Perezagruzka · Daniel Kamyshan

Privacy Policy

Updated: 2026-09-05

1. Data Controller

Controller: Danylo Kamyshan, acting as a natural person and resident of Japan. Address: 〒123-0864, Tokyo-to, Adachi-ku, Shikahama 2-40-4, #105 E-mail for personal-data requests: legal@danielviktorovich.com E-mail for general enquiries: hello@danielviktorovich.com Phone: +81-80-5802-9332 Website: https://pay.danielviktorovich.com/

2. Categories of personal data processed

The Controller processes the following categories of personal data of Users and Clients:

3. Purposes of processing

3.1. Conclusion and performance of agreements for the provision of coaching and consulting services.

3.2. Communication with Users and Clients (e-mails, responses to requests).

3.3. Settlements and invoicing.

3.4. Conducting coaching sessions and supporting the Client's Programme.

3.5. Marketing and informing about new services — only with the express consent of the User.

3.6. Compliance with applicable law (tax accounting, responses to requests of competent authorities).

In accordance with the GDPR (for EU residents) and analogous norms:

5. Retention period

5.1. Contact and identification data — no more than 24 (twenty-four) months after the end of provision of services or the last interaction with the User, unless a longer period is required by applicable law or the individual agreement.

5.2. Payment and tax data — within the period established by applicable Japanese tax law (usually at least 7 years).

5.3. Video and audio recordings of coaching sessions — at least 36 (thirty-six) months after completion of the Client's Programme, on the basis of the Client's consent expressed by signing the individual agreement with the Controller. Deletion after this period — at the Client's request within 30 calendar days, in the absence of a legitimate interest in continuing storage.

5.4. Technical data (cookies, analytics) — within the period configured in the Controller's PostHog project; error reports in GlitchTip — up to 90 days.

6. Video and audio recordings of coaching sessions

6.1. Recordings of coaching sessions with Clients are made on the basis of the Client's consent expressed by signing the individual agreement. Consent to recording is a material condition of the work.

6.2. Recordings are stored locally on the Controller's devices or in secured cloud storage with end-to-end encryption. Where a session is recorded by the video-conferencing platform into its own cloud, a copy is also held by that platform's provider (Section 7).

6.3. Recordings are not published and not used for marketing purposes without the Client's separate written consent to the specific form of use.

6.3-bis. In anonymised form — without name, contact details or other directly identifying data, and where technically possible with the face obscured — excerpts of Recordings may be used for the Controller's professional supervision and continuing education within a closed audience bound by confidentiality. The voice is not altered: intonation and emotional response are the subject matter of professional review. The scope and conditions of such use are agreed in the individual agreement with the Client; outside these purposes no transfer to third parties takes place.

7. Recipients of data (Third-party Processors)

The Controller transfers personal data to the following categories of recipients only to the extent necessary for processing purposes:

A full list of categories of data processed by third parties — upon Client request.

8. Cross-border transfer of data

8.1. Given the international nature of the Controller's activities, personal data may be transferred outside Japan — to the European Union, the USA, CIS countries, and other jurisdictions.

8.2. Upon cross-border transfer, the Controller ensures an adequate level of protection:

9. Rights of data subjects (Users and Clients)

In accordance with GDPR, APPI, and analogous norms, the User has the right to:

To exercise rights, send a request to: legal@danielviktorovich.com.

The Controller responds to requests within 30 calendar days (with the possibility of extension to 60 days for complex requests under GDPR).

10. Cookies and analytics

10.1. The site uses cookies and the PostHog analytics service (EU) for analysing User behaviour and improving service quality.

10.2. The User can manage cookies through browser settings or opt-out using the settings of the relevant services.

11. Jurisdictional specifics

11.1. For EU / Cyprus residents. GDPR (Regulation (EU) 2016/679) applies. Supervisory authority — national regulator of the country of residence.

11.2. For Japan residents. 個人情報保護法 (Personal Information Protection Act / APPI) applies. Supervisory authority — 個人情報保護委員会 (Personal Information Protection Commission, PPC).

11.3. For Russia residents. Processing is carried out in accordance with Federal Law No. 152-FZ "On Personal Data". Given the Controller's status as a resident of Japan and the nature of remote services, data transfer to Russia may be carried out with the data subject's consent.

11.4. For US residents. CCPA (California Consumer Privacy Act) provisions apply for California residents — the right to know, delete, and opt out of the sale of personal data. The Controller does not sell personal data.

11.5. Other jurisdictions — national legislation applies; in case of conflict with this Policy, the Controller brings processing into compliance with the stricter standard.

12. Security

The Controller applies legal, organisational, and technical measures to protect personal data, including:

13. Changes to the Policy

The Controller is entitled to amend this Policy. The current version is published on the site at https://pay.danielviktorovich.com/legal/privacy-policy. Material changes are accompanied by notification of Users by e-mail.

14. Contact

All questions regarding the processing of personal data are sent to:

E-mail: legal@danielviktorovich.com (data requests) · hello@danielviktorovich.com (general enquiries) Phone: +81-80-5802-9332 Address: 〒123-0864, Tokyo-to, Adachi-ku, Shikahama 2-40-4, #105