PRIVACY POLICY
Last updated: [03.12.2025]

This Privacy Policy explains how Individual Entrepreneur Catrin Ray, registered in the Russian Federation, processes personal data of users accessing or purchasing services through catrin-ray.com (the “Website”).
By accessing the Website, purchasing digital content, participating in coaching programs, subscribing, or otherwise interacting with the Website, you agree to the terms of this Privacy Policy.
If you do not agree with any part of this Policy, you must discontinue the use of the Website immediately.

1. Data Controller
The data controller and operator of personal data is:
Individual Entrepreneur Catrin Ray
Primary State Registration Number: 325470400131240
Taxpayer Identification Number: 780537423586
Registered address: Leningrad Region, Sosnovy Bor, Krasnykh Fortov Street, 18–8, Russia
Email for data inquiries: hello@catrin-ray.com
The controller processes your personal data according to this Policy, the laws of the Russian Federation, and applicable international standards for privacy and data protection.

2. Personal Data Collected
We may collect and process the following categories of personal data:
2.1. Data provided directly by the user
  • Name
  • Email address
  • Phone number (optional)
  • Billing information
  • Delivery address (for physical merchandise)
  • Data submitted during coaching intake forms or communication
  • Any content voluntarily provided through forms or messages
2.2. Automatically collected data
  • IP address
  • Browser type and version
  • Device information
  • Cookies and similar tracking technologies
  • Geo-location (city/country level)
  • Referrer URLs
  • Pages visited and time spent on the Website
  • User-agent data
2.3. Payment information
Payments processed through third-party providers (Tinkoff, CloudPayments, PayPal personal, crypto processors, Destream) may require the collection of:
  • masked card data
  • transaction identifiers
  • payment confirmation data
We do not store full card numbers or sensitive financial data.

3. Purposes of Data Processing
Personal data is processed for the following purposes:
  1. To provide access to digital content, courses, subscriptions and coaching programs
  2. To process payments and verify transactions
  3. To deliver physical goods (merchandise)
  4. To communicate with users, including service emails and updates
  5. To provide customer support
  6. To send marketing materials (only with consent)
  7. To ensure the security and proper functioning of the Website
  8. To comply with legal obligations
  9. To prevent fraud, abuse, or unlawful behavior
  10. To personalize content and user experience

4. Legal Basis for Processing
We process personal data on the following legal grounds:
  • User consent
  • Contractual necessity (audio/video content, digital products, coaching)
  • Compliance with legal obligations under Russian and international law
  • Legitimate interest (security, analytics, anti-fraud monitoring)

5. Cookies and Tracking Technologies
We use cookies to:
  • operate the Website
  • maintain user sessions
  • analyze traffic
  • personalize the experience
Users may disable cookies in browser settings. Disabling cookies may affect the Website’s performance.

6. Age Restriction (18+)
The Website contains aesthetic, sensual, intimate and adult-oriented educational content intended strictly for users 18 years or older.
We do not knowingly collect personal data from minors.
If we become aware of such data, it will be deleted immediately.

7. Data Storage and Security
We store personal data on secure servers located in the Russian Federation and/or data centers of trusted third-party providers.
We implement necessary organizational and technical measures to protect personal data from:
  • unauthorized access
  • alteration
  • loss
  • disclosure
  • destruction
However, no method of electronic storage is 100% secure; users acknowledge this risk.

8. Data Sharing and Transfer
We may share personal data with:
8.1. Payment providers
  • Tinkoff acquiring
  • CloudPayments
  • Destream
  • PayPal (personal transfers)
  • Crypto payment providers (e.g., USDT/ETH/BTC processors)
8.2. Technical and hosting providers
  • Website hosting platforms
  • Email service providers
  • Analytics providers
  • Cloud infrastructure services
8.3. Legal or regulatory authorities (when required by law)
8.4. Cross-border transfers
Data may be transferred to servers outside your country of residence.
By using the Website, you consent to such transfers.

9. User Rights
Depending on your jurisdiction, you may have rights to:
  • access your personal data
  • request correction
  • request deletion
  • restrict processing
  • withdraw consent
  • object to marketing
  • request information about data transfers
Requests can be submitted to: hello@catrin-ray.com
We respond within 30 days.

10. Retention Period
We store personal data only as long as reasonably necessary for:
  • fulfilling contractual obligations
  • providing access to purchased content
  • complying with financial, legal, and tax requirements
  • resolving disputes
  • security purposes
When data is no longer needed, it is securely deleted.

11. Third-Party Websites
The Website may contain links to third-party websites.
We are not responsible for their content, privacy policies or data processing practices.

12. Crypto Payments, PayPal Personal and Donations
Payments made via:
  • cryptocurrency,
  • PayPal personal,
  • Destream,
  • other voluntary contribution systems
are treated as voluntary transfers, not subject to standard refund or consumer protection rules.

Users acknowledge that such payments:
  • may be irreversible
  • may not be tied to specific consumer rights
  • may involve inherent blockchain transaction risks
These payments are handled by third-party services, for which we are not responsible.

13. Changes to This Privacy Policy
We reserve the right to update this Policy at any time.
Changes take effect upon posting on the Website.
Continued use of the Website constitutes acceptance of the updated Policy.

14. Contact Information
For all privacy-related requests:
Individual Entrepreneur Catrin Ray
Email: hello@catrin-ray.com
Website: https://catrin-ray.com