Data processing
Privacy policy
Version dated 9 September 2026
This policy explains what personal data Samotsvet receives through the site, why it is needed, who may receive it and how a data subject can exercise their rights. We aim to collect only the information required to respond to an enquiry.
1. Data controller
Individual entrepreneur Nikita Andreevich Samotsvetov (Samotsvet), OGRNIP 323670000016524, INN 672200624836, registered in the Russian Federation.
Email: karfagen38@gmail.com. Telegram: @samotsvetvisa.
The full address and contractual details are included in the service agreement.
You may send a data request to karfagen38@gmail.com. Full details appear on the Contact and company details page.
2. Scope and applicable law
This policy applies to the Samotsvet website and enquiries submitted through its forms. Processing takes account of Russian Federal Law No. 152-FZ on Personal Data, the EU General Data Protection Regulation where it applies, and any other mandatory law of the relevant jurisdiction.
The controller has submitted a personal-data processing notification to Roskomnadzor. The registry details will be added to the site after the entry appears in the public register.
3. Data we collect
- Identity and contact data: name, email address, messenger username or another contact method.
- Enquiry data: work and experience summary, selected country or goal, intended relocation timing and the programme topic where the user arrives from a specific route page.
- Attribution data: landing page, page leading to the form, external referring page, button location and permitted UTM source, medium, campaign, content and term values.
- Technical data: request details and security logs which the site and CRM infrastructure may process for page delivery, form receipt, abuse prevention and fault diagnosis.
The initial form does not ask for passport details, health data, political or religious views, biometric data, bank details or other sensitive or excessive information. Please do not submit such information through the form.
4. Purposes and legal bases
| Purpose | Data | Legal basis |
|---|---|---|
| Replying to an enquiry and arranging a free consultation | Name, contact details and short-form content | Steps taken at the data subject's request before entering into a contract; consent where required |
| Preparing a proposal and negotiating terms | Contact details, selected country or goal, experience summary and timing | Pre-contractual steps and subsequent performance of a contract |
| Understanding enquiry sources and improving the site | UTM values, entry and source pages, external referrer and button location | Legitimate interest in measuring Samotsvet's own channels with limited data |
| Security, spam prevention and protection of rights | Technical request data and logs | Legitimate interest and compliance with legal duties |
| Accounting and legal records after a contract is signed | Contract and payment data | Performance of a contract and compliance with law |
We do not use form data for bulk marketing messages without separate, unambiguous consent.
5. Source of data and required fields
Data normally comes directly from the person submitting the enquiry. The initial form asks for a name, contact method, short work and experience summary, country or goal and intended relocation timing. After consent is confirmed, the request is sent directly to the CRM for specialist review before the free consultation is arranged.
6. Retention
- An enquiry which does not lead to contracted work is kept for no more than 24 months after the last substantive communication.
- If a contract is signed, data is kept throughout the work and afterwards for as long as needed for accounting, mandatory legal requirements and the establishment or defence of legal claims.
- Technical logs are kept for the limited period set by the infrastructure provider and required for security and diagnosis.
After the applicable period, data is deleted or anonymised unless continued retention is required by law.
7. Recipients and processors
Access is limited to what is necessary for a specific purpose and may be given to:
- GitHub Pages, which delivers the static site pages. Submitted form fields do not pass through GitHub Pages;
- the Samotsvet CRM and the provider of its Russian server infrastructure, which receive and store enquiries. The user's browser sends the form directly to
crm.samotsvetvisa.com, and the record is stored in the CRM on a server in Russia; - Samotsvet personnel and contractors who need the data to respond or carry out agreed work and are bound by confidentiality;
- an independent lawyer, regulated immigration adviser, translator or other professional where this is needed for the requested service, covered by the agreement or separately approved by the client;
- public authorities or other parties where disclosure is required by law or needed to protect lawful rights.
Samotsvet does not sell personal data or disclose it to advertising networks.
8. International processing
The enquiry is first recorded and stored in the CRM on a server in Russia. GitHub Pages delivers the site through foreign infrastructure and may process technical request data, but does not receive the contents of the submitted form fields.
If a user chooses to communicate through Gmail or Telegram, that service processes the communication under its own terms. Before sending case material to a foreign lawyer, regulated adviser, translator or other professional, Samotsvet establishes the applicable legal basis and completes any required notice, consent and contractual steps.
9. Cookies and analytics
The Samotsvet site does not set cookies, advertising pixels or third-party analytics. During an open tab, sessionStorage holds only technical enquiry context: permitted UTM values, entry and source pages, the external referrer and button location. Form fields are not written to this storage, and the browser removes the context when the tab is closed. The hosting provider may process request data and logs required for page delivery, security and fault diagnosis.
10. Security
Measures include account-based access controls in the CRM, validation of submitted data, a hidden anti-spam field, HTTPS encryption and other organisational and technical safeguards. No method of internet transmission or storage can remove all risk.
11. Data subject rights
Depending on the applicable law, a data subject may:
- obtain confirmation of processing and a copy of their data;
- request correction of inaccurate or completion of incomplete data;
- request deletion or restriction where there is no longer a lawful basis for processing;
- withdraw consent without affecting processing carried out before withdrawal;
- object to processing based on legitimate interests;
- receive data in a portable format where that right applies;
- complain to the competent supervisory authority, including Roskomnadzor or the authority in the relevant EU Member State.
We may ask for reasonable proof of identity before fulfilling a request so that data is not disclosed to another person.
12. Enquiry review
The form collects information for initial contact and sends it to the CRM. It does not calculate approval prospects or select a programme automatically.
A specialist provides a preliminary view during or after the consultation. That view is not legal advice, a guarantee of approval or a decision by an immigration authority.
13. Children's data
The site is not intended for independent use by anyone under 18. Information about a child in a family enquiry should be provided by a parent or legal guardian, and only to the extent needed at the relevant stage.
14. Requests and complaints
A request may be sent to the controller's address or through the electronic channels on the contact page. Please include your name, the contact method used, the nature of the request and enough information to locate the relevant record. Samotsvet will respond within the period required by applicable law.
15. Changes to this policy
The current version is always published on this page. If the purposes of processing or categories of recipients materially change, the revision date will be updated and new consent will be requested where required by law.