Working draft. This document is provided as a starting template. Review with qualified counsel before relying on it for compliance with GDPR, 152-FZ, ePrivacy, or any other regulation applicable to your jurisdiction.
This Privacy Policy explains how iViTech LLC ("we", "us", "Craft Wall") collects, uses, and protects your personal data when you visit craftwall.pro.
1. Who we are
iViTech LLC, registered in the Russian Federation, with office at Russian Federation, 420500, Innopolis, Universitetskaya St. 5, "N. I. Lobachevsky Technopark". For privacy enquiries: support@craftwall.pro.
2. Data we collect
When you submit the FAQ form we collect:
- Your email address (only if you provide one)
- The question text
- Your IP address and browser user-agent (for spam prevention and rate limiting)
- Submission timestamp
When you visit any page our analytics providers collect:
- Page URL, referrer, timestamp
- Approximate location (country / city derived from IP)
- Browser, OS, device type
- Behavioural events: clicks, scroll depth, page interactions, Web Vitals (LCP, CLS, INP)
- Anonymised session recordings (Yandex.Metrika Webvisor, Microsoft Clarity)
Cookies are used by analytics providers to distinguish return visitors. We do not set advertising or cross-site tracking cookies.
3. Why we collect it (legal basis)
- FAQ submissions — to reply to your enquiry. Legal basis: GDPR Art. 6(1) (a) consent; 152-FZ Art. 9 consent.
- IP address (rate limit) — to prevent abuse. Legal basis: GDPR Art. 6 (1)(f) legitimate interest.
- Analytics — to improve the site and measure traffic. Legal basis: GDPR Art. 6(1)(f) legitimate interest; 152-FZ Art. 6(1)(7) legitimate interest of operator.
4. Third parties
- Google Analytics 4 (Google LLC, USA) — web analytics. Standard Contractual Clauses for EU transfer.
- Yandex.Metrika (Yandex LLC, RF) — web analytics + Webvisor recordings.
- Microsoft Clarity (Microsoft Corp., USA) — heatmaps + session recordings. SCCs for EU transfer.
- Brevo (Sendinblue SAS, France, EU) — outbound email delivery.
- Telegram — optional FAQ submission notifications (encrypted).
5. International data transfers
Data may be transferred outside the EU/EEA to the United States (Google, Microsoft) under the European Commission's Standard Contractual Clauses. For Russian users, transfers outside the Russian Federation occur per your consent (152-FZ Art. 12).
6. Retention
- FAQ submissions — 24 months
- Analytics events — 14 months (GA4 setting)
- Session recordings — 30–90 days per provider
- Server logs — 90 days
7. Your rights
Under GDPR (EU/EEA) and 152-FZ (Russia), you may:
- Access the data we hold about you
- Correct inaccurate data
- Erase your data ("right to be forgotten")
- Restrict or object to processing
- Receive your data in a portable format
- Withdraw consent at any time
To exercise any of these rights, contact support@craftwall.pro. We respond within 30 days. EU residents may also lodge a complaint with their national supervisory authority. Russian residents may contact Roskomnadzor.
8. Cookies
We use only analytics cookies set by GA, Metrika, and Clarity for measurement. We do not use advertising or cross-site tracking cookies. You can block cookies in your browser settings; this may degrade analytics quality but does not block site access.
9. Children
The site is not directed to individuals under 16 years of age. We do not knowingly collect data from children.
10. Changes
We may update this Policy. Material changes will be reflected by an updated "Last updated" date at the top. Continued use after a change constitutes acceptance.
11. Contact
iViTech LLC — Privacy
support@craftwall.pro