UPNOVA UPNOVA
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Privacy Policy

Last updated: April 30, 2026

1. General Provisions

This Privacy Policy (hereinafter — the “Policy”) defines the procedure for processing and protecting personal data of users of the upnova.ru website, owned by the UPNOVA game design studio (Eduard Sergeevich Tumantsev, self-employed, Taxpayer ID (INN): 772096218965; hereinafter — the “Operator”).

By using the website, you agree to the terms of this Policy. If you do not agree, please stop using the website.

2. What Data We Collect

  • Contact details — name, email address, Telegram/VK/phone number (when filling out contact forms or placing an order).
  • Payment data — processed exclusively by the YooKassa payment service; the Operator does not store bank card details.
  • Technical data — IP address, browser type, operating system, pages visited (collected automatically).
  • Cookies — see Section 6 for details.

Actions performed on personal data: collection, recording, systematization, accumulation, storage, clarification, use, transfer (provision), depersonalization, blocking, deletion, destruction.

3. Purposes and Legal Grounds for Data Processing

Purpose of Processing Legal Basis (Art. 6, Federal Law No. 152-FZ)
Processing requests, responding to inquiries Part 1, Cl. 5 — performance of an agreement to which the data subject is a party
Provision of design and logo generation services Part 1, Cl. 5 — performance of an agreement
Processing payments via YooKassa Part 1, Cl. 5 — performance of an agreement; Part 1, Cl. 2 — Russian legislation on settlements
Traffic analytics (Yandex.Metrica) Part 1, Cl. 1 — consent of the personal data subject
Image generation via Leonardo.ai Part 1, Cl. 1 — subject’s consent (obtained when using the generator)
Compliance with Russian legislation Part 1, Cl. 2 — exercise of functions assigned by law

4. Disclosure of Data to Third Parties

The Operator does not sell personal data to third parties. Disclosure is possible only in the following cases:

  • YooKassa (LLC “YooMoney”) — payment processing; basis: performance of an agreement (Part 1, Cl. 5, Federal Law No. 152-FZ).
  • Yandex.Metrica (LLC “Yandex”) — analytics in anonymized form; basis: user consent.
  • Leonardo.ai — image generation; see Section 5.
  • At the request of authorized Russian government bodies in accordance with applicable law.

5. Cross-Border Data Transfer

When using the logo generator, technical request parameters (style description, generation settings) are transmitted to the Leonardo.ai service, located in the USA.

The USA is not included in the list of foreign states ensuring adequate protection of personal data subjects’ rights (Order of Roskomnadzor No. 100 dated March 15, 2013). Cross-border transfer is carried out on the basis of the consent of the personal data subject (Art. 12, Part 4, Cl. 1, Federal Law No. 152-FZ), which you give by clicking the “Generate” button.

Personal data in identifiable form (name, email, phone) is not transmitted to Leonardo.ai — only technical request parameters.

6. Cookies

The website uses the following types of cookies:

  • Technical (necessary) — ensure the website’s operation, authorization, and sessions (wordpress_*, wp-settings-*). Basis: Part 1, Cl. 5, Federal Law No. 152-FZ.
  • Analytical — Yandex.Metrica (_ym_*), anonymized statistics. Basis: user consent.
  • Functional — saving settings (e.g., cookie consent). Basis: user consent.

You may decline analytical cookies via the banner. Disabling technical cookies may disrupt the website’s operation.

7. Data Storage and Protection

Personal data is stored on secure servers within the Russian Federation. Retention periods:

  • Contact details from forms — 3 years from the date of the last inquiry.
  • Payment documents — 5 years in accordance with accounting legislation (Federal Law No. 402-FZ).
  • Technical logs — 1 year.
  • Cookies — according to the validity period of each file (from session-based to 2 years).

Upon expiration of the retention period, data is destroyed. The Operator takes organizational and technical measures to protect data from unauthorized access.

8. User Rights

In accordance with Federal Law No. 152-FZ, you have the right to:

  • obtain information about the processing of your personal data;
  • request clarification, blocking, or destruction of data;
  • withdraw consent to the processing of personal data;
  • appeal the Operator’s actions to Roskomnadzor.

9. Contacts

For questions regarding personal data processing: contact form or via the email address listed in the website footer.

10. Changes to the Policy

The Operator reserves the right to make changes. The current version is always available on this page. Continued use of the website constitutes acceptance of the updated Policy.