Personal Data Policy

Last updated: 23 September 2026

This Personal Data Policy supplements our Privacy Policy and provides additional detail on our data processing activities, in accordance with Article 13 and 14 of the EU General Data Protection Regulation (GDPR).

1. Data Controller and Contact

2. Categories of Personal Data

• Identity data: name (if provided).
• Contact data: email address.
• Communication data: content of your message, subject line.
• Technical data: IP address, browser type, device information.
• Usage data: pages visited, time on site.
• Transaction data: donation amount and status (payment details are handled by the payment processor).

3. Purposes and Legal Bases

Purpose	Legal Basis
Responding to contact form inquiries	Performance of a contract (Art. 6(1)(b)) or legitimate interest (Art. 6(1)(f))
Analytics (Google Analytics 4)	Consent (Art. 6(1)(a))
Site security and spam prevention	Legitimate interest (Art. 6(1)(f))
Processing donations	Performance of a contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c))

4. Recipients of Personal Data

• Hosting provider: Beget (Russian Federation).
• Analytics provider: Google LLC (United States).
• Payment processor: Robokassa (for donations).
• Anti-spam services: Akismet (Automattic), WP Armour (honeypot).

5. International Transfers

Where personal data is transferred outside the EEA, we ensure appropriate safeguards:

• United States: Standard Contractual Clauses (SCCs) and supplementary measures.
• Russian Federation: We implement contractual and technical safeguards to protect your data. However, Russia is not covered by an EU adequacy decision and is considered a high-risk destination. By using the Site, you acknowledge this risk.

6. Retention Periods

• Contact form data: 12 months from last interaction.
• Analytics data: 14 months (Google Analytics default).
• Server logs: 30–90 days.
• Donation records: as required by tax and financial laws (typically 5–7 years).

7. Your Rights

Under GDPR, you have the right to:

• Access your personal data and obtain a copy.
• Rectify inaccurate data.
• Erasure (“right to be forgotten”).
• Restrict processing.
• Data portability.
• Object to processing based on legitimate interests.
• Withdraw consent at any time.
• Lodge a complaint with a supervisory authority.

To exercise these rights, contact info@makelifenotsmoke.com. We will respond within 30 days.

8. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects concerning you.

9. Changes to This Policy

We may update this Personal Data Policy. The “Last updated” date indicates the latest revision.

This document is provided for general informational purposes and does not constitute legal advice. You should consult a qualified legal professional for advice specific to your situation.