Who processes the data
Operator: individual entrepreneur (sole proprietor) Cupworks, taxpayer ID (УНП) уточняется. Registered on уточняется by уточняется. Address: уточняется.
The person responsible for internal control over the processing of personal data is Cupworks. Contact for any question about data processing: info@cupworks.dev.
What data is collected
From the request form, what you enter yourself: name, contact (Telegram or phone), budget, what needs to be done and a description of the task. From the free audit form: your site’s address, a contact (Telegram or email) and, if you write it, what matters most to you.
Automatically during a visit: the page address, the referral source, the ad campaign’s UTM tags, the browser and device type, and a random session ID. The IP address is stored only as an irreversible hash; the address itself is not recorded.
Recordings of actions on the page made by Yandex Metrica (Session Replay, “Webvisor”) and Microsoft Clarity: cursor movement, scrolling, clicks. Form fields are masked during recording, and the text entered in them does not get into the recording.
Why
Data from the form: to answer your request or send the audit, discuss the task and keep up the correspondence about it.
Technical data: to understand which pages and ad campaigns bring in requests, and to tell people from bots. It is not used for mailing lists.
With your consent, the Meta pixel receives the addresses of the pages you viewed and the fact that a request was sent, with the budget you chose, in order to show Cupworks ads and measure their results. Your name, contact and the text of your request are not passed to it.
On what basis
On the basis of your consent, which you give by ticking the box in the form before sending it. Consent is voluntary: without it, you can skip the form and write directly on Telegram or by email.
Legal basis: Law of the Republic of Belarus No. 99-Z of 7 May 2021 “On Personal Data Protection” (Закон Республики Беларусь № 99-З «О защите персональных данных»).
The consent covers collection, systematisation, storage, modification, use, depersonalisation, blocking, provision and deletion of data. Processing is mixed: automated (the site, the database, analytics services) and non-automated, when we read your request and reply to it.
Who receives the data
The content of your request goes to Telegram: the message arrives in the developer’s messenger.
Technical data about visits is processed by web analytics services: Google (Google Tag Manager, Google Analytics), Yandex (Yandex Metrica) and Microsoft (Microsoft Clarity). For advertising, data about visits and sent requests is received by Meta Platforms (the Meta pixel). Each of them has its own data processing policy.
All of the site’s traffic passes through Cloudflare, which protects it from attacks and speeds up loading: it sees the IP address and the address of the page opened.
The site and the database are hosted on servers in Germany; the web analytics services, Meta, Cloudflare and Telegram process data on their own servers outside the Republic of Belarus. This is a cross-border transfer of personal data, and it is carried out on the basis of your consent.
Google, Microsoft, Meta and Cloudflare are located in the USA, Telegram stores data in various countries, and those countries do not provide an adequate level of personal data protection under the legislation of Belarus. The risks are: the laws of those countries apply to the data, their government authorities may gain access to it, and it will be harder to protect your rights in the manner established in Belarus. Ticking the box in the form and clicking “Accept all” in the banner mean consent to such a transfer, taking these risks into account.
The data is not passed or sold to anyone else.
How long it is kept
Requests: up to three years from the date of contact, so that the project’s history can be revisited. Technical data about visits: up to one year.
Consent is valid for as long as the data is kept, or until it is withdrawn. At your request, the data is deleted earlier.
Your rights
You have the right to withdraw your consent; to receive information on which of your data is processed; to demand that it be changed if it is incomplete or inaccurate; to demand that processing stop and the data be deleted; to receive information on the provision of your data to third parties; and to appeal the operator’s actions to the National Personal Data Protection Center of the Republic of Belarus.
To exercise any of these rights, write to info@cupworks.dev. You will receive a reply within the period set by Law No. 99-Z.
How to withdraw consent
By email to info@cupworks.dev with the subject “Withdrawal of consent”. No special form is needed; it is enough to give the contact you left. After withdrawal, processing stops and the data is deleted.
Cookies, analytics and advertising
Analytics and advertising turn on only after you consent. Until you click “Accept all” in the banner at the bottom of the page, Google Tag Manager, Yandex Metrica, Microsoft Clarity and the Meta pixel do not load, and our own counter sends nothing. The form works either way.
After consent, the following appear: a random session ID in browser storage, which links page views, clicks and a request to each other and on its own says nothing about you, and the files set by Google, Yandex, Microsoft and Meta.
You can withdraw consent at any time: the “Cookie settings” button at the bottom of this page brings the banner back. Your choice itself is kept in localStorage under the key cw_consent and is recorded whatever your answer.
Without consent, the site remembers only the landing page, the ad tags and the referral source (sessionStorage, key cw_entry): this record has no ID, is erased when the tab is closed and leaves the browser only together with a request, and after consent also in the visit statistics.