Revision date: 18 October 2026
The Russian-language version of this Policy is the legally binding version. This English translation is provided for information only.
1.1. This Policy sets out how the self-employed person (professional income tax payer) Margarita Evgenievna Polyakova (INN 771821200326) (the “Operator”) processes the personal data of users of the CLCTD.VINU service at https://vinu.clctd.pro and the VINU mobile apps (the “Site”).
1.2. The Policy is based on clause 2, part 1, Art. 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (“152-FZ”) and is published at https://vinu.clctd.pro/privacy-policy.
1.3. The Policy applies only to the Site. Processing in the CLCTD service (https://clctd.pro) is governed by the separate policy published on the CLCTD website.
1.4. The Operator processes data only for the stated purposes, does not disclose it without consent unless required by law, protects it, answers users’ requests and provides users with free access to their data. Users have the right to full information about processing, to correction, blocking or deletion of their data, to withdraw consent and to protect their rights before the competent authority or in court.
The Constitution and Civil Code of the RF; Federal Laws No. 149-FZ, No. 152-FZ and No. 422-FZ; Government Decree No. 1119 of 01.11.2012 and FSTEC Order No. 21 of 18.02.2013; the User’s consent; the Public Offer.
Passwords are stored only as an irreversible cryptographic hash (argon2id). Biometric and special categories of personal data are not processed. Wine, bottle, purchase, storage, notes, scores and photos entered by the User are user content.
5.1. Processing is automated, non-automated and mixed. Actions: collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer (to YooKassa to the extent needed for payments), blocking, deletion, destruction.
5.2. Data is processed with the User’s consent, given freely, except where the law allows processing without consent. Consent may be withdrawn by writing to support@clctd.pro or by deleting the account.
5.3. CLCTD and VINU belong to the same Operator. If the User signs in to VINU with the email and password of a CLCTD account, the Operator checks them against the CLCTD account and obtains from CLCTD the name, user ID and plan details — solely for sign-in and to determine the right to free access. The plan is re-checked at every sign-in. VINU cellar data is not transferred to CLCTD.
5.4. Data is stored in Yandex Cloud (Russian Federation) — a virtual machine, a managed database and S3-compatible object storage; backups are encrypted. Personal data is kept for the life of the account and up to 12 months after its deletion or the last payment, unless the law or the agreement provides otherwise. No cross-border transfer is made. Data is not disclosed to an indefinite number of persons.
5.5. In case of unlawful or accidental transfer of personal data, the Operator notifies within 24 hours of discovery and takes measures together with the User to prevent negative consequences.
Inaccurate data is corrected within 7 business days; unlawful processing is stopped within 3 business days, and data is destroyed within 10 business days if lawfulness cannot be ensured; on achieving the purpose or withdrawal of consent, data is destroyed within 30 days. Requests sent to support@clctd.pro are answered within 10 business days.
The Operator is liable under RF law. Disputes are resolved under RF law. The Operator may amend this Policy; a new revision takes effect upon publication. Questions: support@clctd.pro.
Self-employed (professional income tax payer)
Name: Margarita Evgenievna Polyakova
INN: 771821200326
E-mail: support@clctd.pro
Website: https://vinu.clctd.pro
Moscow