Privacy Policy: How We Collect and Protect Data

1. General provisions

This Privacy Policy describes how prime61 (hereinafter — “we”, the “Operator”) handles information it receives through the prime61.com website, the customer account and the Telegram bot. This Policy applies together with the Personal Data Processing Policy and the Telegram Bot Policy.

We collect the minimum amount of data: only what is necessary to respond to a request, perform the work and ensure the security of the service. We do not buy contact databases, do not sell data and do not use it for intrusive advertising.

2. What data we receive

Data can be divided into three groups.

Data from forms: name, phone number or messenger username, comment text and, for registration, email, role (client or partner) and, for a partner, a code word.
Project data: correspondence, files, layouts, estimates and documents that you provide in the course of work or upload to the account.
Technical data: IP address, device and browser type, language, time of access, the address of the page from which the form was submitted, and server logs.

We never write passwords or code words to logs and never forward them in clear text — we record only the fact of logging in.

3. Why we use data

to respond to a request and a question and to agree on the task, timeline and price;
to conclude and perform a contract: manage the project, statuses, files and documents;
to support the operation of the customer account: login, access, order history;
to grant partner access and calculate bonuses;
to ensure security: protection against spam, password guessing and attacks;
to improve the website and services — based on anonymised visit statistics;
to comply with legal requirements: accounting and tax records, responses to requests from public authorities.

4. Legal grounds

We process data on the basis of your consent (for example, when you submit a form or subscribe to the bot), for the conclusion and performance of a contract, and also on the basis of legitimate interest — when we protect the service from abuse and keep mandatory records.

Consent is given freely and voluntarily. You may withdraw it — the procedure is described in section 8.

5. Cookies and technical data

The website uses only essential technical cookies: they are needed for forms, account login and protection against repeated submission to work. We do not place advertising pixels and do not connect third-party trackers that would follow you on other websites.

Cookies can be disabled in your browser settings. Forms and sections of the website will still open, but logging into the customer account may not work: without a technical cookie the server cannot maintain the session.

If we ever connect analytics, we will first update this document and describe what data is collected and why — we will not silently enable counters.

6. To whom data is transferred

We do not sell data or transfer it for advertising. Transfer is possible only to the extent necessary for operation and only to those who help ensure it:

hosting and server infrastructure where the website and the request database are located;
Telegram — if you write to the bot yourself or receive notifications (see the Telegram Bot Policy);
contractors and specialists involved in the project — to the extent needed to perform the work;
a bank or payment service — when paying and issuing an invoice;
public authorities — upon a reasoned request in cases established by law.

All contractors work under a contract and are obliged to maintain confidentiality.

7. How long we store data

When the period expires or you withdraw consent, the data is deleted or anonymised unless the law requires it to be retained.

requests and correspondence on them — up to 1 year from the date of the last contact;
data of ongoing projects and clients — for the duration of the work and 3 years after its completion;
documents for accounting and tax records — within the periods established by law;
technical server logs — up to 6 months;
partner access data — while the partnership is in effect and for 1 year after its termination.

8. How we protect data

No method of transmitting data over the internet provides an absolute guarantee. If an incident affecting your data occurs, we will notify you and the supervisory authority within the periods established by law.

the website operates only over HTTPS, traffic is encrypted;
access to requests and the account — by login, password and, for partners, a code word;
access within the team — on the principle of least privilege;
server logs do not contain passwords or code words;
we regularly update dependencies and monitor for vulnerabilities;
we make backups to restore data after a failure.

9. Your rights

A request can be sent to hello@prime61.com or via the Telegram bot. In your request, state exactly what needs to be done and provide a contact for the response. We respond within up to 30 calendar days, usually within one business day.

to receive information about what data of yours we process and why;
to demand that data be rectified, blocked or deleted if it is incomplete, outdated, inaccurate or unlawfully obtained;
to withdraw consent to processing at any time;
to object to processing if you consider it excessive;
to receive a copy of your data in a convenient form;
to appeal our actions to Roskomnadzor or in court.

10. Data of minors

The website and services are intended for users aged 18 and over. We do not knowingly collect data of children. If a minor wishes to take part in training, the request is submitted by a parent or legal representative, who gives consent on their own behalf. If such data reaches us by accident, let us know — we will delete it.

11. Changes to the Policy

We may update the Policy: for example, when the set of services or the requirements of law change. The new version takes effect from the moment it is published on this page; the update date is always shown at the top. If the changes are significant, we will give notice in the Telegram bot.

12. Contacts

Questions, requests and complaints regarding data processing: hello@prime61.com or the Telegram bot @prime61_bot. There you can also ask to delete data or withdraw consent.

Privacy Policy