Effective date: 5 June 2026.
1. General provisions
This Personal Data Processing Policy (the “Policy”) is issued pursuant to clause 2, part 1, article 18.1 of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law No. 152-FZ”) and defines how personal data is processed and secured at White Lotus LLC.
The Policy applies to all personal data the Operator may receive from visitors of the white-lotus.pro website. By submitting an enquiry through the contact form, the user confirms agreement with this Policy.
This English text is provided for convenience only. In case of any discrepancy, the Russian-language version of this Policy prevails.
2. Operator and responsible person
Operator: White Lotus Limited Liability Company (White Lotus LLC), OGRN 1267700061727, INN 9703239825, KPP 770301001, address: 123242, Moscow, Presnensky district, Volkov lane, bldg. 13, block 1, unit 13.
The person responsible for organising the processing of personal data is the Director General, Dmitry B. Vlasov. Requests regarding personal data processing should be sent to info@white-lotus.pro.
3. Key terms
- Personal data - any information relating to a directly or indirectly identified individual (the data subject).
- Processing - any action or set of actions with personal data (collection, recording, storage, use, transfer, deletion and others).
- Operator - the party that organises and/or carries out the processing of personal data.
4. Categories of subjects and data processed
The Operator processes personal data of website users who submit an enquiry through the contact form.
Through the contact form the Operator processes data the user provides voluntarily:
- name;
- organisation name (optional);
- email address;
- message text.
When the web analytics service is used, technical data may be processed automatically: IP address, device and browser information, referral source, on-site activity and cookie identifiers (see “Cookies and web analytics”).
The Operator does not request or process special categories of personal data or biometric personal data.
5. Purposes of processing
- reviewing user enquiries and preparing replies;
- arranging interaction at the user’s request;
- collecting anonymised traffic statistics and improving the website.
6. Legal basis
- Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”;
- the charter of White Lotus LLC;
- the consent of the data subject given when submitting the contact form.
7. Processing methods, storage and localisation
Processing is carried out by mixed means - with and without the use of automation - in compliance with Law No. 152-FZ.
Recording, systematisation, accumulation, storage, refinement and retrieval of the personal data of citizens of the Russian Federation are performed using databases located in the territory of the Russian Federation (part 5, article 18 of Law No. 152-FZ). The Operator’s servers and mail infrastructure are located in the Russian Federation; messages from the form are delivered by the Operator’s own means.
8. Retention and destruction
Personal data is processed for no longer than the purposes of processing require. Data received through the contact form is kept until the processing purpose is achieved or consent is withdrawn, but no longer than one year from the last enquiry.
Once the purposes are achieved or consent is withdrawn, personal data is destroyed or anonymised in the established manner.
9. Transfer of personal data
The Operator does not transfer personal data to third parties except in cases provided for by the legislation of the Russian Federation. No cross-border transfer of personal data is carried out.
10. Cookies and web analytics
The website uses cookies. Strictly necessary cookies keep the website working and are set without consent.
Anonymised traffic statistics are collected using the Yandex.Metrica service (Yandex LLC), which sets analytics cookies and processes technical data in the territory of the Russian Federation. Analytics cookies are set only after consent is given through the cookie notice. The user can decline analytics cookies or change the choice later, and can also disable cookies in the browser settings.
11. Rights of the data subject
The data subject has the right to:
- obtain information about the processing of their personal data;
- request the correction, blocking or destruction of data that is incomplete, outdated, inaccurate or processed unlawfully;
- withdraw consent to the processing of personal data;
- appeal the Operator’s actions to Roskomnadzor or in court.
To exercise these rights, send a request to info@white-lotus.pro. A reply is provided within the time limits established by Law No. 152-FZ.
12. Security measures
The Operator takes the necessary legal, organisational and technical measures to protect personal data from unlawful access, destruction, alteration, blocking, copying and distribution: appointing a person responsible for organising processing, restricting access to data, using secure transmission channels, backups and control over actions with personal data.
13. Changes to the Policy
The Operator may amend this Policy. The current version is permanently available on the website at white-lotus.pro/privacy. A new version takes effect once published, unless the version provides otherwise.
14. Operator contacts
For questions about personal data processing: White Lotus LLC, info@white-lotus.pro, +7 992 111 0999.