Consent to Personal Data Processing
Effective date: 27 July 2026
This document sets out the content of the consent given by a data subject to the Operator when submitting an enquiry through the form on jemio.ru, or when contacting the Operator by email or messenger.
Consent is given in accordance with Art. 9 of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (152-FZ) and, for individuals located in the EU/EEA and Türkiye, with regard to Art. 6(1)(a) and Art. 7 of the GDPR (Regulation (EU) 2016/679) and Art. 5(1) of the KVKK (Turkish Law No. 6698).
Applies together with the Personal Data Processing Policy, Cookie Policy, Terms of Use, and the Public Offer Agreement.
1. Data Operator
Full name: Individual Entrepreneur Khamzin Artem Maratovich
TIN: 166019255124 · OGRNIP: 325169000153195
Address: 420075, Kazan, Republic of Tatarstan, 3rd Klenovaya str., 100, Russian Federation
Email for personal data enquiries: hello@jemio.ru (subject line: "Personal Data")
2. How consent is given
2.1. Consent is given by the data subject freely, by their own will and in their own interest, and is specific, informed, and unambiguous.
2.2. Consent is expressed by ticking the "I consent to the processing of personal data" checkbox and then submitting the enquiry form on jemio.ru. The checkbox is not pre-ticked; submitting the form without ticking it is technically impossible.
The enquiry form on the site is embedded in a Yandex Forms frame (on every language version); consent is expressed by submitting that form, and the fields collected correspond to Section 3 of this document. Enquiries submitted through that form reach the Operator via the Yandex Forms service (clause 6.1).
2.3. Sending a message containing personal data and a service enquiry to hello@jemio.ru, studio@jemio.ru, or via Telegram is treated as conduct expressing consent to processing of the transferred data for the purposes set out in Section 4.
2.4. The service is intended exclusively for individuals aged 18 or over acting in a professional (B2B) capacity (Section 2 of the Terms of Use). No separate age confirmation is requested when an enquiry is submitted. The Operator does not knowingly collect personal data of minors and destroys such data if discovered.
2.5. The fact and date of consent are recorded by the Operator together with the content of the enquiry.
3. Personal data covered by this consent
| Category | Data |
|---|---|
| Identification data | name; company or brand name |
| Contact data | email address; phone number; Telegram handle |
| Enquiry data | task description, number of products, desired number of images, link to a website or product listing |
| Files submitted by the data subject | product photographs and other materials (up to 5 files), which may contain images of natural persons as part of the product, trademarks, and logos |
| Technical data | IP address, browser and operating system type, referral URL and UTM parameters, cookie data — to the extent and on the terms set out in the Cookie Policy |
The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, criminal records) and does not request them from the data subject.
4. Purposes of processing
4.1. Reviewing the enquiry and preparing a commercial proposal.
4.2. Conducting business correspondence with the data subject, responding to their requests, and clarifying task parameters.
4.3. Concluding and performing the services agreement on the terms of the Public Offer Agreement, including delivery of the result and acceptance of services.
4.4. Complying with obligations under the law of the Russian Federation (including accounting and tax obligations).
Processing for purposes incompatible with those listed above is not carried out. Personal data is not used for automated decision-making producing legal effects for the data subject, nor for profiling.
5. Processing operations and methods
5.1. The data subject consents to the following operations by the Operator: collection, recording, systematisation, accumulation, storage, updating (renewal, alteration), retrieval, use, transfer (provision, access) to the extent set out in Section 6, anonymisation, blocking, deletion, and destruction of personal data.
5.2. Processing is carried out by mixed means — with and without the use of automation.
5.3. The Operator does not disseminate personal data, i.e. does not disclose it to an indefinite range of persons. Separate consent to dissemination of personal data (Art. 10.1 of 152-FZ) is not given by this document and is not requested by the Operator.
6. Consent to transfer to third parties and cross-border transfer
6.1. The data subject consents to the transfer of their personal data to the following categories of recipients, solely to the extent necessary for the purposes in Section 4:
| Recipient | Data transferred | Purpose |
|---|---|---|
| Yandex LLC (Yandex Forms) | content of an enquiry submitted through the form on the site | receipt and storage of the enquiry in the service whose frame hosts the form |
| Telegram Messenger Inc. (bot @jemio_studio_bot) | enquiry content: name, company, contact data, task description, attached files | delivery of the enquiry notification to the Operator and subsequent correspondence |
| Yandex LLC (Yandex Metrica) | technical and analytics data, cookie data | website analytics — on the basis of separate cookie consent |
| Payment agent (acquiring) | payer details | acceptance and processing of payments |
| External automated image generation and processing services | product images only, submitted by the data subject for task performance, without contact or identification data | provision of services under the Public Offer Agreement |
6.2. An up-to-date named list of external services engaged by the Operator as processors (sub-processors) is provided on written request to hello@jemio.ru.
6.3. Cross-border transfer. The data subject is informed of and consents to the fact that, upon submission of the enquiry, data is transferred to the Telegram messenger, whose server infrastructure is located outside the Russian Federation (including in the United Arab Emirates and EU member states), and that external image processing services may be located outside the Russian Federation.
The transfer is carried out on the basis of Art. 12 of 152-FZ; before commencing a cross-border transfer, the Operator satisfies itself that the foreign state provides adequate protection of personal data, or carries out the transfer on the basis of this consent on terms ensuring confidentiality of the data. For data subjects in the EU/EEA, Chapter V of the GDPR applies; for data subjects in Türkiye, Art. 9 of the KVKK applies.
6.4. The data subject may choose not to use the website form and instead send an enquiry directly to studio@jemio.ru — in that case no data is transferred to Telegram.
6.5. The Operator does not sell personal data and does not transfer it to advertising networks or data brokers.
7. Validity period of consent
7.1. Consent is valid from the date it is given until the purposes of processing are achieved or until it is withdrawn by the data subject, and in any event no longer than the retention periods set out in Section 8 of the Personal Data Processing Policy.
7.2. Once the purposes are achieved or the retention period expires, personal data is destroyed or anonymised.
8. Withdrawal of consent
8.1. The data subject may withdraw consent at any time by sending a written request:
- by email: hello@jemio.ru with the subject line "Personal Data";
- content of the request: the data subject's full name, the contact details used when submitting the enquiry, and a statement of withdrawal.
8.2. The Operator ceases processing and destroys the personal data within 30 (thirty) calendar days of receiving the withdrawal, except for data whose processing continues on another lawful basis: performance of a concluded agreement, compliance with statutory requirements (including accounting and tax records), and protection of the Operator's rights and legitimate interests.
8.3. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal (Art. 7(3) GDPR).
8.4. Withdrawal of consent before the services are rendered may make it impossible to review the enquiry and to perform the agreement.
9. Rights of the data subject
The data subject has the right to obtain information about the processing of their data, to request its rectification, blocking or erasure, restriction of processing, data portability, to object to processing, and to lodge a complaint with a supervisory authority. The full list of rights and the procedure for exercising them is set out in Section 9 of the Personal Data Processing Policy.
Supervisory authorities: Roskomnadzor for data subjects in the Russian Federation; the data protection authority of the relevant member state for data subjects in the EU/EEA; the Personal Data Protection Authority (KVKK) for data subjects in Türkiye.
10. Changes to this Consent
The Operator may amend this document. A new version takes effect upon publication at jemio.ru/legal/consent. Changes do not apply to consents given before publication of the new version to the extent they would worsen the data subject's position; in the event of material changes, the Operator requests consent anew.
11. Contacts
Email: hello@jemio.ru (subject: "Personal Data")
Telegram: https://t.me/ahamzin
IE Khamzin A.M., address: 420075, Kazan, Republic of Tatarstan, 3rd Klenovaya str., 100, Russian Federation