Personal Data Processing Policy

Last updated: July 1, 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).

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);
• 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 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.

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.

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;
• 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