Translation notice. This page is an English translation of the Russian-language document for users’ convenience. The Russian text is the controlling version. If the texts differ, the Russian version applies.
FLProg Club Personal Data Processing Policy
Revision dated 02 October 2026
1. General provisions
1.1. This Personal Data Processing Policy (the “Policy”) defines the procedure and conditions for processing personal data of users of the FLProg Club website located at https://flprog.club, as well as related software interfaces and service functions of FLProg Club.
1.2. The personal data operator is Individual Entrepreneur Глушенко Сергей Викторович, TIN (ИНН) 301709153180, Primary State Registration Number (ОГРНИП) 324300000053391, hereinafter referred to as the “Operator”.
1.3. This Policy applies when visiting FLProg Club, using a User account, contacting support, downloading software files and resources, and when FLProg software interacts with FLProg Club services where such interaction is associated with a specific User.
1.4. As of the date this Policy is approved, FLProg Club is a free information resource. Paid services and educational services are not provided under this revision of the Policy. Informational and, where applicable, informational and advertising e-mails are sent only to Users who have separately subscribed to the relevant thematic mailing.
1.5. The Operator processes only the personal data necessary for the stated processing purposes and does not process personal data in a manner incompatible with the purposes for which it was collected.
1.6. This Policy applies to website visitors, registered FLProg Club Users, and persons contacting the Operator through FLProg Club communication and technical-support tools.
2. Legal grounds for personal data processing
2.1. Personal data is processed in accordance with the laws of the Russian Federation, including Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
2.2. Depending on the purpose and nature of processing, the legal grounds for personal data processing include:
- the data subject’s consent;
- the need to enter into or perform the User Agreement or other agreements to which the User is a party or beneficiary;
- the need to comply with obligations established by the laws of the Russian Federation;
- exercise of the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the personal data subject are not thereby violated.
2.3. Where the law requires User consent for particular processing, such consent is requested separately from the User Agreement and other documents.
2.4. The User may choose not to provide optional personal data where it is not required to use the relevant FLProg Club function.
2.5. Failure to provide data objectively required to create an account, authenticate, or perform a function requested by the User may make the relevant function unavailable.
3. Procedure and methods of personal data processing
3.1. The Operator processes personal data using information systems and automated means and, where necessary, with the participation of authorized persons of the Operator.
3.2. Processing may include collection, recording, organization, accumulation, storage, clarification (updating or modification), retrieval, use, granting access, anonymization or pseudonymization, blocking, deletion, and destruction of personal data.
3.3. Access to personal data is granted only to persons who require such access to administer FLProg Club, provide technical support, ensure security, and perform other duties of the Operator.
3.4. The Operator may entrust personal data processing to persons that provide server infrastructure, backup services, e-mail delivery, and other technical maintenance of FLProg Club. Such processing is performed only to the extent necessary for the relevant purpose, under an agreement or other instruction permitted by law, and subject to confidentiality and security requirements.
3.5. To organize thematic e-mail mailings, the Operator uses the Unisender service provided by Unisender SMART LLC (ООО «Юнисендер СМАРТ»), PSRN (ОГРН) 1227700213180, TIN (ИНН) 9731091240, which processes subscriber data on behalf of the Operator. When a User subscribes, only the data necessary to maintain the selected subscription and deliver messages is transferred to the service: e-mail address, display name or login, association with the selected mailing topic, and a technical identifier for managing unsubscribe requests.
3.6. To process User requests and maintain official e-mail correspondence, the Operator uses Yandex 360 for Business, including the support@flprog.club mailbox. In such correspondence, the service may process the sender’s e-mail address, the name provided by the sender, the subject and content of the message, attachments, and technical data required for e-mail delivery and storage. Personal data received from the Operator in connection with use of the service is processed by Yandex on the Operator’s instructions in accordance with the service terms and the applicable data processing agreement. Processing is performed using databases located in the Russian Federation.
3.7. The main FLProg Club information system and the User database are hosted in Moscow, Russian Federation.
3.8. Backups of the information system are created to enable restoration of FLProg Club operation. Personal data contained in backups is subject to the same confidentiality, security, and localization requirements as data in the production information system.
3.9. When collecting personal data of citizens of the Russian Federation, recording, systematization, accumulation, storage, clarification, and retrieval of such data are performed using databases located in the Russian Federation.
3.10. The Operator does not perform cross-border transfer of personal data processed within FLProg Club.
4. Purposes of personal data processing
4.1. The Operator processes personal data for the following purposes:
- creating and maintaining a FLProg Club User account;
- identifying and authenticating the User;
- providing access to information materials, software files, and other FLProg Club functions available to the User;
- supporting interaction between installed FLProg software and other FLProg ecosystem components and FLProg Club, including authorization, determination of the permitted access level, and obtaining information about available versions, updates, distributions, and targeted deliveries;
- processing User requests and providing technical support;
- maintaining thematic subscriptions selected by the User and sending informational and, where applicable, informational and advertising e-mails where separate consent has been provided;
- ensuring the operability and security of FLProg Club, protecting accounts, detecting errors, investigating technical incidents, and preventing abuse;
- generating technical statistics on website operation and downloads, including approximate geographic statistics;
- complying with obligations established by the laws of the Russian Federation.
5. Categories and list of personal data processed
5.1. Depending on the FLProg Club functions used by the User, the Operator may process the following information:
- User login;
- display name or pseudonym;
- internal pseudonym, if used;
- e-mail address, if voluntarily provided by the User in the profile;
- telephone number, if voluntarily provided by the User in the profile;
- internal account identifier;
- information about roles, access rights, and permissions granted to the User.
5.2. For identification and authentication, a protected representation of the password, User session identifiers, authorization tokens, and other technical identifiers necessary to confirm the User’s authority may be processed.
5.3. When FLProg and other ecosystem components interact with FLProg Club, information about the software and its version, service pack, installation type, operating system, User access level, and other technical parameters necessary to perform the relevant request may be processed.
5.4. When the website and software interfaces are used, the IP address, browser or client software information, User-Agent, interface language, date and time of access, information about the requested function or resource, the technical result of the request, and other service information necessary for operation and protection of the system may be processed automatically.
5.5. Cookies, session identifiers, and browser local-storage data may be used for sign-in, maintaining the User session, storing the selected language, and other technical settings. Their use is additionally described in Section 6 of this Policy.
5.6. For download statistics, the User’s approximate geographic location at the country, region, and city level may be determined locally from the IP address. A pseudonymous visitor identifier calculated from the IP address using a one-way cryptographic transformation may be generated for statistical accounting. FLProg Club does not determine the device’s actual location using GPS or other precise positioning systems.
5.7. When the User contacts support, the Operator may process the request text, files attached by the User, account information, and other data that the User independently provides in connection with the request.
5.8. When software files are downloaded and update mechanisms are used, information about the downloaded or requested resource, software version, time of the operation, result of the operation, and related technical identifiers may be processed.
5.9. When a thematic subscription is created, information about the selected mailing topic, subscription and address-confirmation status, date and source of granting or withdrawing consent, consent version, and technical identifiers necessary to confirm the subscription and unsubscribe is additionally processed.
5.10. The Operator does not specifically request information about Users’ race or nationality, political views, religious or philosophical beliefs, health, intimate life, or biometric personal data and does not deliberately process such data.
6. Cookies and browser local storage
6.1. FLProg Club uses cookies and browser local storage that are necessary for website operation, User authentication, storing the selected interface language, and certain User settings.
6.2. In particular, the following may be used:
- User session identifier;
- a technical identifier that allows User authorization to persist between visits to the website;
- information about the selected interface language;
- browser local-storage data required for technical interface settings and website notifications.
6.3. A technical identifier for persistent authorization may be stored on the User’s device for up to one year unless deleted earlier when the User signs out, the relevant session is terminated, or browser data is cleared.
6.4. Information about the selected interface language may be stored on the User’s device for up to one year.
6.5. Optional web analytics are enabled only after the User selects “Accept analytics”. Before such consent is given, FLProg Club does not load Yandex Metrica or Google Analytics and does not send website-visit data to these services. The User may choose “Necessary only” and can later change this choice using the “Cookie settings” button.
6.6. FLProg Club uses Yandex Metrica to analyze website traffic and improve the website. After the User gives consent, the service may process information about website visits and technical browser/device data, including IP address, cookies and browser identifiers, the URL and source of the visited page, the date and time of the visit, browser and operating-system information, and information about the User’s interaction with page elements.
6.7. Yandex Metrica features used on FLProg Club include Webvisor, click maps, scroll maps, and form analytics. Webvisor makes it possible to reproduce a visitor’s actions on website pages. The Operator does not use these tools for the intentional collection of passwords, payment information, or other information that is not required for web analytics. Yandex Metrica is provided by Yandex LLC and processes relevant data in accordance with the terms of use of the service.
6.8. After the User gives consent, FLProg Club also uses Google Analytics to obtain aggregated statistics about traffic, referral sources, page views, and visitor interaction with the website. Google Analytics may use analytics cookies and other technical identifiers. FLProg Club uses Google Consent Mode: analytics storage is enabled only after the User gives consent, while storage and signals related to advertising and personalized advertising remain denied on the website.
6.9. FLProg Club does not use web-analytics data to create advertising profiles of FLProg Club Users for the purpose of tracking their activity on third-party websites.
6.10. The User may restrict or prohibit cookies using browser settings. In that case, some website functions, including authorization, retention of User settings, and web-analytics functionality, may operate incorrectly or become unavailable.
7. Retention periods, termination of processing, and deletion of personal data
7.1. Personal data is retained no longer than required by the purposes for which it is processed unless another retention period is established by the laws of the Russian Federation or by an agreement with the User.
7.2. User account data is processed for the period during which the account exists and the User uses FLProg Club.
7.3. When the User stops using FLProg Club, the User may request that the Operator stop processing and delete the User’s personal data.
7.4. Once a processing purpose has been achieved, processing of the relevant personal data is terminated and the data is destroyed or anonymized within the time limits provided by the laws of the Russian Federation unless another lawful basis for continued processing exists.
7.5. If consent is withdrawn, data that was processed solely on the basis of that consent will cease to be processed and will be destroyed within the period established by law unless another lawful basis for further processing exists.
7.6. Withdrawal of consent for one processing purpose does not necessarily require deletion of the data if its further processing is necessary on another basis provided by law.
7.7. Technical logs, security-event information, and activity data necessary to ensure FLProg Club security and investigate technical incidents are retained for the period necessary for the relevant purpose and then deleted or anonymized.
7.8. Detailed download statistics and geographic-statistics data are retained for a period established by the Operator and then deleted or converted into anonymized aggregated statistics if detailed data is no longer required.
7.9. Information about granting, confirming, and withdrawing consent to thematic mailings may be retained for the period necessary to confirm the lawfulness of processing, comply with the Operator’s obligations, and protect its rights and legitimate interests.
7.10. Personal data may temporarily remain in information-system backups after deletion from the production database until the established backup rotation cycle is completed. At the end of that cycle, the copies are automatically replaced with newer ones.
7.11. If data cannot be destroyed within the prescribed period, the Operator blocks the data and destroys it within the period prescribed by the laws of the Russian Federation.
8. Protection of personal data
8.1. The Operator takes the necessary legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions.
8.2. Such measures include access-right separation in information systems, identification and authentication of Users and administrative personnel, restriction of administrative access, protected network connections when using the website, data backup, monitoring of information-system status, installation of software updates, logging of significant technical events, and measures to prevent unauthorized access.
8.3. User passwords must not be stored in a form that makes it possible to restore their original value. A cryptographically protected representation is used to verify a password.
8.4. Access to personal data is granted only to persons who require such access to perform their functions.
8.5. The Operator takes measures to detect incidents in a timely manner, restore the operability of information systems, and prevent recurrence of identified violations.
9. User rights
9.1. The User has the right to obtain information about whether the Operator holds and processes personal data relating to the User.
9.2. The User has the right to request correction of personal data if it is incomplete, inaccurate, or outdated.
9.3. The User has the right to request blocking or destruction of personal data if it was obtained unlawfully, is processed unlawfully, or is no longer required for the stated processing purposes.
9.4. The User has the right to withdraw previously granted consent to personal data processing.
9.5. The User has the right to request termination of processing of the User’s personal data in the cases and according to the procedure provided by the laws of the Russian Federation.
9.6. The User has the right to obtain information about the purposes, legal grounds, and methods of processing, the composition of the personal data processed, processing and retention periods, and the persons to whom personal data is provided in cases provided by law.
9.7. The User has the right to challenge the Operator’s actions or omissions before Roskomnadzor or in court.
10. Procedure for contacting the Operator
10.1. For questions concerning personal data processing, the User may contact the Operator at support@flprog.club.
10.2. To identify the User and fulfill the request, it is recommended that the request include the FLProg Club account login, the substance of the request, and the preferred method for receiving a response.
10.3. The Operator may request additional information necessary to reliably identify the applicant if, without it, the Operator cannot verify that the request was submitted by the personal data subject or the subject’s legal representative.
10.4. Requests are considered within the time limits established by the laws of the Russian Federation.
11. Actions in the event of a personal data security incident
11.1. If unlawful or accidental transfer, provision, or access to personal data is detected, the Operator takes measures to stop the violation, remedy its consequences, and prevent recurrence.
11.2. In the cases provided by the laws of the Russian Federation, the Operator notifies Roskomnadzor of the incident and conducts an internal investigation.
11.3. Information about incidents and measures taken may be retained to the extent and for the period necessary to comply with legal requirements, investigate the circumstances of the event, and ensure information-system security.
12. Final provisions and Operator information
12.1. This Policy is a publicly available document and is published on FLProg Club.
12.2. The Operator may amend this Policy when the laws of the Russian Federation, FLProg Club functionality, the composition of processed data, or the processing procedure changes.
12.3. A new revision of the Policy takes effect on the date it is published on the website unless another effective date is stated directly in the new revision.
12.4. Previous revisions of the Policy may be retained by the Operator in an archive.