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Privacy Policy
for users of the SeldorGate software

Русская версия

1. General provisions

  1. This Privacy Policy (the “Policy”) defines how personal data collected and processed by Aleksandr Nikolaevich Kubintsev (INN 504706888452), a self-employed taxpayer under the Russian professional tax regime (the “Operator”), is processed and protected in connection with the use of the SeldorGate software (the “Software”) and the website https://seldor.ru (the “Site”).
  2. The Policy is prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”) and other applicable laws of the Russian Federation.
  3. The Policy applies to all personal data that the Operator receives from users of the Software (“Users”) or that is generated in the course of their interaction with the Software and the Site.
  4. Using the Software and the Site means unconditional consent to this Policy. If you do not agree with the Policy, you must stop using the Software and the Site.
  5. The key terms used in the Policy follow the definitions in Article 3 of the Personal Data Law:
    • Personal data — any information relating to an identified or identifiable natural person (the data subject);
    • Operator — a natural person who independently or jointly with others organises and/or carries out the processing of personal data;
    • Processing of personal data — any action or set of actions performed with personal data: collection, recording, systematisation, accumulation, storage, clarification, extraction, use, disclosure, anonymisation, blocking, deletion, destruction.

2. Purposes of personal data processing

  1. The Operator processes Users’ personal data exclusively for the following purposes:
    # Purpose of processing Data categories
    1 Binding a licence to a specific device and monitoring compliance with the licence agreement Device ID
    2 Providing and controlling the trial period Device ID
    3 Payment processing, receipt issuance, performance of the licence agreement Email, payment identifier, purchase data
    4 Delivery of the licence key Email, Device ID
    5 Responding to Users’ inquiries and requests Email, content of the inquiry
    6 Compliance with legal requirements (including tax legislation) Payment data
  2. The Operator does not process personal data for any purposes not listed in this section. The Operator does not send marketing communications and does not sell or disclose personal data to third parties for commercial purposes.

3. Legal bases for processing

  1. The legal bases for processing personal data are:
    • Consent of the data subject — the User gives consent by accepting the licence offer (paying for a licence) and/or by installing and activating the Software (for the trial period), pursuant to Art. 6(1)(1) of the Personal Data Law;
    • Performance of a contract — processing of data necessary to perform the licence agreement concluded with the User, pursuant to Art. 6(1)(2) of the Personal Data Law;
    • Compliance with legal requirements — processing of data necessary to fulfil the Operator’s obligations as a professional tax payer (receipt issuance, record-keeping), pursuant to Art. 6(1)(2) of the Personal Data Law.

4. Scope and categories of data processed, categories of data subjects

  1. Categories of data subjects:
    • Users of the Software — natural persons using the Software on devices they lawfully own.
  2. Categories and list of personal data processed:

    4.2.1. Device identifier (Device ID)

    • A unique hardware identifier of the device on which the Software is installed (generated by the device operating system);
    • Transmitted automatically by the Software upon licence activation or trial start;
    • Used to bind the licence to the device, control the trial period, and prevent unauthorised use of the licence.

    4.2.2. Email address (Email)

    • Provided by the User when paying for a licence through the YooKassa payment service (passed by YooKassa as part of the payment data);
    • Used to deliver the licence key, issue and send the receipt, and to respond to the User’s inquiries.

    4.2.3. Payment data

    • Payment identifier assigned by the YooKassa payment service;
    • Amount and date of the payment;
    • Type of licence purchased (annual / lifetime / trial period);
    • Used for accounting of licence payments and fulfilment of tax obligations.
  3. The Operator does not process the following categories of data:
    • Full name, passport data, registered address;
    • Special categories of personal data (health, nationality, religion, political views);
    • Biometric personal data;
    • Payment card details (card numbers, accounts) — these are processed exclusively by the YooKassa payment service and are not disclosed to the Operator.
  4. The Operator does not collect any personal data not listed in this section. If the Operator becomes aware of other personal data of the User (for example, from email correspondence), such data is processed solely to respond to the inquiry and is deleted after the inquiry is resolved.

5. Procedure and conditions of processing

  1. Method of processing: automated processing using computer systems (the Operator’s server, the licence database).
  2. Data collection:
    • The Device ID is collected automatically by the Software at first installation and activation on the device;
    • Email and payment data are received from the YooKassa payment service after the payment is completed.
  3. Data storage:
    • Personal data is stored on a server located in the Russian Federation;
    • Retention periods:
      Data category Retention period Basis
      Device ID (active licence) Term of the licence + 90 days Contract performance, compliance monitoring
      Device ID (trial period) 90 days from the end of the trial period Prevention of trial reuse
      Email Term of the licence + 1 year Contract performance, responding to inquiries
      Payment data 6 years from the payment Tax legislation (Law 54-FZ, Art. 4.7)
  4. Disclosure of data to third parties:
    • The Operator discloses the User’s personal data to the YooKassa payment service to the extent necessary for payment processing and receipt issuance, under YooKassa’s terms and in accordance with applicable law;
    • The Operator does not disclose personal data to any other third parties, except where directly required by the law of the Russian Federation (for example, upon a request by an authorised government body);
    • The Operator does not carry out cross-border transfer of personal data.
  5. Operations performed with personal data: collection, recording, systematisation, accumulation, storage, clarification, use, blocking, deletion, destruction.

6. Updating, modifying, deleting and destroying data

  1. The Operator keeps personal data accurate and up to date during the processing period.
  2. Personal data shall be destroyed in the following cases:
    • The purposes of processing have been achieved;
    • The retention period specified in section 5.3 has expired;
    • The User withdraws consent (as provided in section 7);
    • The Operator ceases the activity related to processing personal data.
  3. Destruction is carried out by irreversibly removing the data from the Operator’s database within 30 (thirty) calendar days from the occurrence of the ground for destruction.
  4. If consent to processing of the Device ID is withdrawn, the Operator must remove the device-to-licence binding, which will terminate the licence. The User is informed of this consequence when withdrawing consent.

7. Rights of the data subject

  1. The User has the right to:
    • Request information about their personal data processed by the Operator;
    • Request correction, blocking, or destruction of their personal data if it is inaccurate or processed unlawfully;
    • Withdraw consent to the processing of personal data;
    • File a complaint about the Operator’s actions with the supervisory authority (Roskomnadzor).
  2. Consent is withdrawn by sending a written request to the Operator’s email: biz@seldor.ru. The request must include:
    • The email address used for the payment;
    • The device’s Device ID (available in the “About” section of the Software);
    • The request to withdraw consent and delete personal data.
  3. The Operator reviews the User’s request within 30 (thirty) calendar days of receiving it and sends the response to the email address specified by the User.
  4. Withdrawal of consent to processing of the Device ID terminates the licence, because the device-to-licence binding is technically impossible without processing the Device ID.

8. Security measures

  1. The Operator takes the necessary organisational and technical measures to protect personal data from unlawful access, copying, modification, destruction, and other unlawful actions, in accordance with Article 19 of the Personal Data Law.
  2. Measures applied:
    • The licence database is stored on a server with restricted, password-protected access;
    • HTTPS/TLS encryption is used for data transfer between the Software and the Operator’s server;
    • The Device ID is transmitted as a hash value where technically feasible;
    • Access to the database is restricted — only the Operator has access;
    • Regular backup of the data.
  3. The Operator is not liable for a possible data breach caused by third parties (including the YooKassa payment service) or by force majeure circumstances.

9. Cookies, analytics and local data

  1. The Software does not use cookies for tracking. Data exchange with external servers happens only with the VPN gateway chosen by the User and, when the built-in browser is used for SSO, with the identity provider configured on that gateway.
  2. The Software does not send analytics data, telemetry, or any information about the User’s behaviour to third-party services.
  3. Connection profiles (VPN gateway address, credentials, session cookies) are stored only on the User’s device and are never transmitted to the Operator or to third parties. VPN tunnel traffic is encrypted and is inaccessible to the Operator.
  4. The Site may use technical cookies required for the payment form to work correctly (for example, YooKassa session cookies). The Operator does not collect or process analytics cookies.

10. Final provisions

  1. The Operator may amend this Policy. The current version is published on the Site with the last-updated date. Amendments take effect upon publication on the Site.
  2. The new version applies to personal data processed after its publication. For personal data processed on the basis of previously given consent, the version in force at the time consent was given applies.
  3. All matters not regulated by this Policy are resolved in accordance with the applicable laws of the Russian Federation.
  4. Last updated: September 16, 2026

11. Operator details

Full name: Aleksandr Nikolaevich Kubintsev
INN: 504706888452
Status: self-employed (professional tax payer)
Email: biz@seldor.ru
Website: https://seldor.ru