Privacy policy

1.1.The data controller is Individual entrepreneur Victoria A. Drozdova (OGRNIP 317910200139082), Russian Federation. Contact for all privacy questions and requests: info@brainin.media (Telegram: https://t.me/brainin_media).

1.2.We have not appointed a data protection officer. Because the Site is operated from Russia, your data is processed in Russia (see “International transfers”).

• Technical data (IP address, browser and device type, page requested, date and time). Purpose: to operate and secure the Site and protect it from abuse and spam. Legal basis: our legitimate interests (Art. 6(1)(f) GDPR).
• Analytics data (pages viewed, actions on the page, visit duration, approximate location at city level, cookie identifiers), collected by Yandex Metrica and Google Analytics, and by our own page-view counter. Purpose: to understand how the Site is used and improve it. Legal basis: your consent (Art. 6(1)(a) GDPR), given through the cookie banner. Nothing is collected for analytics before you accept. For visitors outside Russia we do not use Yandex session replay (“Webvisor”).
• Club reviews: the name or nickname, rating and text you enter in the form. Purpose: to publish your review after moderation. Legal basis: your consent (Art. 6(1)(a) GDPR), given by submitting the form. Please do not include your phone number, email, address or other personal details of yourself or others.
• Messages: whatever you send us by email or Telegram. Purpose: to answer you. Legal basis: our legitimate interests (Art. 6(1)(f) GDPR).

3.1.The Site uses strictly necessary storage (for example your language and theme choice and your cookie decision), which does not require consent, and analytics cookies and identifiers, which are used only after you accept them in the cookie banner.

3.2.You can change your decision at any time with the “Cookie settings” link in the footer, and you can also delete cookies in your browser. Withdrawing consent does not affect the lawfulness of processing before withdrawal. The Site keeps working if you decline analytics.

4.1.We may use AI services to pre-screen reviews for spam and abuse and to machine-translate articles. Only the text of the review or article is sent, without information that identifies its author. Decisions about disputed reviews are made by our editors; no decision with legal or similarly significant effect on you is made by automated means alone.

5.1.We do not sell personal data and do not share it for advertising. Recipients are: our hosting provider; analytics providers (Yandex LLC, Russia, and Google LLC, USA) — only if you have consented; AI service providers (review and article text only); and public authorities where the law requires.

6.1.The Site’s servers and the controller are located in Russia. The European Commission has not adopted an adequacy decision for Russia, so there may be fewer safeguards than in your country. We limit the data we collect, and where we transfer analytics data to Russia or to the United States (Google Analytics) we rely on your explicit consent given in the cookie banner (Art. 49(1)(a) GDPR). If you do not wish this, decline analytics cookies.

6.2.Technical data is necessarily processed on our servers in Russia whenever you load a page; if you do not accept this, please do not use the Site.

7.1.Technical logs are kept for a limited period needed for security and troubleshooting. Analytics data is kept according to the settings of the respective provider and, for our own counter, only in aggregated form. Reviews are kept while they are published or until you ask us to delete them. Your cookie decision is stored in your browser for up to 12 months.

8.1.You have the right to: access your data; have it corrected; have it erased; restrict or object to its processing; receive it in a portable format; and withdraw consent at any time (Art. 7(3), 15–21 GDPR). To exercise a right, write to info@brainin.media and tell us the name used in your review, the page address and the approximate date. We will reply within one month.

8.2.You also have the right to complain to a data protection supervisory authority — in the EEA, the authority in your country of residence, place of work or the place of the alleged infringement; in the United Kingdom, the Information Commissioner’s Office (ico.org.uk).

9.1.The Site is not directed at children under 16. If a minor has left a review, tell us and we will delete it.

10.1.The connection is encrypted (HTTPS), passwords of staff accounts are stored only as hashes, access to the control panel is restricted, and the number of login and form submission attempts is limited.

11.1.The Site links to third-party websites. We are not responsible for their privacy practices.

12.1.We may update this Notice. The current version is always on this page, with its date at the top. If a change affects the legal basis of processing, we will ask for your consent again where required.