1 Operator and scope
1.1. The operator is the Autonomous Nonprofit Organization Centre for the Preservation of Industrial and Natural Heritage “ZELINO 1893”, OGRN 1266900006713, INN 6900033592. Address: building 7, Zelino territory, Staritsa municipal district, Tver Region, Russian Federation. Data requests: zavod@zelino.ru.
1.2. This policy covers donations through https://zelino.ru, monthly support management, receipt confirmation, refunds and related requests. Other processing purposes require the appropriate separate basis and information for the person.
2 Data and purposes
2.1. Donation processing and records use the amount, date, purpose, transaction references and status, refunds and accepted terms. A name for a one-off donation is optional. If it is not supplied or lawfully obtained from payment documents, the Organization does not invent a donor identity. The one-time general statutory donation form requests the donor’s name to document and trace the agreement. It is recorded as self-declared, not as verified bank identity. This form does not request a telephone number or email address.
2.2. Monthly support uses the supplied name and email, amount, schedule, charge authorization, saved-method reference and its usage history. Email is used for support management and service messages, not marketing enrolment.
2.3. Requests and refunds use supplied contact details, request content, the relevant payment and necessary evidence of authority. Third-party and unnecessary information should be omitted or redacted.
2.4. Website protection uses minimal request and security-event information: time, requested resource, network address or its protected representation, client software information, check result and event reference. Private management links, payment tokens and payment-form contents must not enter public logs or analytics.
2.5. The Organization does not request a PIN, CVV/CVC, banking password or payment confirmation code. Full payment credentials are entered with the provider. Special-category and biometric data are not needed for this process.
2.5. To resume an unfinished request, the current browser tab temporarily stores a random request identifier and private status link. This lets the same payment continue after a page reload. The entry is removed after verified completion or cancellation, or when the tab session ends. These details are not sent to analytics.
3 Legal bases
3.1. Data necessary to conclude and perform a donation agreement is processed on a contractual basis. Data needed for accounting, tax records, mandatory reports and lawful requirements is processed on the applicable legal basis. Necessary protection of legitimate interests relies on a lawful basis while respecting individual rights.
3.2. When processing relies on consent, a standalone text and a separate verifiable action are provided. Consent is not incorporated into acceptance of the offer or preselected. It covers only its specified data, actions and purposes. Refusing optional processing does not remove other lawfully available donation methods.
3.3. Publishing a donor’s name, image, story or contacts, and marketing, require their own lawful basis. This policy, a payment and monthly management consent do not authorize public acknowledgements or advertising.
4 Disclosure and location
4.1. Banks and the payment service process payment within their agreements and duties. The service used is YooKassa, NBCO YooMoney LLC; an aggregator’s participation follows the payment acceptance agreement. Those parties fulfil their own relevant processing duties. The Organization receives only necessary transaction information.
4.2. Technical and accounting contractors receive access only as needed for a task on a proper legal basis. A processing instruction must define the purpose, data and actions, confidentiality, security and contractor duties. Information is disclosed to authorities on a lawful basis.
4.3. Collection of Russian citizens’ data through the website is arranged using databases within the Russian Federation in accordance with Article 18 of Federal Law No. 152-FZ. Adding a foreign service or cross-border transfer requires prior legal and technical checks and compliance with the law. Arbitrary donor-data exports to cloud spreadsheets, public repositories or external generative services are prohibited.
4.4. Access is limited by staff and contractor duties. Measures include secure connections, access controls, secret protection, backups and recovery checks, event recording and incident management. The protection level and particular measures follow the actual system; this policy does not assert certification or accreditation.
5 Retention and termination
5.1. Data is retained to the extent needed for its purpose. Information in primary accounting documents and registers follows accounting retention requirements: at least five years after the reporting year, subject to longer mandatory archival or other periods. Document retention and lawful defence of claims may continue after monthly support ends.
5.2. A saved method is no longer used once its authorization ends. Data needed only for support management is deleted or anonymized after that task and related requests end unless another lawful basis requires retention. Ordinary technical logs are limited to 90 days; information concerning a particular incident is separated and retained as needed to address it.
5.3. On fulfilment of the purpose, withdrawal of consent or discovery of unlawful processing, the Organization stops, blocks, corrects or destroys data as required by law. Withdrawal does not automatically cancel the agreement or accounting duties. If another basis remains, it is explained and further processing is limited to what is necessary.
6 Rights and requests
6.1. Individuals may obtain processing information, seek correction, blocking or destruction where grounds exist, withdraw consent, request termination where provided by law and challenge the operator before Roskomnadzor or a court.
6.2. Requests go to zavod@zelino.ru or the Organization’s address. Before disclosure the Organization verifies the individual or authorized representative and requests only necessary evidence. Information and access are provided within ten working days; a reasoned notice may extend this by no more than five working days. Correction, termination and destruction follow the special periods in Article 21 of Federal Law No. 152-FZ.
6.3. New revisions are published with a number and date. Updating the policy does not create consent to a new purpose, public disclosure or marketing.
7 Optional community
7.1. After a gift, a donor may provide their full name and email or phone for a community invitation. Connecting the bot uses the Telegram user ID, language, random token and invitation and membership events. A profile does not verify the payment-account owner. Gifts are associated with a profile only through a confirmed link or a documented director decision.
7.2. Separate consent covers participation and service contact, not advertising, public naming or publication of gift amounts. Full names, email addresses, phone numbers and gift amounts are not included in bot messages or links. Telegram is optional and processes information under its own rules. The ANO checks applicable data-transfer requirements before activating this channel.
7.3. Profiles are held in the ANO database in Russia until departure or withdrawal of consent. Optional data is erased within 30 days of withdrawal unless another lawful retention basis applies. Contact zavod@zelino.ru or use /stop in the bot. Donation history and required evidence remain for their statutory retention periods; contact details are not copied into immutable financial logs.