Privacy Policy

This Policy sets out how personal data of users of the Tuqo service (https://tuqo.ru) is processed and protected. The operator of personal data is Individual entrepreneur (sole proprietor) Aleksandr Viktorovich Antonov (TIN (INN) 262517638904, OGRNIP 312265133100116, address: 52/359 Skachkova St., Rostov-on-Don, Russia). Processing is carried out in accordance with Federal Law No. 152-FZ “On Personal Data”. Contact for matters of processing: support@tuqo.dev.

Who are you? If you are a visitor of a site hosted on Tuqo (you submitted a form, signed up or paid for access), the operator of your data is the owner of that site, and the terms that apply to you are set out on the page “Tuqo terms for site visitors”. If you are a site owner, the sections below apply to you, as does the document “Personal data processing instruction”.

1. Roles: operator and processing on instruction

• With respect to account holders, the Operator processes their personal data as an operator (determines the purposes and means of processing itself).
• With respect to data that sites hosted by Users collect from their visitors, and data that Users themselves place in the content of sites or in sign-in address lists, the Operator acts as a person processing personal data on the instruction of the operator (Part 3 of Article 6 of Federal Law No. 152-FZ; hereinafter “processing on instruction”): the operator of such data is the User (the site owner) themselves. The User is solely responsible for the lawfulness of collection, obtaining consents and informing their visitors. The terms of the instruction are set out in the document “Personal data processing instruction”.
• Two roles of one platform. For the data of site visitors, the Operator is a processor acting on the owner's instruction; for technical access logs, abuse prevention, traffic accounting and settlements with owners under their plans, it is an independent operator with its own purposes (sections 3–4).

2. What data is processed

• Authentication data: email, name, avatar, OAuth identifiers (Yandex, VK), password (stored only as an irreversible hash), time zone and interface language;
• Messengers (if the User has linked them): Telegram and MAX account identifiers and the contents of notifications sent to them;
• Technical data: IP address, user agent, date and time of requests, cookie data;
• Usage data: information about projects, sites, domains, deploys, API keys, audit logs;
• Support tickets: the content of correspondence, attached files, the ticket category and the notification address specified by the User;
• Content complaints (complainants are any persons, including non-Users): the name and email address, if the complainant provided them, the address of the material, the type and substance of the violation, for an intellectual property complaint — information about the complainant, the original and the rights, correspondence on the complaint, IP address, browser details, the date and time of the complaint and of the consent, the version of the documents;
• Analytics data (Yandex Metrica): cookie identifiers, browser details and actions on pages, including session recording — on the https://tuqo.ru website only after consent in the cookie banner, in the control panel only after separate consent to analytics;
• Consent records: which consent was given or withdrawn, the date and time, IP address, browser details and the version of the documents;
• Traffic statistics of Users' sites, on the User's instruction (Terms of Service, clause 17.1): IP address, information about the client application, date and time of the request, the requested address, response code and size, referrer. Raw events are not stored: the database keeps only daily totals and anonymized lists (popular pages, referrers, response codes). The unique-visitor marker is computed by an irreversible transformation with a key that changes daily and is not stored anywhere, so a visitor cannot be matched across days. In the basic mode no cookies are used and no code is added to the User's site;
• Payment data (when paying for paid plans), in masked form (last digits of the card, expiry date, payment system); full card details are not transferred to the Operator and are not stored by it.
• Data of visitors of Users' gated sites (the “Member sign-up” («Регистрация») and “Paid access” («Платный доступ») modes), on the User's instruction (Terms of Service, clauses 17.1 and 18.1): email address, name (if the User has enabled such a field), IP address and the moment of consent together with a snapshot of the documents the visitor agreed to; membership status and sign-in records. Sign-in codes are stored for minutes and destroyed after use; visitors are not issued passwords. A block on a visitor after their data has been deleted is stored as an irreversible pseudonym of the address (HMAC) that does not allow the address itself to be recovered. In the “Paid access” mode, a payment record is additionally kept (amount, date, email address, what was purchased); the money goes directly to the User under the User's own acquiring agreement, and buyers' card details are not transferred to the Operator. In the “MAX users” mode: the identifier and name of the visitor's MAX account, a phone number verified by MAX (only if the User has turned on the request and the visitor shared it), participation status, the moment and text of consent, sign-in records; no record is created for a visitor whom the User's rules did not admit. The terms for the visitors themselves are set out on the page “Tuqo terms for site visitors”;
• Data of the “Email code” mode («Код на почту»), on the User's instruction: email addresses from the list maintained by the User and their labels; sign-in sessions (moment of sign-in, no more than three devices per address) without the IP address; addresses not on the list from which sign-in was attempted, and the number of attempts and the time of the last one, for the User's log;
• Log of visitors' consents, on the User's instruction (Terms of Service, clause 17.1a), if the User requests consents on the login screen or in the Tuqo bot: email address or Telegram or MAX account identifier, IP address and browser details at the moment of consent, date and time, a snapshot of the items and ticks;
• Notifications about events on gated sites, on the User's instruction: information about a request, payment or sign-in attempt is sent to the recipients chosen by the User; the visitor's address, name, phone number and identifier are included only if the User has enabled this for the recipient;
• Publishing without registration (Tuqo Drop drafts): IP address, information about the client application (user agent), the fact and time of confirming consent to the Terms of Service, and the uploaded draft files. No account is created, and no email or name is requested.

3. What data is not collected

The Operator does not intentionally collect special categories of personal data (concerning health, racial or ethnic origin, political, religious or philosophical beliefs, intimate life) or biometric personal data.

4. Purposes and legal grounds (Federal Law No. 152-FZ)

• Providing the Service, authentication: performance of the contract (the Terms of Service);
• Communication and support: performance of the contract;
• Security, abuse prevention (technical data, audit logs): the Operator's legitimate interest;
• Publishing a draft without registration: performance of the contract (the Terms of Service, section 16) as regards the publication itself; recording the IP address, client application and confirmation of consent: the Operator's legitimate interest (clause 7 of Part 1 of Article 6 of Federal Law No. 152-FZ), namely protection against abuse, handling complaints about content and compliance with legal requirements;
• Accepting payments and fiscal receipts (for paid plans): performance of the contract and a legal requirement (the Tax Code of the Russian Federation, Federal Law No. 54-FZ on cash register equipment);
• Web analytics (improving the Service): consent — on the https://tuqo.ru website, given in the cookie banner; in the control panel, a separate optional consent to analytics that can be withdrawn with a switch in the profile;
• Marketing messages (promotions, special offers and news): only with separate consent, which can be withdrawn at any time with a switch in the profile;
• Recording consents: the Operator's obligation to prove that consent was obtained (Part 3 of Article 9 of Federal Law No. 152-FZ).
• Handling content complaints: the complainant's consent (“Complainant's consent”), given with a separate checkbox in the complaint form or by stating it in an email; keeping information about the complaint and the measures taken is also the Operator's legitimate interest (clause 7 of Part 1 of Article 6 of Federal Law No. 152-FZ): proof of the information intermediary's response to the complaint (Article 1253.1 of the Civil Code of the Russian Federation).

The user gives consent to the processing of personal data separately from the Terms of Service and this Policy, with a separate checkbox at sign-up (Part 1 of Article 9 of Federal Law No. 152-FZ). Its text is in the document “Consent to the processing of personal data”. Processing required to perform the contract and to comply with the law continues after consent is withdrawn, within those grounds (Part 2 of Article 9 of Federal Law No. 152-FZ).

5. Transfer to third parties

Data is stored on infrastructure in the Russian Federation leased by the Operator: TIMEWEB.CLOUD LLC (ООО «ТАЙМВЭБ.КЛАУД», TIN 7810945525, Timeweb Cloud: servers, databases, object storage; data centers in Moscow and Saint Petersburg) and Cloud Technologies LLC (ООО «Облачные технологии», Cloud.ru, TIN 7736279160, OGRN 5167746080057: backups, with database backups in encrypted form). The infrastructure providers do not process personal data on instruction and have no access to the contents other than technological access; processing is carried out by the Operator; this is not a transfer to third parties. The Service's emails are sent from the Operator's own mail server; no third-party email service is used.

Data may be transferred only to the extent necessary for the Service to work:

• to the web analytics service Yandex Metrica (YANDEX LLC, TIN 7736207543): only with consent — on the https://tuqo.ru website, given in the cookie banner; in the control panel, a separate consent to analytics;
• to OAuth providers (Yandex, VK), as part of the sign-in procedure;
• to the Telegram and MAX messengers, if the User has linked a messenger themselves: to deliver notifications and submissions from their sites;
• to the payment agent (acquirer) and the fiscal data operator, when paying for paid plans;
• to the User's payment provider (a bank or payment service under the User's acquiring agreement), in the “Paid access” mode, on the User's instruction: the data needed to create a payment and, if an online cash register is connected, to issue a receipt (the buyer's email, the item name and the amount);
• to the owner of the site whose material an intellectual property complaint concerns: the complainant's name, email address and the text of the complaint, only with the complainant's separate consent to such transfer;
• to authorized government bodies, upon lawful requests.

Employees and contractors are given access to data on the principle of the minimum necessary scope.

6. Cross-border transfer

The Operator does not carry out cross-border transfer of personal data. Storage and processing take place in the territory of the Russian Federation. If this changes, the Operator will notify data subjects and file the required notifications with Roskomnadzor (the Russian data protection authority). Delivery of visitors' submissions and the check of visitors' subscriptions via Telegram, if enabled by the User, are performed on the User's instruction as the operator of that data (Processing instruction, sections 3 and 5).

7. Retention periods

• Account profile: for as long as the account exists; when the User deletes the Account, it is destroyed automatically after the 72-hour cancellation period (see the Terms of Service, section 15); data in backups is destroyed in the course of scheduled rotation (within 14 days at most);
• Audit logs: 1 year;
• Support tickets: correspondence is kept 3 years from the date of the last message, after which the ticket is deleted automatically. When the Account is deleted, the ticket is moved to the archive: its link to the Account is severed, the correspondence is closed, attachments are destroyed immediately, and the ticket itself is deleted when the stated period expires. The ground for retention is the performance of the Operator's obligations and the protection of its rights (clauses 2 and 7 of Part 1 of Article 6 of Federal Law No. 152-FZ);
• Data subject requests (for deletion, access, correction of data) and records of their fulfilment: in a separate log, 3 years; the log confirms the Operator's response and is kept even after the ticket itself is deleted;
• Content complaints: 3 years from the date of filing, after which they are deleted automatically;
• Artifacts and site data: according to the retention settings and until the site/project is deleted (a deleted site is kept in the trash for 24 hours, or 7 days if it was deleted for non-payment); in backups, within 30 days at most after final deletion, backups being destroyed automatically;
• Form submissions on Users' sites and the files attached to them: for as long as the User keeps them in the project; spam is moved to the archive after 30 days, locked submissions over the limit after 90 days, archived submissions are deleted 180 days after being moved to the archive, and all submissions of a site are deleted when the site or the project is deleted; the files of a submission are deleted together with it, or earlier upon the User's action; in backup copies, no later than 30 days after deletion;
• The “Email code” mode: an address is kept for as long as it is on the User's list; sign-in sessions: 30 days from sign-in; sign-in attempts from addresses not on the list: 30 days from the last attempt;
• Daily totals of site statistics: 12 months; anonymized lists (popular pages, referrers, response codes): 3 months;
• Drafts published without registration: 24 hours from publication (or until moved to an account, from which point the general periods for sites apply); log records of a draft's publication: 1 year, like other audit logs;
• Data of members of gated sites (the “Member sign-up”, “Paid access” and “MAX users” modes; sign-in sessions: 30 days from sign-in): for as long as the member record exists, that is, until it is deleted by the User who owns the site or until the site itself is deleted; the irreversible pseudonym of a blocked address: for as long as the block is in effect;
• Log of consents of visitors of Users' sites: together with the member record, the MAX user record or the address on the list, and together with the site; records of channel subscribers: 3 years after the last sign-in; the queue of notifications about events on gated sites: 7 days after sending; control panel bell notifications about such events and about form submissions that may contain visitor data: 30 days;
• Records of buyers' payments on Users' sites: 3 years from the payment date, including after the member profile is deleted, as an accounting trail of the transaction for resolving disputes; then destroyed;
• Visitor data, upon a separate request for destruction from the site owner: destroyed within 30 days at most;
• Billing logs (for paid plans): indefinitely, as financial records under tax legislation;
• Consent records (giving and withdrawal, the Account's email address, IP address, browser details, document version): for as long as the Account exists and 3 years after its deletion, as proof that consent was obtained for processing already carried out (Part 3 of Article 9, clause 7 of Part 1 of Article 6 of Federal Law No. 152-FZ); then destroyed automatically;
• Cookie banner choice (localStorage): until cleared by the browser.

When the period expires, the data is destroyed or anonymized.

Technical serving logs. The Service's web servers record requests to hosted sites: IP address, date and time, the requested address, response code, referrer and information about the client application. These logs are needed to investigate incidents, violations and Users' requests, are kept for 14 days and are then deleted automatically. With respect to the data of visitors of a User's sites, the Operator acts on that User's instruction (section 1).

8. Data subject rights

The User has the right to:

• obtain information about the processing of their data, its source, purposes, methods and periods;
• demand that incomplete, outdated or inaccurate data be corrected, blocked or destroyed;
• demand that the processing of personal data be stopped (Part 5.1 of Article 21 of Federal Law No. 152-FZ);
• withdraw consent: optional ones (dashboard analytics, news) with switches in the profile, consent on the https://tuqo.ru website via “Cookie settings” in the site footer, the others by a request to the Operator or by deleting the Account using the Service's tools;
• appeal against the Operator's actions to Roskomnadzor and in court.

Requests are sent to support@tuqo.dev; the response period is 10 working days from receipt of the request; it may be extended by no more than 5 working days with a reasoned notice (Parts 1 and 3 of Article 20 of Federal Law No. 152-FZ).

9. Data protection

The Operator applies legal, organizational and technical measures: transmission over secure channels (TLS), encryption of secrets (API keys, tokens), access control, audit logs of significant actions, and mechanisms protecting against automated abuse. Details of the technical measures are not disclosed so as not to reduce their effectiveness.

10. Cookies

The use of cookies and similar technologies is described in the Cookie Policy.

Separately: no cookies are used and no code is added to pages for analytics on Users' sites; in the basic mode, statistics are counted by the serving server from the requests it serves anyway. The User enables the extended mode, which places code, themselves; it gives rise to separate obligations of the User towards the visitors of their site (Terms of Service, clause 17.2).

The exception is the service cookie for gated access: it is set only if the User has restricted access to the site themselves (with a password, an email code, a channel subscription, member sign-up, sign-in with MAX or paid access), only after a successful sign-in and only so that access does not have to be checked again on every page. It contains no information about the visitor and is not used for analytics; for details, see the Cookie Policy.

In the “subscribers only” mode, the check is performed by the Service's bot in the messenger (Telegram or MAX): the platform is sent a query about whether the visitor is a member of the User's channel, and the Service receives in response only the fact of subscription. The numeric identifier of the visitor's messenger account is used at the moment of the check and is not stored in the Service's database, except in the consent log if the User asks for consents (section 2); anonymized counters (“screen shown”, “signed in”) contain no identifiers. Processing is carried out on the instruction of the User who owns the site (the same framework as for address lists, Part 3 of Article 6 of Federal Law No. 152-FZ).

In the “MAX users” mode, the visitor confirms sign-in in the Service's bot in the MAX messenger, and the Service receives from MAX the identifier and name of their account and, if the User has turned on the phone request and the visitor shared it, a phone number verified by MAX. This data is kept in the User's participant log and used only for admission to that site, keeping that log and the bot's messages to the visitor about their access status; the visitor sees what the site owner will see before confirming. Processing is carried out on the User's instruction (Part 3 of Article 6 of Federal Law No. 152-FZ).

11. Changes to the Policy

The Operator may amend this Policy. A new version is published at https://tuqo.ru/legal/privacy with its effective date indicated.