Privacy and Personal Data Policy

1. Operator and contact

The website and personal data operator is SAN PORTO LLC (ООО «САН ПОРТО»), INN 7730285464, OGRN 1227700519694, address: 35 Kutuzovsky Prospekt, floor 1, premises XXIX, room 2, Moscow, 121165, Russia. Russian law, including Federal Law No. 152-FZ of 27 July 2006 on Personal Data, applies to processing. For privacy questions and rights requests, contact info@sanporto.com. For partnerships and licensing, use gela@sanporto.com.

2. Enquiries through the form and email

The partnership form asks for your name and email for a reply, an optional phone number, project, topic and message. After you tick the separate consent box and press Send, the information is submitted to the SAN PORTO server, which forwards the enquiry through its email system to info@sanporto.com. The email includes the consent statement, version 2026-10-21-contact-v2 and a link to the relevant document.

The information is used to review your proposal, respond, discuss licensing or partnerships and conduct related negotiations. You may voluntarily include your company and role in the message where relevant. Do not provide passport details, health information, other special categories, payment details or unnecessary information about other people. Submitting the form does not subscribe you to mailings. You can instead email info@sanporto.com directly.

3. Separate choices and legal grounds

Enquiries have a separate personal data consent. Optional analytics has a different consent. Neither is bundled with acceptance of this policy or subscribes you to advertising. Where information is necessary to enter a contract at your request or comply with law, the applicable independent legal ground may apply.

4. Technical information and analytics

Delivering pages and receiving enquiries requires processing network requests, including IP address, request time, page address and browser information. Website operation, form protection and email delivery may generate ordinary technical logs. This information is distinct from optional website analytics.

Yandex Metrica, counter 101434061, is enabled only after you choose to allow analytics. It may receive IP addresses, cookie identifiers, browser and device characteristics, page visits and referral information. The integration uses URLs without query parameters or fragments and does not transmit form contents or user parameters. Session Replay, click maps and link tracking are disabled; forms are excluded from analytics. The website does not transmit contact details for advertising mailings.

If you decline, analytics is not enabled and you can still view projects and submit an enquiry. See the Cookie Policy for details and controls.

5. Access and other services

Enquiries are intended for staff who need access to answer you and discuss your proposal. The SAN PORTO server receives the form, and the email system handles delivery and subsequent correspondence. We do not publish your correspondence or use this consent to make personal data publicly available.

Google reCAPTCHA v3 protects the form against automated submissions. It loads only after you tick the separate enquiry consent box and press Send. During the check, Google may receive your IP address, browser, device and verification interaction information, service identifiers and cookies. Processing terms: Google Privacy Policy, Google Terms of Service. Form verification does not enable Yandex Metrica; you may use the published email address instead of the form.

When analytics is permitted, processing is entrusted to Yandex LLC, 16 Lva Tolstogo Street, Moscow, 119021, Russia. Service documents: Yandex Privacy Policy, Yandex Metrica: data collected. Following a link to SMISH, ROLCE, Shish & Twist, an app store or another external resource opens an independent website with its own rules.

The SMISH app video in the Games section is hosted on Platformcraft; your browser contacts video.platformcraft.ru and hlsvod.platformcraft.ru to deliver it. Clips from the ROLCE catalogue are delivered through the zxtwxjikl6.a.trbcdn.net CDN. Clip posters are hosted on sanporto.com. The video stream loads only after you click its poster or Play button, rather than when you open the page. When a video loads, the relevant servers receive your IP address and technical request information. Playing a video does not enable Yandex Metrica or change your analytics choice.

6. Retention and ending processing

The enquiry and subsequent correspondence are processed in the operator’s email system for as long as necessary to review it, negotiate and meet related legal obligations. Retention depends on the purpose, correspondence, contract and applicable law. Technical records support operation and protection of the website and email system; this policy does not assign one fixed period to every such record. Information is deleted or de-identified when no longer required, unless a separate legal ground permits further retention.

Your analytics choice is recognised in the browser for up to 180 days. This is a website preference period, not a common retention period for enquiries, technical logs or external-service data. See the Cookie Policy for cookie information.

7. Your rights and withdrawal

You may request information about processing of data relating to you, correction, restriction, deletion or cessation of processing where applicable. Send your request or withdrawal to info@sanporto.com, with enough information to associate the request with you. Do not send a passport or unnecessary documents unless needed. Requests are considered within the periods required by applicable law.

You may also withdraw analytics consent through “Cookie settings” in the footer by declining analytics. This stops further collection on the site; contact the operator about previously processed information. You may complain to Roskomnadzor or seek judicial protection.

8. Protection and changes

Access is restricted to staff who need the information to handle the enquiry. The operator maintains confidentiality and applies necessary legal, organisational and technical safeguards against unauthorised access, alteration and disclosure. It is updated if the form, analytics or service providers change; a material change of purpose requires a separate assessment of legal grounds.

Related documents: Privacy and Personal Data Policy, Enquiry Consent, Cookie Policy, Analytics Consent.