1. General provisions
1.1. This Policy sets out how personal data are processed by individual entrepreneur Viktor Aleksandrovich Shramko (Russian Federation; INN 540446955504, OGRNIP 321547600139524) (the "Operator"). It is drawn up under Russian Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (the "Law") and published under Article 18.1(2) of the Law. Visitors from other countries may also have rights under the law of their country; requests are handled as described in section 7.
1.2. The Policy covers personal data of:
- visitors to swnapple.com and swnapple.ru (Russian version);
- people who contact the Operator about buying apple juice concentrate by the phone numbers, e-mail addresses and messengers listed on these sites.
1.3. Requests about personal data: shramko.va@sibval.com. Postal address: 104 2-ya Rakitnaya St., Novosibirsk, Novosibirsk Region, 630029, Russia.
1.4. The sites present products made by LLC "SIBERIAN WELLNESS-NAMANGAN" (Republic of Uzbekistan). Depending on the delivery terms, the seller may be LLC «Laboratoriya Sovremennogo Zdorovya» (Russia). The specific seller is stated in the commercial offer and the contract.
1.5. The Operator receives enquiries and coordinates the discussion of supplies. The Operator does not act as an agent or representative of the manufacturer or the seller and does not conclude deals on their behalf. The seller of a specific lot is stated in the commercial offer and the supply contract.
2. Processing activities
2.1. Enquiries from individuals and individual entrepreneurs
- Data: name, phone number, company name (if any); in correspondence — e-mail address, messenger user name or number, content of the enquiry.
- Purpose: replying and coordinating the discussion of the supply, including passing on the commercial offer, sending samples (2.4) and preparing the deal with the seller (2.5).
- Legal basis: Article 6(1)(5) of the Law — processing is needed to conclude, at the data subject's initiative, a supply contract to which they will be a party
2.2. Enquiries from representatives of organisations
- Data: as in 2.1, to the extent needed for business communication.
- Purpose: as in 2.1, in respect of the organisation the person represents.
- Legal basis: Article 6(1)(7) of the Law — the Operator's legitimate interest in coordinating the supply discussion with the organisation the person represents, without infringing the data subject's rights and freedoms
2.3. How enquiries are handled
Name, phone and company are entered into a table kept only on the Operator's computer in the Russian Federation; only the Operator has access to it. Correspondence is conducted by e-mail and in WhatsApp and Telegram.
An enquiry is used to reply to it and to coordinate the discussion of the supply. Contacting the Operator is not consent to any other processing, mailings or disclosure to third parties. WhatsApp and Telegram process messages under their own terms, including on servers that may be located outside the Russian Federation. The Operator transfers contact details from an enquiry to the table kept in Russia and deletes the correspondence within the periods in section 3. If you prefer not to use messengers, please contact us by phone or e-mail.
Enquiries are also received on the Operator's instruction by Andrey Kharchenko (Russian Federation): he passes contact details to the Operator and has no access to the table.
2.4. Sending samples
- Who and from where: samples are sent personally by the Operator, only from Russia. No samples have been sent outside the Russian Federation so far; before the first such shipment the Operator will comply with Article 12 of the Law.
- What the carrier receives: only the data needed for delivery: the recipient's full name, phone number, delivery address or the chosen pick-up point.
- Carrier: chosen separately for each shipment; it processes the data under its own terms. Where a particular carrier processes the data depends on that carrier.
- Retention: shipping data are kept with the materials of the related enquiry (section 3).
- Legal basis for passing data to the carrier: Article 6(1)(5) of the Law — processing is needed for the carriage contract under which the sample recipient is the beneficiary; samples are sent at the recipient's request
2.5. Preparing a deal when the seller is LLC «Laboratoriya Sovremennogo Zdorovya»
- When: only if, under the delivery terms stated in the commercial offer, the seller is LLC «Laboratoriya Sovremennogo Zdorovya».
- What is passed on: the leads table is not passed to the seller as such. The buyer's company details needed to prepare the deal are passed on; personal data contained in them — only to the extent necessary and where there is an appropriate legal basis.
- Personal data that may be in the company details: full name of the director or representative; if the buyer is an individual entrepreneur, their full name, INN, OGRNIP and address; phone numbers and e-mail addresses if they appear in the company details.
- Purpose: preparing a deal in which the seller is LLC «Laboratoriya Sovremennogo Zdorovya».
- Legal basis and formalities of the transfer: for a buyer who is an individual entrepreneur: Article 6(1)(5) of the Law (a contract to which they will be a party at their own initiative); for the name and contacts of an organisation's director or representative: Article 6(1)(7) of the Law (legitimate interest in preparing the contract with that organisation). The seller processes the company details as an independent operator — a party to the contract
2.6. Web analytics — only with the visitor's consent
- Service: Yandex Metrica, counter 111487523, on both sites. According to the configuration the counter sends to the browser, Webvisor (session recording) and automatic goals are enabled; the sites also have goals for clicks to Telegram, WhatsApp, phone and e-mail. According to Yandex, Webvisor recordings are kept for 15 days, including the current day.
- When it runs: only after "Accept analytics" is pressed. Until then the Metrica script is not loaded. Silence, scrolling or continuing to browse is not consent.
- Data: identifiers in cookies and browser storage, IP address, browser and device data, pages viewed and referrer, date and time of the visit, actions on the page (clicks, scrolling, cursor movements) and their recording, goal completions.
- Purposes: traffic analysis and measuring the performance of Yandex Direct advertising.
- Legal basis: the visitor's consent (Article 6(1)(1) of the Law) given as a separate document: consent terms.
- Yandex: YANDEX LLC processes these data on the Operator's instruction (Article 6(3) of the Law) under clause 5.4 of the Terms of Use of Yandex Metrica and AppMetrica, version of 7 August 2026. Under the same terms Yandex may also process the data for the purposes of its own Privacy Policy where this is required to use other Yandex services or is provided for by the counter settings. According to Yandex, personal data collected by Metrica are stored on servers in the Russian Federation.
- Identifier exchange: when Metrica runs, the browser calls yandex.ru
(
/an/mapuid/googledctssp/) and is then redirected to cm.g.doubleclick.net (a Google domain), sending service parameters including a matching identifier and — as with any request — its IP address and browser data. According to Yandex, the yuidss cookie on the Yandex domain "stores auxiliary information for synchronising identifiers". hdrc.yandex.net and mdd.yandex.net are also used. According to Yandex support, these are technical addresses used by Metrica and cannot be switched off in the counter settings.
2.7. Web server logs
- Data: IP address, date and time of the request, requested address, response code and size, referrer, browser data. The log is shared by the sites hosted on the server.
- Purpose: operation and security of the sites.
- Legal basis: Article 6(1)(7) of the Law — the Operator's legitimate interest in the operation and security of the sites
- Location: Timeweb Cloud (TAIMVEB.KLAUD LLC) virtual server in Russia, St Petersburg, Dataline data centre (according to the provider). The provider makes daily backups of the server disk and keeps the three latest copies; the logs are included in these copies.
2.8. Google map on the home pages
The home pages of both sites have a Google map. It is loaded only after the visitor presses "Show map"; until then no requests are sent to Google. After the button is pressed the browser loads the map from Google servers (maps.google.com, www.google.com, maps.googleapis.com, places.googleapis.com, maps.gstatic.com, fonts.googleapis.com, fonts.gstatic.com), and Google receives the IP address, browser data and the address of the page. The analytics choice does not affect the map: consenting to Yandex Metrica does not load the map, and declining does not prevent opening it.
2.9. Data kept only in the browser
The chosen site language (key lang) and the analytics choice (key
nat_analytics_consent: choice, consent text version, date and time, random choice number) are
kept in the visitor's browser. The site language is not sent to the Operator. For the choice journal the browser
reports the analytics choice to the Operator's server: time, site, choice, consent text version and the random
choice number — without IP address or browser data (section 3). The choice number is shown to the visitor in
"Analytics settings" and can be used to find the journal entry.
3. Retention
| Data | Purpose | Period starts | Period | Reason |
|---|---|---|---|---|
| Prospective buyers table (leads without a deal): name, phone, company | Replying to the enquiry, coordinating the supply discussion | Last substantive contact with the person | Up to 12 months | The product is made seasonally — one harvest a year; renewed interest usually comes with the next season. |
| Ordinary correspondence on a completed deal (e-mail, messengers) | Coordinating and supporting the supply | Last delivery and final settlement | Up to 12 months | Time for questions about performing the deal. |
| Buyer company details; sample shipping data | Preparing the deal; delivering a sample | As for the related enquiry or deal | Same period as the related enquiry or deal | Kept with the enquiry or deal materials; may contain personal data (2.4, 2.5). |
| Web server logs | Operation and security of the sites | Moment of recording | Up to 15 days on the server (current setting: the current file plus 14 daily archives); up to 3 more days in the provider's daily disk backups (3 copies kept). | Enough to investigate failures over the last two weeks. |
| Webvisor recordings in Yandex Metrica | Analysis of site use | Day of recording | 15 days, including the current day (according to Yandex) | Set by the service. |
| Other data in Yandex Metrica | Traffic analysis and advertising performance | Data received by the counter | Up to 1 year: at least once every 12 months the Operator sets up a new counter and deletes the previous one with all its data | Deleting an individual visitor's data or data for a separate period is technically impossible — only the whole counter. After deletion in the Metrica interface the data can still be restored for up to 90 days and are then deleted irreversibly (according to Yandex). |
| Analytics choice in the visitor's browser | Not asking again, showing the current choice | Moment of the choice | 365 days, then a new choice is required | Kept only in the browser; both acceptance and refusal are kept. |
| Evidence of consent held by the Operator | Proving that consent was obtained (Art. 9(3) of the Law) | Moment of the choice | 27 months | Choice journal on the Operator's server: time, site, choice, consent text version, random choice number; no IP address or browser data. The period covers the consent validity (365 days), retention of collected Metrica data (up to 1 year) and the Yandex recovery window (up to 90 days). Metrica visits are also tagged with the consent text version. |
The analytics consent is valid for 365 days or until withdrawn, if that happens earlier. The validity of the consent, the period for keeping the choice in the browser and the retention of data in Yandex Metrica are different periods.
Retention of documents the Operator is required by law to keep and of materials of an ongoing dispute is determined separately under the applicable requirements; the periods in the table do not apply to them.
Data are deleted before these periods end if the purpose and the ground for keeping them no longer exist, subject to legal requirements to keep certain documents.
4. Disclosure of personal data
4.1. Personal data are disclosed to third parties only in the cases described in section 2 or as required by the law of the Russian Federation. For each disclosure it is checked separately whether it is necessary and on what legal basis it takes place.
4.2. Passing enquirers' contact details to LLC "SIBERIAN WELLNESS-NAMANGAN" (Republic of Uzbekistan) is planned but is not carried out as of this version. Before it starts, the Operator will notify Roskomnadzor under Article 12 of the Law and amend this Policy.
4.3. LLC «Laboratoriya Sovremennogo Zdorovya»: the leads table is not passed to the seller as such. The buyer's company details needed to prepare the deal are passed on; personal data contained in them — only to the extent necessary and where there is an appropriate legal basis (2.5).
4.4. Carriers sending samples receive only the data needed for delivery (2.4).
5. Protection of personal data
- The contact table is kept on the Operator's computer and only the Operator has access; the computer is password-protected and runs antivirus software.
- The sites work over HTTPS only.
- Automatic security updates are enabled on the server; access to server logs is restricted.
6. Rights of the data subject
- to obtain information about the processing of their personal data (Article 14 of the Law);
- to require their personal data to be corrected, blocked or destroyed if incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose;
- to require that processing of their personal data be stopped;
- to withdraw consent;
- to appeal against the Operator's actions to Roskomnadzor (the Russian data protection authority) or to a court.
7. Requests, response times and withdrawal of consent
7.1. Send requests to shramko.va@sibval.com or by post to: 104 2-ya Rakitnaya St., Novosibirsk, Novosibirsk Region, 630029, Russia.
7.2. Time limits depend on the type of request:
| Request or situation | Time limit | Provision of the Law |
|---|---|---|
| Information about processing | 10 working days from receipt; may be extended by no more than 5 working days with a reasoned notice | Art. 14, Art. 20(1) |
| Correcting incomplete, inaccurate or outdated data | 7 working days from receipt of supporting information | Art. 20(3) |
| Destroying data that were unlawfully obtained or are not necessary for the purpose | 7 working days from receipt of supporting information | Art. 20(3) |
| Request to stop processing | 10 working days from receipt; may be extended by no more than 5 working days; except in cases provided for by the Law | Art. 21(5.1) |
| Withdrawal of consent | processing stopped and data destroyed within 30 days of receipt, unless the Law provides otherwise; processing may continue if another legal basis applies | Art. 21(5) |
| Unlawful processing identified | stopped within 3 working days of identification; if it cannot be made lawful — data destroyed within 10 working days | Art. 21(3) |
7.3. Withdrawing analytics consent:
- The "Decline" button in "Analytics settings" at the bottom of any page: the browser remembers the refusal, the running counter is stopped, Metrica cookies and records on this site's domain are deleted and the page reloads; after that Metrica is no longer loaded on this site.
- The button works only in this browser and on this site: swnapple.com and swnapple.ru separately.
- The button does not delete data already sent to Yandex Metrica, nor cookies on Yandex and Google domains (e.g. yandex.ru, doubleclick.net) — you can delete those in your browser settings. You can also opt out of Metrica data collection on all sites with the Yandex Metrica blocker described in the Yandex help.
- Consent can also be withdrawn by writing to shramko.va@sibval.com. After withdrawal the browser no longer sends data to Metrica. Data already collected cannot be deleted separately (according to Yandex): they are deleted together with all data of the counter within the retention period — up to 1 year (section 3 of the Policy).
8. Final provisions
8.1. The Operator may amend this Policy. The current version is published at swnapple.com/privacy/ and (in Russian) swnapple.ru/privacy/. If the versions differ, the Russian text prevails.
8.2. This version takes effect on the date of approval: 30 September 2026.