Gift Mate Personal Data Processing Policy

Last updated: 5 September 2026

This Policy explains what personal data is processed when the giftmate.online website, the @gift_mate_bot bot, the Gift Mate browser extension for Chrome, and related Gift Mate features (the Service) are used, why the data is processed, and what rights users have.

1. Data Controller

The data controller and owner of the Service is Konstantin Nikolaevich Poklonskii (Поклонский Константин Николаевич), an individual applying the Russian special tax regime “Tax on Professional Income” (self-employed/NPD).

For questions about personal data processing, contact support@giftmate.online.

2. Who This Policy Applies To

This Policy applies to website visitors, Service users, and people who contact support. Gift Mate is intended for adults and is not designed for persons under 18 years of age.

3. Data We Process

Depending on the features used, the Service may process:

Gift Mate does not ask users to provide special categories of personal data, including information about health, intimate life, or political or religious beliefs. Do not add such information about yourself or anyone else.

4. Purposes of Processing

Data is processed to:

Data is not used for automated decision-making that produces legal effects for a user or otherwise significantly affects the user's rights.

5. Legal Bases

The principal processing required to create an account and operate Gift Mate is necessary to enter into and perform the Terms of Use to which the user is a party. It is based on paragraph 5 of part 1 of Article 6 of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data.”

Where provided by law, data may also be processed to comply with the controller's legal obligations or protect lawful rights and interests, provided that the user's rights are respected.

The Service does not use a separate personal-data consent or mandatory checkbox for its core operation. Acknowledging this Policy does not constitute consent for any purpose for which the law requires separate consent.

If Gift Mate introduces advertising or marketing messages in the future, they will be sent only after obtaining separate, specific, and voluntary consent that can be withdrawn. Refusing such consent will not restrict access to the Service's core features.

6. How Data Is Processed

Processing may include collection, recording, organisation, accumulation, storage, correction, retrieval, use, disclosure to persons involved in operating the Service, restriction, and deletion. Processing is automated; the controller may also participate when handling support requests.

Gift Mate does not sell personal data.

7. Data Localization

Where Russian law requires localization of personal data of Russian citizens, recording, organisation, accumulation, storage, updating and retrieval are performed using databases located in the Russian Federation.

8. Public Wishlists

A user may make their own wishlist accessible through a public link. That page publishes only:

The user's name is not shown in the page's own text to outsiders: someone who opens the link and is not connected to the owner within the Service sees impersonal wording, and the name is not sent to their browser at all. It appears only for the owner and for users who are already connected to them.

Anyone who receives a public link may view it and share it with others. Do not include information in the title or product cards that you do not want disclosed to an indefinite number of people.

The Service asks search engines not to index such pages and serves them the corresponding directive, but this cannot be guaranteed if the link is posted publicly elsewhere.

The Service has no feature for publishing a close person's wishlist. Names of close persons, event dates, notes, preferences, and gift ideas associated with them are not published through a public wishlist.

9. Information About Other People

A user may save limited information about close persons for personal gift and event planning. The user is responsible for entering that information lawfully, must consider the reasonable expectations of the person concerned, and must not enter excessive or confidential information or special categories of data.

If a person believes information about them is being processed unlawfully, they may contact support@giftmate.online. The controller will review the request and restrict processing or delete the information where grounds exist.

10. Disclosures and Service Providers

Data may be processed by organisations and individuals that provide:

Only the data necessary for the relevant function is provided. These persons process data under a contract, applicable law, or their own policies where they independently determine the purposes of processing. Data may also be disclosed to public authorities where required by law.

Current information about the persons engaged and the nature of disclosures may be requested through the support address.

11. Cookies

The website uses technical cookies and similar session data required for sign-in and continued authentication. Account features cannot operate without them. Gift Mate does not use advertising cookies or third-party analytics trackers.

In addition, an anonymised visitor identifier is stored in the browser (localStorage): a random number generated in the browser itself, unrelated to a name, email address or phone number and used only for the service's own statistics — how many people opened a page and which sections are used. This identifier is created before an account exists, which is why a notice about cookies and similar technologies is shown on the first visit. Clearing the site data in the browser removes the identifier, after which the browser counts as a new visitor.

12. Browser Extension

The Gift Mate extension for Chrome saves a product from a page the user has open to their own wishlist or to gift ideas for someone close to them. It handles data as follows:

The extension's access to the account is limited: it can read the names of the user's close ones and add a wish or an idea. Notes about people, events, chat history and other account data are not available through it. The extension can be disconnected in the profile on the site — the “Активные входы” (Active sign-ins) section — after which its token stops working immediately.

Data obtained through the extension is used only for the Service purposes listed in section 4. It is not sold or transferred to third parties for their own purposes, is not used for purposes unrelated to the extension's single purpose, and is not used to determine creditworthiness or for lending purposes.

13. Retention and Deletion

Account data and user content are retained while the account exists or until the relevant record is deleted by the user.

When an account is deleted, the account and associated data are deleted immediately after the deletion command is carried out and cannot be restored. Gift Mate does not create backups of user data, so deleted data is not retained in backup copies.

De-identified usage statistics — event records without names, texts or contact details — are retained after the account is deleted: these records cannot be traced to an individual user, and deleting them retroactively would distort the Service's historical metrics.

Certain information may be retained only where and for as long as retention is expressly required by law or necessary to address a dispute that has already arisen. Its use is then restricted to that purpose, after which it is deleted.

Technical logs are retained no longer than reasonably necessary for security and troubleshooting, after which they are deleted or anonymised.

14. User Rights

Where provided by law, a user may:

Requests may be sent to support@giftmate.online. To protect data, the controller may ask the requester to verify their identity and connection to the relevant account. A response will be provided within the period required by law.

15. Security

The controller takes necessary and proportionate organisational and technical measures to protect data against unlawful or accidental access, alteration, disclosure, restriction, copying, and deletion. However, no internet service can guarantee absolute security.

The user is responsible for safeguarding their means of account access and should promptly contact support if unauthorised access is suspected.

16. Advertising and Affiliate Links

Gift Mate currently contains no advertising materials and no affiliate links to third-party websites or stores: links to shops are ordinary links without affiliate parameters, and the owner of Gift Mate receives no compensation for them. Should that change, this section will be updated before any such advertising or links appear.

The content of user records is not disclosed to advertisers — neither now nor if advertising is introduced: wishlists, notes, information about close persons and gift history are not used for targeting.

Advertising and marketing communications by email, Telegram, push notifications or other channels are sent only where there is an appropriate lawful basis and, where required by law, separate user consent.

17. Changes to This Policy

This Policy may be updated when the Service or the law changes. The current version is published at https://giftmate.online/privacy and states its revision date. If a change materially affects users' rights, Gift Mate will provide notice by an available and reasonable method.

18. Contacts and Language

Controller: Konstantin Nikolaevich Poklonskii (Поклонский Константин Николаевич), an individual applying the NPD regime.

Email: support@giftmate.online.

Terms of Use: https://giftmate.online/terms.

Russian version: https://giftmate.online/ru/privacy.

This English text is a translation. If the Russian and English versions are interpreted differently, the Russian version prevails, subject to mandatory applicable law.