1. Terms and scope
This document applies to the prime61.com website, the customer account, the Telegram bot and any enquiries — by email, messenger or phone.
- Personal data — any information relating to a directly or indirectly identified person.
- Processing — any actions with data: collection, recording, storage, rectification, use, transfer, blocking, deletion and destruction.
- Operator — prime61, which determines the purposes and scope of processing.
- Data subject — the person whose data we process: a website visitor, client, partner, student or contractor.
2. Operator
The personal data operator is prime61, website prime61.com. We accept enquiries on any matters of data processing at hello@prime61.com and in the Telegram bot @prime61_bot. We state the operator's full name, tax identification number (INN) and address in the contract and invoice and provide them on request.
3. What data and about whom we process
- Website visitors: IP address, cookies, device and browser type, referral source, pages and time of visit.
- Applicants (clients and partners): name, phone number, messenger username, email, comment on the request, role.
- Active clients: details for the contract and invoice, correspondence, project files, order and payment history.
- Partners: name and contacts, access code word, data on orders, accruals and achievements.
- Students: name and contacts, the chosen programme, completed assignments and training feedback.
We do not process special categories of data: information about health, religion or political views, or biometrics — and we do not request them. If a project requires special data, we will separately explain why it is needed.
4. Purposes of processing
- to contact you about a request and prepare a commercial proposal;
- to conclude, perform and close a contract: work, delivery of stages, documents;
- to provide access to the customer account and support for it;
- to open partner access, accrue bonuses and make settlements;
- to organise training: materials, assignments, calls, feedback;
- to send notifications about project status within the Telegram bot;
- to ensure information security and prevent abuse;
- to keep mandatory records and reporting and respond to lawful requests.
We do not use data for automated decision-making that produces legal consequences, and we do not engage in profiling for advertising.
5. Legal grounds for processing
- the data subject's consent — for requests, notification mailing and registration;
- performance of a contract to which you are a party or intend to become a party;
- legitimate interest — protecting the service from spam, fraud and attacks, and keeping statistics based on anonymised data;
- performance of duties imposed by law — accounting and tax records, responses to requests from public authorities.
6. Procedure and conditions of processing
Processing is carried out by a mixed method: with and without the use of automation tools. Data is stored on servers with restricted access. We process data no longer than necessary for the purposes of processing and destroy or anonymise it once the purpose is achieved, upon withdrawal of consent or upon expiry of the retention period.
Within the team, only those specialists who need it to work on your project are granted access to data.
7. Data transfer and Telegram
We do not sell data or transfer it for advertising. Transfer is possible to hosting, a payment service, participating specialists and — in cases established by law — to public authorities.
Let us say separately about Telegram. If you use the Telegram bot, some data — your identifier, username, name and the content of messages — passes through the service of Telegram Messenger Inc., whose infrastructure is located outside the Russian Federation. This means cross-border transfer. We do not control Telegram's servers, therefore:
- use the bot voluntarily — you can limit yourself to email at hello@prime61.com;
- do not send passport data, card numbers, passwords or other sensitive information in the chat;
- transfer documents for the contract by secure methods that we will offer separately.
For more details, see the Telegram Bot Policy and Telegram's own policy: https://telegram.org/privacy.
8. Processing and retention periods
After the period expires, the data is destroyed or anonymised in such a way that it cannot be restored.
- requests without a concluded contract — up to 1 year;
- data under contracts — the duration of the work and 3 years after, unless another period is established by law;
- data for accounting and tax records — within the periods established by law;
- technical logs and cookies — up to 6 months;
- partner data — the period of the partnership and 1 year after its termination.
9. Protection measures
- traffic encryption (HTTPS) and secure transmission channels;
- a password and, for partners, a code word for access to the account;
- restriction of access for employees and contractors;
- no passwords or code words in logs or correspondence;
- backup and data recovery;
- vulnerability monitoring and updating of the software used.
10. Rights of the personal data subject
Send your enquiry to hello@prime61.com or via the Telegram bot. We respond within up to 30 calendar days from receipt of the enquiry; in our response we explain what we have done or give a reasoned refusal if the request contradicts the law.
- to receive information about processing: what data, for what purpose, to whom it is transferred and how long it is stored;
- to demand rectification, blocking or deletion of data;
- to withdraw consent to processing;
- to object to processing and demand that it be stopped;
- to receive your data in a structured form;
- to appeal the operator's actions to Roskomnadzor or in court.
11. Withdrawal of consent
Consent may be withdrawn at any time: write to hello@prime61.com or via the Telegram bot with the phrase “I withdraw consent to the processing of personal data” and state the contact you used. We will stop processing and delete the data, except for that which we are obliged to retain by law or for the performance of an existing contract, and we will inform you what data remained and why.
12. Changes to the Policy
The Policy may be updated. The new version is published on this page; the update date is shown at the top. By continuing to use the website and services after publication, you confirm that you have read the new version.