Draft pending legal review. Items in [square brackets] will be filled in before launch.
Privacy Statement
Last updated: October 1, 2026
This statement explains what personal data the spomeny.com website collects today, why, and what you can do about it. The Spomeny vault product has not launched yet; a separate notice will cover it before launch.
01Who is responsible
The data controller is [Operator legal name, registration number and address]. Contact: [privacy contact email].
02What we collect
Concierge request: your name, phone number and the topic you choose.
Waitlist: your email address and the tier you are interested in.
With every request we also store the date and time, the site language and your IP address (to fight spam and abuse).
The interactive vault demo does not send anything: the text you type is encrypted in your browser with a throwaway key and stays on your device.
03Why and on what basis
To answer your concierge request and to invite you to the pilot. The basis is your consent, which you give with the checkbox in the form.
We do not send newsletters, sell, or rent your data, and we do not use it for advertising.
04Where it is stored and who sees it
Requests are stored on our server in a data centre in Moscow, Russia, in a file accessible only to the service that receives them.
If notifications are enabled, a copy of the request is sent to the team via Telegram, which may involve cross-border transfer.
05How long we keep it
Until the purpose is achieved (your request is answered or the pilot opens) or until you withdraw consent, and no longer than 3 years.
06Cookies and analytics
The site does not set cookies and does not use third-party analytics or tracking. Fonts and scripts are served from our own server.
07Your rights
You can ask what data we hold about you, correct it, delete it or withdraw consent at any time by writing to [privacy contact email]. We reply within 10 working days.
Depending on where you live, these rights are provided by Russian Federal Law No. 152-FZ “On Personal Data” and/or the EU GDPR. You may also complain to your data protection authority.