Privacy Policy for Golovin Archive
Effective Date: 10 may 2026
Website:
http://golovinarchive.com/Operator: Pavel Golovin
Location of Operator: Russia, Chelyabinsk
Golovin Archive (“we”, “our”, “us”) respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, disclose, and safeguard your information when you visit our website
http://golovinarchive.com/ (the “Site”), in accordance with Russian Federal Law No. 152-FZ “On Personal Data” and other applicable data protection laws.
1. Data Controller (Operator)
Under Russian law, the “Operator” is the entity that organizes and processes personal data. For this Site, the Operator is:
Golovin Archive
Contact email: [Insert email, e.g.,
mr.pavelgolovin@inbox.ru]
2. What Personal Data We Collect
We may collect the following categories of personal data:
Voluntarily provided information: Name, email address, or any other details you submit via contact forms, subscription forms, or when you comment on materials (if enabled).
Automatically collected information: IP address, browser type and version, time zone setting, browser plug-in types, operating system, referring/exit pages, and date/time stamps (via server logs or basic analytics).
Cookies & similar technologies: Used to remember preferences and analyze general traffic patterns (no sensitive data stored).
We do NOT collect special categories of personal data (racial/ethnic origin, political opinions, religious/philosophical beliefs, biometric data, health data, or data concerning criminal convictions) unless you explicitly provide them in open correspondence.
3. Legal Basis for Processing (Compliance with Russian Law 152-FZ)
We process your personal data only when at least one of the following applies under Article 6 of 152-FZ:
You have given your consent to the processing of your personal data (e.g., by ticking a box or sending a message).
Processing is necessary for the performance of a contract to which you are a party (e.g., providing a requested service).
Processing is required for compliance with a legal obligation to which the Operator is subject (e.g., tax or archival retention rules).
Processing is necessary for the legitimate interests of the Operator (e.g., ensuring Site security) provided your fundamental rights do not override those interests.
4. How We Use Your Data
We use your personal data for the following purposes:
To respond to your inquiries or support requests.
To provide access to archived materials, articles, or digital collections.
To analyze and improve Site performance and user experience (aggregated data only).
To maintain security, prevent fraud, and comply with legal requirements (e.g., responding to lawful requests from Russian state authorities, including Roskomnadzor or law enforcement).
To send occasional updates about the archive (only if you have explicitly subscribed).
5. How We Share Your Data
We do not sell, rent, or trade your personal data. We may disclose your data only in the following limited circumstances:
Service providers: Third parties that help operate the Site (e.g., hosting provider) – under a contract that ensures compliance with 152-FZ.
Legal obligations: To comply with a court order, subpoena, or lawful request from Russian or international authorities.
Protection of rights: To enforce our terms of use or protect the safety, property, or rights of Golovin Archive, users, or others.
With your explicit consent: Any other disclosure will only occur after we obtain your separate, informed consent.
6. Data Transfers (International)
If you access the Site from outside the Russian Federation, your data may be transferred to and processed on servers located within Russia or in other countries where our service providers operate. By using the Site, you acknowledge that data transfers are carried out in
Golovin Archivegolovinarchive.comaccordance with Chapter 5 of 152-FZ (including cross‑border transfer rules). We ensure that any international transfer meets adequacy requirements or uses standard contractual clauses.
7. Data Retention
We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or archival (historical retention) requirements. After that period, your data will be anonymized or securely deleted.
Contact form data: up to 1 year after last interaction.
Subscriber data: until you unsubscribe or 3 years of inactivity.
Server logs: up to 6 months.
8. Your Rights Under Russian Law (152-FZ)
As a data subject, you have the following rights:
Right to access: Request confirmation of whether we process your personal data and receive a copy (within 10 days for simple requests, up to 30 days for complex ones –
*Article 14, 152-FZ*).
Right to rectification: Correct inaccurate or incomplete data.
Right to erasure (right to be forgotten): Request deletion of your data if processing is no longer lawful or if consent is withdrawn.
Right to restrict processing: Limit how we use your data while a complaint is investigated.
Right to withdraw consent: At any time, without affecting the lawfulness of processing before withdrawal.
Right to data portability: Receive your data in a structured, machine-readable format (where technically feasible).
Right to object: To processing based on legitimate interests.
To exercise any of these rights, contact us at [Insert email]. We may ask for proof of identity (e.g., a scan of your passport or Federal Law‑compliant e‑ID). We will respond within the deadlines set by 152‑FZ (generally 10 to 30 days).
9. Cookies and Tracking Technologies
We use minimal, non‑invasive cookies:
Essential cookies: Required for Site operation.
Analytics cookies: To count visits and traffic sources (anonymized).
You can set your browser to refuse all or some cookies, but parts of the Site may not function properly. No third‑party advertising cookies are used.
10. Children’s Privacy
The Site is not intended for individuals under 18 years old without parental consent. We do not knowingly collect data from minors. If we learn we have inadvertently collected personal data from a child under 16 (or the relevant age under Russian law), we will delete it immediately.
11. Data Security
We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access, in accordance with Article 19 of 152‑FZ (requirements for data protection). These include encryption, firewalls, limited access controls, and regular security audits.
However, no transmission over the Internet is 100% secure. You use the Site at your own risk.
12. Changes to This Privacy Policy
We may update this policy from time to time. The latest version will always be posted on this page with the “Effective Date” at the top. If we make material changes affecting your rights, we will notify you via a notice on the Site or by email (if we have your address).
13. Contact Information & Complaints
For any questions, access requests, or complaints regarding this Privacy Policy or our data processing practices, please contact:
Golovin Archive – Data Protection Officer (if any)
Email: [Insert email]
Mail: [Insert mailing address]
You also have the right to lodge a complaint with the Russian data protection authority:
Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)
Address: Kitaygorodskiy proyezd, 7, building 2, Moscow, 109074
Website:
https://rkn.gov.ru/However, we encourage you to contact us first so we can resolve your issue promptly.
14. Consent to Processing (for Russian users)
By using our Site and providing any personal data (including by filling out a contact form, subscribing, or sending an email), you confirm that:
understood this Privacy Policy.
You freely give your explicit consent to the processing of your personal data as described herein, under the terms of 152‑FZ.
You understand you may withdraw your consent at any time.
If you do not agree with any part of this policy, please do not use the Site or provide any personal data.
Golovin Archive – All rights reserved.
Instructions for implementation
Replace placeholders (e.g., [Insert Date], [Insert email], [Insert legal name], [Insert physical address]) with actual information about the site owner.
Add a visible consent checkbox on any form that collects personal data (e.g., “I consent to the processing of my personal data in accordance with the Privacy Policy”). Russian law requires explicit, informed consent.
If the site uses any external analytics (like Yandex.Metrica or Google Analytics), add a separate paragraph listing those services and their cookie policies.
If the site has no contact forms or user accounts, you can simplify sections 2, 4, and 5, but you must still inform users about automatic data collection (IP, logs).
This document minimizes legal risk for
http://golovinarchive.com/ while being clear for English‑speaking visitors.