PRIVACY POLICY

“Blog, kotoryy smog” («Блог, который смог»)

Last updated: 9 October 2026. The current version is published at https://greywiese.blog/politika

1. Who we are

This Privacy Policy describes how Studio 1804 FZE LLC (the “Company”, “we”, “us”) collects and processes personal data of visitors to https://greywiese.blog (the “Site”) and of clients of the “Blog, kotoryy smog” lifestyle coaching programme (the “Programme”). The Company is a free zone limited liability company licensed by the Sharjah Publishing City Free Zone Authority under license number 4 423 789.01, TRN 105 221 788 000 001, with registered address at Business Center, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates.

This Policy applies to all purchases of participation in the Programme, whether paid in Euro through the Stripe payment system on the Site or in another currency arranged through our support service, as described in the Terms of Service at https://greywiese.blog/oferta.

This Policy is issued under UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”). For Clients resident in the European Economic Area or the United Kingdom, this Policy is also intended to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the UK GDPR. References to legal bases under those regimes are included where relevant.

2. What we collect

We collect personal data that you provide directly and data that is generated automatically when you use the Site and the Programme.

Provided by you:

• Identification data: full name.
• Contact data: email address, phone number (where you choose to provide it), and Telegram username (necessary to grant access to the Programme’s Telegram channel, chats and curator groups).
• Account data: login details for the Company’s closed online platform where the Programme’s episodes and materials are published (the “Platform”).
• Transaction data: amount paid, currency, date of transaction, selected tariff and payment method. We do not receive or store full payment card numbers; these are handled directly by Stripe or by the other payment provider used.
• Programme participation data: practical tasks, answers and other content you submit, links to and content of your blog that you share for feedback, and the feedback provided to you by curators.
• Communications data: the content of emails and messages you exchange with us, our support service and the curators, and your messages in the Programme’s chats.
• Recordings: your image, voice and messages, where you take part in live sessions or online coaching sessions that are recorded and made available to participants of the Programme.

Collected automatically:

• Usage data: progress through the episodes, login timestamps, and access logs to the Platform and the Programme’s Telegram channel and chats.
• Technical data: IP address, browser type, operating system, referring URL, pages visited, cookies and similar identifiers.

Participants under 18 may take part in the Programme only where the purchase is made by a parent or legal guardian. In that case we process the participant’s data on the basis of the consent and instructions of the parent or guardian. We do not process special categories of personal data (such as data revealing racial or ethnic origin, health, religious beliefs or biometric data) in the ordinary course of providing the services. We ask you not to share such data in practical tasks or chats.

3. Why we use your data

We use your personal data for the following purposes:

(a) To deliver the Programme you have purchased. This includes granting and maintaining access to the Platform and the Programme’s Telegram channel, chats and curator groups, providing coaching support and feedback from curators, holding live and coaching sessions, and providing customer support. Legal basis: performance of a contract (PDPL Art. 4(2); GDPR Art. 6(1)(b)).

(b) To process payments. This covers payments made through Stripe and, on request, in other currencies through the support service, as well as keeping accounting records as required by UAE law and the laws of any jurisdiction where we have tax obligations. Legal basis: performance of a contract and legal obligation.

(c) To communicate with you about your participation. This includes purchase confirmations, access details, episode and live session schedules, changes to the schedule, refund requests and complaint handling. Legal basis: performance of a contract.

(d) To send marketing communications about new seasons and products, only if you have opted in. You can withdraw consent at any time by clicking the unsubscribe link in any marketing email or by writing to info@greywiese.blog. Legal basis: consent.

(e) To analyse Site usage, in aggregate and pseudonymous form, to understand how the Site performs and to improve it. Legal basis: legitimate interest. For Site visitors in the EEA or UK, analytics cookies are loaded only with prior consent.

(f) To protect our legal interests. This includes responding to disputes, enforcing the Terms of Service (in particular, preventing unauthorised sharing of access to the Platform), preventing fraud and defending against claims. Legal basis: legitimate interest.

4. Who has access to your data

We share your personal data only with the following categories of recipients, and only to the extent necessary:

• Stripe Inc. and its affiliates, for payment processing. Privacy: stripe.com/privacy.
• Other payment providers, for payments in other currencies arranged through the support service.
• Website and Platform hosting providers, for hosting the Site, the Platform and the materials of the Programme.
• Telegram, for granting and managing access to the Programme’s channel, chats and curator groups.
• Video conferencing and live-streaming services, for holding live sessions and online coaching sessions.
• Email service provider, for sending access details, Programme communications and, where you have opted in, marketing emails.
• Curators (coaches) and moderators engaged by the Company, who have access to the data necessary to provide coaching support and moderate the chats, under confidentiality obligations.
• Accountants, tax advisers and external counsel, under appropriate confidentiality undertakings, where necessary for the running of the business.
• Competent public authorities, where disclosure is required by applicable law.

Please note that messages you post in the Programme’s chats and groups, and your participation in recorded live or group coaching sessions, are visible to other participants of the Programme.

We do not sell your personal data and we do not share it with third parties for their independent marketing purposes.

5. International data transfers

The Company is established in the UAE. Some of our service providers, in particular Stripe, Telegram and hosting providers, process data in jurisdictions outside the UAE.

For Clients in the EEA or the UK, this means that personal data may be transferred outside the EEA or the UK. We rely on the following safeguards:

• transfers to providers covered by an adequacy decision (where applicable);
• Standard Contractual Clauses approved by the European Commission, where the recipient is in a third country without an adequacy decision;
• Stripe’s own GDPR-compliant data transfer framework.

Where a transfer to the UAE is involved, transfers are made on the basis of Standard Contractual Clauses or your explicit consent given at checkout.

6. How long we keep your data

• Transaction and contractual records: 7 years from the end of the financial year in which the transaction occurred, in line with UAE record-keeping requirements.
• Platform account and access data: for the duration of your access period under your tariff, plus 1 year thereafter.
• Programme participation data (practical tasks, feedback, curator communications): for the duration of your access period, plus 1 year thereafter.
• Recordings of live and coaching sessions: for as long as they are available to participants of the Programme, and no longer than the longest access period of the Season.
• Marketing list data: until you withdraw consent or after 3 years of inactivity, whichever occurs first.
• Site analytics data: aggregated and retained for up to 14 months.
• Support communications: for as long as necessary to handle the matter and a further 3 years for evidentiary purposes.

After the relevant retention period expires, data is deleted or anonymised.

7. Your rights

You have the following rights in respect of your personal data:

• Access: to obtain a copy of the data we hold about you.
• Rectification: to have inaccurate or incomplete data corrected.
• Erasure: to request deletion of your data, subject to our legal obligation to retain certain records.
• Restriction: to ask us to limit the processing of your data in certain circumstances.
• Objection: to object to processing carried out on the basis of legitimate interest, including direct marketing.
• Portability: to receive your data in a structured, commonly used, machine-readable format and to have it transmitted to another controller.
• Withdrawal of consent: to withdraw any consent you have given, at any time and without affecting the lawfulness of prior processing.
• Lodging a complaint: with the UAE Data Office under the PDPL or, for EEA/UK residents, with your local supervisory authority.

To exercise any of these rights, write to info@greywiese.blog with the subject “Data request”. We respond within 30 days. We may need to verify your identity before processing the request.

8. Cookies

The Site uses cookies and similar technologies for three purposes:

• Strictly necessary cookies, required for the Site and the Platform to function (session, security, payment routing, Platform authentication). These are loaded without consent.
• Analytics cookies, to measure how visitors use the Site. For visitors in the EEA, UK and other jurisdictions requiring prior consent, these are only loaded after you accept them in the cookie banner.
• Marketing cookies, used by Stripe and other third parties to support fraud prevention and to enable us to attribute traffic. These are loaded only with your consent in the relevant jurisdictions.

You can change your preferences at any time using the cookie settings link in the Site footer or by clearing cookies in your browser.

9. Security

We apply appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include personal access credentials to the Platform, access controls, encryption of data in transit (HTTPS), use of reputable service providers, confidentiality obligations of curators and moderators, and regular review of our processing practices. No system is fully secure. If we become aware of a personal data breach affecting your data, we will notify you and the relevant authority where required by law.

10. Changes to this Policy

We may update this Privacy Policy from time to time. The current version is always available at https://greywiese.blog/politika. Where changes materially affect your rights, we will provide reasonable advance notice by email or by a notice on the Site.

11. Contact

Studio 1804 FZE LLC
SPCFZ License No.: 4 423 789.01
TRN: 105 221 788 000 001
Registered address: Business Center, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
Email: info@greywiese.blog