Privacy Policy / Политика обработки персональных данных

1. Controller and contact

Controller: ENTSPACE CONSULTANCIES LLC, Commercial License No. 1183752, address: BJ36, BLOCK J PSAIH SHUAIB, United Arab Emirates, TRN: 104337344600003, tel.: +971507850607, e-mail: docs@entspace.com. Data Protection Officer: not appointed. Privacy requests: docs@entspace.com.

2. Services

The Controller sells and organizes access to the online strategic program «Triptych Shchedrovitsky V · 2026 — Government of the Future», archive recordings for 2022-2025 cycles and related community, materials and support services. The program is delivered online in Russian.

3. Categories of personal data

• •contact data: name, e-mail, phone, Telegram;
• •professional data voluntarily provided: company, role, team participation details;
• •transaction data: tier, archive item, order number, payment method, currency, amount, Stripe session ID, payment status;
• •service data: access records, support requests, participation status and communication history;
• •technical and analytics data: IP address, user-agent, cookies, analytics events and consent logs.

4. Legal bases and purposes

• •consent for personal data processing where consent is required or requested;
• •contract performance: registration, payment, access to sessions, recordings and materials, support and refunds;
• •legal obligations: accounting, tax, payment, consumer protection, compliance and recordkeeping;
• •legitimate operational interests where permitted: service security, fraud prevention, internal analytics, protection of rights;
• •direct marketing only with separate consent or where otherwise permitted by applicable law.

5. Recipients and processors

Personal data may be processed by Stripe, banks and payment processors, hosting and infrastructure providers, communication services, analytics providers, CRM and spreadsheet tools, accountants, lawyers, contractors supporting the program and EntSpace platform operators. Processors receive only the data necessary for their tasks.

6. Cross-border transfers

Data may be transferred outside the UAE, including to jurisdictions where payment, hosting, analytics, communication or support providers operate. Transfers are made where there is an adequate protection level, appropriate contractual safeguards, explicit consent, contract necessity or another legal basis recognized by applicable UAE law.

7. Retention

• •order and payment records: for the period required by accounting, tax, payment and limitation rules;
• •program access and support records: for the duration of access and a reasonable support period afterwards;
• •intro session applications and communications: until the purpose is fulfilled or earlier deletion is requested, unless retention is required for legal claims;
• •technical logs and cookies: according to website settings and provider retention schedules.

8. Data subject rights

Subject to applicable UAE law, the user may request information about processing, access to personal data, data portability where technically feasible, correction, completion, erasure, restriction or stopping of processing, withdrawal of consent and objection to direct marketing or automated decisions that have legal or similar effects.

9. Security

The Controller applies organizational and technical measures proportionate to the nature of the data and risks: access control, confidentiality obligations, secure payment pages, logging, backup, processor due diligence and procedures for responding to privacy requests and incidents.

10. Updates

The Controller may update this policy due to changes in law, providers, product mechanics or processing practices. The current version is published on the website with its revision date.