Privacy Policy

1. General provisions

This Policy describes how Individual Entrepreneur Sergey Nikolaevich Evstigneev, taxpayer number 300435681000 and registration number 320237500089791 (the “Operator”), processes and protects personal data when users visit the Russian or English version of investhai.ru.

It applies to information submitted through forms and to technical data required for website operation, analytics, abuse prevention and reliable delivery of enquiries.

2. Purposes

• responding to an enquiry and providing property consultation;
• selecting and comparing properties and preparing calculations;
• entering into and performing contracts;
• protecting forms against spam, duplicates and technical attacks;
• analysing website performance and enquiry sources;
• sending promotional communications only after separate voluntary consent.

3. Data categories

Data may include name, phone number or messenger identifier in any international format entered by the user, email, comment, budget, preferred location, purchase objective, preferred contact method, and the fact and version of consent.

Technical data may include IP address, approximate IP-based location, page URL and title, referrer, UTM parameters, YCLID/GCLID, Yandex Metrica ClientID, device, browser and operating system data, form completion time, Request ID and Lead ID.

4. Legal grounds

Processing is based on Russian Federal Law No. 152-FZ on Personal Data, the data subject’s consent, steps taken at the user’s request before entering into a contract, and performance of a contract.

5. Recipients and services

The Operator may use JSC Timeweb for hosting, a protected lead gateway, amoCRM, a regional Telegram notification channel and Yandex Metrica. Access and routing are configured with limited permissions and are not published on the website.

Any transfer, including a cross-border transfer, is made only where a valid legal basis exists and applicable legal requirements have been met. Passwords, tokens and access keys are not embedded in public website code.

6. Retention

Enquiry data is retained until the processing purposes, contractual obligations and applicable limitation periods have been satisfied, normally no longer than three years after the last substantive interaction unless law or contract requires a longer period. Technical logs and anti-fraud data may be retained for shorter periods under internal rules.

7. Security

• role-based access and multi-factor protection;
• encrypted connections and secret storage outside the public directory;
• idempotency, safe error logging and backups;
• masking phone numbers and IP addresses in Telegram while retaining full values in the trusted gateway and CRM;
• access reviews and processor controls.

8. Cookies and analytics

Essential technologies are used to operate the website and submit enquiries. Yandex Metrica and other non-essential analytics systems load only after the user makes a choice in the analytics settings panel. The choice can be changed through the footer link. Declining analytics does not prevent an enquiry from being submitted.

9. Your rights

You may request information, correction, restriction or deletion of data, withdraw consent and challenge the Operator’s actions. Send requests to info@kvmsochi.ru.

10. Operator details

Individual Entrepreneur Sergey Nikolaevich Evstigneev
Taxpayer number: 300435681000
Registration number: 320237500089791
Address: 79 Teplichnaya Street, Building 1, Apartment 65, Sochi, Krasnodar Region, 354004, Russian Federation
Email: info@kvmsochi.ru
Phone: +66-99-999-66-93

11. Changes

A new version takes effect when published on investhai.ru. The Russian version prevails; the English version is provided for convenience.