Privacy and personal data processing policy
Effective date: 4 August 2026.
1. Controller and scope
This policy describes personal-data processing through chateaulouvre.ru by Individual Entrepreneur Sergey Nikolaevich Evstigneev, Russian tax ID 300435681000, registration number 320237500089791 (the “Controller”). It covers information submitted through forms and technical information produced when the website and lead gateway are used.
2. Purposes
- responding to enquiries and preparing a property selection;
- coordinating viewings, reservations and transaction-related communication;
- maintaining lead history in CRM and controlling service quality;
- protecting forms from automated, duplicate or abusive submissions;
- measuring page and advertising performance only after analytics consent;
- complying with applicable obligations and protecting legitimate rights.
3. Data categories
Data entered by the user may include name, telephone, email, comment, intended property or purpose, budget, location and timing. Technical and attribution data may include IP and trusted proxy chain, date and time, page URL and title, landing page, referrer, UTM parameters, advertising click identifiers, Yandex Metrica ClientID after analytics consent, language, device, operating system, browser, User-Agent, screen size, session and visitor identifiers.
Service data may include the form identifier, Lead ID, Receipt ID, idempotency key, message digest, consent version and time, submission frequency for a protected IP hash, automatic risk indicators and delivery status for CRM and Telegram.
4. Processing and recipients
The Controller may collect, record, organise, store, update, use, transfer to authorised processors, restrict and delete data as required for the stated purposes. Hosting and lead processing may involve Timeweb and amoCRM. A shortened Telegram notification may be sent with masked telephone and email; full lead data is intended for the configured CRM and encrypted server queue.
5. Analytics
Yandex Metrica and any configured Google tag are loaded only after the visitor allows analytics in the cookie banner. Adding other analytics or advertising services requires updating this policy and the consent configuration.
6. Retention and security
Lead data is retained for no longer than three years from the enquiry unless a different period is required by law or contract, or until the purpose is achieved or consent is withdrawn. Protected submission-frequency records are retained for up to 30 days. The encrypted retry queue is retained until confirmed delivery or exhaustion of the configured retry policy.
Technical controls include HTTPS, restricted access, secrets outside the public directory, encrypted queue storage, masking in notifications, CSRF protection, honeypot, rate limiting, duplicate protection and technical error logging without public disclosure.
7. Rights and contact
A user may request information, correction, restriction or deletion of data and may withdraw consent. Requests can be sent to info@kvmsochi.ru. The Controller may request enough information to locate and verify the relevant enquiry.
8. Controller details
Individual Entrepreneur Sergey Nikolaevich Evstigneev
Tax ID 300435681000; registration number 320237500089791
79/1 Teplichnaya Street, apartment 65, Sochi, Krasnodar Krai 354004, Russia
Telephone: +66 99 999 66 99
This English version is provided for convenience. Where mandatory local wording is required, the Russian version and applicable law take priority.