Personal Data Processing Policy

Last updated: 08.11.2026

1. General Provisions

This Personal Data Processing Policy (the “Policy”) has been developed in accordance with Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and defines how personal data is processed, as well as the measures taken to ensure its security.

Data operator: Sole Proprietor David Andreevich Pantsulaya (INN: 771508450365, OGRNIP: 325774600810861) (the “Operator”, “we”).

This Policy applies to all personal data that the Operator receives from users of the website picturium.art (the “Site”) and the Picturium mobile application (the “App”).

2. Personal Data We Process

2.1. Data you provide

When registering and using the Site / App, you may provide: a username (nickname), email address, photos of your colored artwork, comments, and other information that you supply voluntarily.

2.2. Data collected automatically

When you visit the Site, we automatically collect: IP address, browser type and version, device type, screen resolution, referrer, data about pages viewed and actions on the Site, and cookies (see Section 6).

2.3. Order data in the shop

When you place an order on shop.picturium.art, you provide the recipient’s full name, telephone number, email address, delivery country and address, and an order comment. In addition, the language and source of the order (website or app), the number of the accepted version of the offer, and the time and IP address of its acceptance are stored. If you go to the shop while signed in to a Picturium account, the order is also saved to that account (section 2.4).

2.4. Orders in your account

If you go to the shop while signed in to a Picturium account in the app or on the website, the order you place is saved to that account. The account name is shown on the order form; to keep the order from being saved, tick “Don't save” there.

A saved order appears in “My orders” on shop.picturium.art and, in versions of the app that have a “My orders” section, in the app as well. There and on the order page you can see the order number, date, items and total, the delivery method and place (city or collection point), the status and the tracking number, and the order page on the website also shows the recipient’s initials. The full name, telephone number, email address, home delivery address and order comment are not shown there. When the status of the order changes (paid, shipped, refunded), a push notification with the order number may arrive on the device where you are signed in to this account in the app.

You can remove an order from your account in the “My orders” section of the app, if your version has it, or by writing to us. If your order has ended up in someone else's account, write to us and we will remove the link.

For this purpose we store the account identifier and the date and method of linking it to the order. The record of going to the shop from the app or the website and the network it started from are kept for 30 days, and a request to add an order with a code from an email for one day after it expires. When an account is deleted, the link is removed, and the order is kept for the period stated in section 5.

3. Purposes of Processing

We process personal data for the following purposes:

• providing access to Site and App features (gallery, likes, comments, uploading artwork);
• improving the quality of the Site and App and analyzing user behavior;
• ensuring technical operability and security;
• communicating with you (responding to inquiries);
• processing and fulfilling orders: accepting payment, issuing fiscal receipts, delivery, communicating about the order, handling inquiries, and complying with legal requirements;
• complying with the requirements of the legislation of the Russian Federation.

4. Legal Bases for Processing

Personal data is processed on the following bases: the data subject’s consent (Art. 6(1)(1) of Law 152-FZ); the performance of obligations imposed on the Operator by law, including those relating to the use of cash register equipment (Art. 6(1)(2)); the necessity of performing a contract (Art. 6(1)(5)); and the Operator’s legitimate interests (Art. 6(1)(7)), provided this does not infringe the rights and freedoms of the data subject.

5. Storage and Protection

The personal data of citizens of the Russian Federation is stored on servers located in the territory of the Russian Federation, in accordance with Art. 18(5) of Law 152-FZ.

The Operator takes the necessary organizational and technical measures to protect personal data against unauthorized access, destruction, alteration, blocking, copying, and distribution.

Personal data is stored no longer than the purposes of processing require. Once these purposes are achieved, or upon the user’s request, the data is destroyed.

Order data is stored for 5 years after the contract has been performed and is then deleted or de-identified; information that the Operator is required by law to keep is stored for the period established by law.

6. Cookies

6.1. What cookies are

Cookies are small text files stored in your browser when you visit the Site. They allow the Site to remember your settings and collect visit statistics.

6.2. Cookies we use

Strictly necessary (functional)

These ensure the basic operation of the Site: remembering the interface language, theme, and cookie consent. Without them, the Site cannot function properly. Basis: the Operator’s legitimate interest.

In the shop, these include:

• __Secure-picturium_cart — the contents of the cart: which books and how many copies you have added (no prices or data about you); shared by picturium.art and shop.picturium.art and kept for 30 days after the cart was last changed;
• __Host-shop_link — shop sign-in: an encrypted pass issued when you go to the shop from the app or the website while signed in to your account; it is used to save the order to the account (section 2.4) and to open “My orders”; it is kept until you close the browser, and the sign-in it carries is valid for no more than 2 hours; the “Sign out” button in “My orders” deletes it;
• shop_via — whether you came to the shop from the app or the website; kept until you close the browser;
• picturium_theme — the light or dark theme, so that the shop looks the same as the website or the app; shared by picturium.art and shop.picturium.art and kept for up to a year;
• .AspNetCore.Culture on shop.picturium.art — the language of the shop pages if you came via a link that specifies the language; kept for up to a year.

Analytics

We use Yandex.Metrica (Yandex LLC, Russia) to analyze traffic and user behavior. Yandex.Metrica sets cookies (including _ym_uid, _ym_d, _ym_isad, and others) and collects de-identified data: page views, clicks, scrolls, device and browser type. These cookies are set only after your explicit consent.

More about Yandex.Metrica: Terms of Service.

6.3. How to disable cookies

You can decline analytics cookies at any time by clicking “Decline” in the banner shown on your first visit to the Site. You can also delete or block cookies through your browser settings:

• Google Chrome
• Mozilla Firefox
• Safari
• Yandex Browser

Please note: disabling cookies may affect the proper functioning of the Site.

7. Sharing Data with Third Parties

The Operator does not sell or transfer personal data to third parties, except:

• the use of analytics services (Yandex.Metrica) — subject to the user’s consent;
• for order fulfillment: to the Robokassa payment service — the email address and the contents, amount, and number of the order; to the fiscal data operator, via the payment service’s receipt service — the email address for the receipt; to the delivery service — the recipient’s full name, telephone number, and address (including the country) and the order comment; to the email service through which emails are sent — the data contained in the emails about the order; to the Yandex SmartCaptcha service — technical data from the check on the checkout page;
• upon request of authorized government authorities in accordance with the legislation of the Russian Federation.

8. Your Rights

In accordance with Law 152-FZ, you have the right to:

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

If you are located in the EU/EEA, you may also contact your local data protection authority.

To exercise your rights, send a request by email: info@remedia.pics. We will respond within 10 business days.

9. Contact Information

For all questions related to the processing of personal data, please contact:
Sole Proprietor David Andreevich Pantsulaya
INN: 771508450365, OGRNIP: 325774600810861
Email: info@remedia.pics