Documents
Personal Data Processing Policy
1. Scope
This website represents the Autonomous Non-profit Organisation “Center for International Strategic Initiatives” (TIN 7719484057, PSRN 1187700021563). This Policy covers personal data in inquiries sent to info@centrisi.com and the technical processing directly connected with that channel.
It does not govern all data processed by CISI and does not appoint the individual named below as controller for all organisational data. Under the confirmed procedure, these emails are not passed to CISI, its management or partners for review.
2. Controller for email inquiries
Khadzhimurat Sakhratulaevich Azimov, an individual who reviews inquiries independently and acts in his own name.
- inquiry channel: info@centrisi.com;
- personal data questions: h-murad93@ya.ru;
- controller's postal address: 1 Sergeya Makeeva Street, Apartment 79, Moscow, Russian Federation.
3. Data subjects and data
Data subjects are senders and their representatives. Depending on what is actually included in correspondence, data may comprise a name, email address, telephone number, role and organisation, the inquiry and attachments, date and time, technical email headers and the history of replies.
The controller does not request passport details, health information, biometric data or other people's data through this channel. Do not send such information without necessity and an appropriate legal basis.
4. Purposes and legal bases
Data is used to receive and review an inquiry, prepare a reply, arrange subsequent contact, secure correspondence and protect the legitimate rights and interests of the controller and sender.
Depending on the inquiry, processing is based on steps taken at the data subject's request before entering into or performing a contract; legitimate interests provided that the subject's rights and freedoms are respected; or compliance with legal obligations. Specific consent is used only where an additional activity actually relies on consent. Visiting the website or sending any email is not treated as blanket consent to all processing.
5. Processing operations
Operations may include collection, recording, organisation, accumulation, storage, updating, retrieval, use, restriction, deletion and destruction, by automated and non-automated means. No decision producing legal effects for an applicant is made solely by automated processing.
6. Technical providers and external services
- JSC Timeweb provides website hosting and email infrastructure. To operate and secure these services, it may technically process email content and metadata, IP addresses, request timestamps, browser details and security logs.
- Google Maps is not loaded before the visitor makes a choice. If “Load map” is selected, the browser contacts Google directly; Google may receive the IP address, page URL, browser and device data and may use cookies or local storage. This may involve processing outside Russia. The map is not required to send an inquiry.
- Telegram and WhatsApp links open external platforms only when selected, and their own policies apply independently.
Data may be disclosed to public authorities only where and as required by law. Personal data is not sold.
7. Localisation and retention
Initial recording and storage of incoming email uses Timeweb infrastructure in Russia. The domain's MX records route email through Timeweb. The interactive map is a separate optional service and loads only after the visitor's choice.
| Category | Period | Deletion |
|---|---|---|
| Correspondence not followed by a contract or dispute | Until review is complete and 12 months after the last substantive message | Delete from the active mailbox; final removal after the applicable backup cycle |
| Contract, claim or rights-related correspondence | For the period required by law or necessary to perform the contract and protect rights | Delete when that period ends unless another lawful ground applies |
| Hosting and security logs | Up to 180 days under the provider's current service | Provider rotation |
| Google Maps loading preference | 180 days on the visitor's device | On expiry, preference change or clearing browser storage |
| Website file backups | 30 days | Provider rotation; correspondence is not stored on the website |
These periods apply subject to mandatory retention requirements, applicable law and the provider's actual backup cycle.
8. Data subject rights
Data subjects may request information, correction, restriction or deletion, object to processing and complain to the competent authority or a court. Requests may be sent to h-murad93@ya.ru or to the controller's postal address. To locate correspondence, state the sender address and approximate date; information needed to verify identity and authority may be requested.
Responses are provided within statutory periods: generally 10 working days, which may be extended by no more than 5 working days with a reasoned notice.
9. Security and deletion
Access to correspondence is restricted by accounts and passwords; protected connections, spam filtering and security logs are used. Once the purpose is achieved or a valid request is received, processing stops and data is deleted or destroyed within statutory periods unless another lawful basis requires retention.
10. Policy updates
The current version is published at https://centrisi.com/en/privacy.html. Version date: 5 September 2026.