• approximate geographical location;
• clicks, scrolling and link navigation;
• technical events and errors;
• pseudonymous browser, visitor or session identifiers;
• interactions with website elements;
• heatmaps and session recordings.

Google states that the default implementation of Google Analytics collects user and session statistics, approximate location, and browser and device information. Microsoft recommends disclosing the use of Clarity, heatmaps and session replay in the website privacy policy. ([Поддержка Google][2])

If Webvisor is enabled in Yandex Metrica, it may record visitor interaction with website pages. The Controller must not intentionally transmit names, telephone numbers, email addresses, identity document details, payment information or other directly identifying information to Yandex Metrica. ([Яндекс][3])

Further information about cookies and similar technologies is provided in the Cookie and Similar Technologies Policy.

3.4. Information provided when contacting the Controller

If a visitor contacts the Controller by email, Telegram, VK or another listed communication channel, the following information may be processed:

• name or nickname;
• email address;
• social network or messenger profile name and identifier;
• telephone number, if voluntarily provided;
• message content;
• information about the requested service;
• attached documents and files;
• other information voluntarily provided by the visitor.

Visitors should not send special-category personal data or confidential information unless it is necessary for their enquiry.

4. Information not requested through the website

The current version of the website does not provide:

• user registration;
• user accounts;
• contact forms;
• website-based ordering;
• online payments;
• user content uploads;
• automated contract execution.

The website does not intentionally request passport information, payment details, medical information, biometric data, political opinions, religious beliefs or other special categories of personal data.

5. Purposes of processing

5.1. Website operation and security

Technical information may be processed to:

• load and display website pages;
• maintain website security;
• identify technical errors;
• prevent abuse and malicious requests;
• diagnose server and hosting problems.

The legal basis may include the technical necessity of providing the website, compliance with legal obligations and the Controller’s legitimate interest in protecting the website.

5.2. Saving website preferences

Information about the selected theme and analytics decision is processed to remember preferences directly selected by the visitor.

5.3. Website analytics and improvement

After consent has been obtained, analytics data may be processed to:

• measure website traffic;
• identify popular pages;
• analyse traffic sources;
• identify navigation and display problems;
• improve website content, structure and usability;
• evaluate the effectiveness of published information.

The legal basis for this processing is the visitor’s consent.

5.4. Responding to enquiries

Information provided by a visitor may be processed to:

• answer questions;
• discuss software development services;
• discuss Python or SQL lessons;
• make a preliminary project assessment;
• prepare a proposal;
• enter into or perform a contract;
• continue business communication.

The legal basis may include the visitor’s request, steps taken at the visitor’s request before entering into a contract, performance of a contract, consent, or the Controller’s legitimate interest in maintaining business correspondence.

5.5. Compliance and legal claims

Data may be processed to:

• comply with legal, tax or accounting obligations;
• handle complaints;
• protect legal rights and interests;
• respond to lawful government requests;
• establish, exercise or defend legal claims.

6. Consent to analytics

On the first visit, the website offers two options:

• “Allow analytics”;
• “Necessary only”.

When the visitor selects “Allow analytics”, the visitor consents to the simultaneous activation of:

• Google Analytics 4;
• Yandex Metrica;
• Microsoft Clarity.

When the visitor selects “Necessary only”, the listed analytics services must not be loaded.

Continuing to browse the website, scrolling a page or following an internal link does not by itself constitute consent.

The visitor may change the decision at any time through the “Cookie settings” link in the website footer.

Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

7. Advertising and profiling

The website does not use:

• Google Signals;
• Google Ads;
• advertising remarketing;
• advertising pixels;
• personalised advertising;
• automated decision-making producing legal or similarly significant effects.

The Controller does not sell analytics information or use it to create an individual advertising profile of a visitor.

If the purposes of the analytics services materially change, this Policy and the consent mechanism must be updated.

8. Recipients and service providers

Depending on the visitor’s actions, data may be processed by the following categories of recipients.

8.1. Hosting provider

The hosting provider makes the website available online and may process technical requests and server logs.

8.2. Analytics providers

After consent is given, data may be transmitted to:

• Google;
• Yandex;
• Microsoft.

These providers process data in accordance with their own service terms, configurations and privacy policies.

8.3. Communication services

When a visitor opens Telegram, VK, an email service or another external communication service, that service processes data under its own privacy policy.

8.4. Public authorities and other recipients

Data may be disclosed to:

• public authorities in response to a lawful and binding request;
• courts or law enforcement authorities;
• professional advisers where necessary to protect the Controller’s rights;
• contractors involved in performing a contract where the disclosure is necessary and lawful.

The Controller does not sell personal data or disclose it to third parties for their independent advertising purposes.

9. International data transfers

The Controller is located in Georgia, the website is available internationally, and analytics and technical service providers may use infrastructure located in different countries.

As a result, information may be processed outside the visitor’s country of residence.

Depending on the applicable law, an international transfer may be based on:

• the visitor’s consent;
• the need to perform a contract or take steps at the visitor’s request;
• the service provider’s contractual mechanisms;
• an adequacy decision;
• standard contractual clauses;
• another transfer mechanism permitted by applicable law.

Visitors should also review the relevant provider’s privacy notice for information about its international transfer mechanisms.

Under the GDPR, information about intended third-country transfers, recipients, retention and applicable safeguards forms part of the transparency information provided to the data subject. ([EUR-Lex][4])

10. Retention periods

Personal data is not retained longer than necessary for the relevant purpose.

10.1. Analytics preference

The visitor’s analytics decision may be stored in the browser for up to 12 months or until the visitor changes the decision or removes the browser data.

10.2. Theme preference

The selected theme may be retained until the preference is changed or the browser data is removed.

10.3. Technical logs

Server and hosting logs are retained for the period necessary for:

• security;
• error diagnosis;
• abuse prevention;
• compliance with legal requirements.

The exact period may depend on the hosting provider’s configuration and rules.

10.4. Analytics data

The retention period for analytics data depends on:

• the relevant analytics property settings;
• the settings selected by the Controller;
• the rules of Google, Yandex and Microsoft;
• applicable law.

Approximate retention periods for individual cookies are described in the Cookie and Similar Technologies Policy.

10.5. Correspondence and contractual relationships

Correspondence is retained for as long as necessary to handle the enquiry, perform a contract and protect the legitimate interests of the parties.

When the relevant purpose has been achieved, information is erased, anonymised or retained only where required by law or necessary for the defence of legal claims.

11. Data security

The Controller takes reasonable legal, organisational and technical measures to protect data, including:

• HTTPS encryption;
• restricted access to accounts;
• passwords and authentication mechanisms;
• software updates;
• data minimisation;
• limiting the number of third-party services;
• preventing analytics from loading before consent;
• backups and access controls where appropriate.

However, no method of transmitting or storing information on the internet can guarantee absolute security.

12. Visitor rights

Depending on the applicable law, a visitor may have the right to:

• receive information about the processing of personal data;
• request access to personal data and obtain a copy;
• request correction of inaccurate or incomplete data;
• request termination of processing;
• request erasure or destruction of data;
• request restriction or blocking of processing;
• object to processing;
• withdraw consent;
• receive visitor-provided data in a machine-readable format where the right to portability applies;
• lodge a complaint with a competent supervisory authority;
• seek a judicial remedy.

The GDPR provides rights relating to access, rectification, erasure, restriction, objection, portability and withdrawal of consent. Georgian law also provides rights relating to access, correction, termination of processing, erasure, blocking, portability and withdrawal of consent. ([EUR-Lex][4])

Requests may be sent to:

oleg9175495330@gmail.com

The request should include:

• the nature of the request;
• information enabling the relevant data to be located;
• the preferred method of receiving a response.

Where there are reasonable doubts about the identity of the requester, the Controller may request additional information necessary to confirm the requester’s identity.

Data subject rights may be restricted where permitted by law, including where processing is necessary to perform a contract, comply with a legal obligation or defend a legal claim.

A visitor may also contact:

• the competent Georgian personal data supervisory authority;
• Roskomnadzor where Russian data protection law applies;
• the competent EEA supervisory authority where the GDPR applies;
• a competent court.

13. Children’s data

The website does not determine the age of visitors and is not designed to intentionally collect children’s personal data.

The website includes information about individual lessons. Where a minor contacts the Controller concerning lessons, the Controller may request the involvement of a parent or legal guardian where required by law or appropriate considering the visitor’s age.

A parent or legal guardian may contact the Controller to request the deletion of a minor’s personal data.

14. Third-party links

The website may contain links to:

• Telegram;
• VK;
• GitHub;
• social networks;
• websites of completed projects;
• other external resources.

After a visitor follows an external link, data processing is governed by the privacy policy of the relevant third party.

The Controller does not control the content, security or data processing practices of third-party websites.

15. Changes to processing purposes

If the Controller intends to process personal data for a new purpose that is materially different from the original purpose, additional information will be provided to the visitor.

Where consent is required for the new purpose, processing will not begin until new consent has been obtained.

16. Changes to this Policy

This Policy may be updated following changes to:

• applicable law;
• website functionality;
• analytics services;
• processing methods;
• processing purposes;
• technical service providers.

The current version will always be published on this page.

Where a change is material, the website may request analytics consent again.

17. Contact details

Questions concerning personal data processing may be sent to:

Controller: Oleg Zemtsov, individual entrepreneur

Country of registration: Georgia

Website: olegzemtsov.com

Email: oleg9175495330@gmail.com