FOR PARENTS & CUSTOMERS
Privacy and personal data policy
Updated 21 October 2026
This policy explains processing on shishandtwist.com and shishandtwist.ru when you browse, contact us, choose analytics or use the shop. Visiting the site does not by itself give consent to optional analytics, advertising or publication of personal information.
1. Who processes your data
Website operator: SAN PORTO LLC (ООО «САН ПОРТО»). OGRN 1227700519694; INN 7730285464. Address: 121165, Russia, Moscow, Kutuzovsky Prospekt, 35, floor 1, premises XXIX, room 2. Website and privacy enquiries: info@sanporto.ru.
Shop seller and operator of customer data: KUSHA LLC (ООО «КУША»). OGRN 1177746542324; INN 7730236643. Address: 121165, Russia, Moscow, Kutuzovsky Prospekt, 35, premises 29, room 8. The seller’s KUSHA LLC: seller privacy policy and shop contacts describe its processing in more detail. The website operator and the seller have different purposes; SAN PORTO LLC is not identified here as the seller.
2. Information, purposes and legal grounds
| Purpose and operator | Information | Grounds under Russian law |
|---|---|---|
| Website operation and security — SAN PORTO LLC | IP address, browser/device details, requested URL and time, technical results and settings needed for the requested feature. | Providing and protecting the requested service and legitimate interests, subject to visitor rights: Article 6(1)(7), Law No. 152-FZ. |
| Replies to enquiries — SAN PORTO LLC | Email address, the name you provide, message content and information needed to reply. | Handling the request and protecting rights; entering into or performing a contract where relevant; consent where required. |
| Analytics — SAN PORTO LLC | Yandex Metrica № 113707256 processes browser/cookie identifiers, IP address, device and browser details, page views, visit time and duration, and available traffic-source information to measure visits and improve the site. Session Replay (Webvisor) is not enabled. | Separate prior consent: Articles 6(1)(1) and 9, Law No. 152-FZ. |
| Orders, delivery and customer account — KUSHA LLC | Name, optional patronymic, phone, email, recipient details, address or pickup point, order contents/status, payment/refund information, profile and saved addresses. Business purchases also use the company and representative details entered. | A contract entered into at the customer’s request or its performance: Article 6(1)(5); legal obligations: Article 6(1)(2); separate consent where required. |
| Shop sign-in and security — KUSHA LLC | Verified contacts, one-time code verification records, session identifiers, IP address and technical access events. | Operating the requested account and protecting access, contractual and other grounds permitted by law. |
Processing is limited to information needed for each purpose. Passwords, financial details, contacts, delivery addresses and private messages are excluded from Metrica parameters, goals and events. Please do not submit health, biometric, passport or other unnecessary information through the forms.
3. Services and recipients
- If you allow analytics, technical information is received by Yandex Metrica, supplied by YANDEX LLC (16 Lva Tolstogo Street, Moscow, 119021, Russia). See the Yandex Metrica: terms of use and data processing and Yandex privacy policy.
- To fulfil orders, the seller uses shop information systems, communication providers and the selected delivery service. Checkout address suggestions and city detection use DaData: the search fragment is sent for suggestions and IP address for city detection. See the DaData privacy policy.
- Payments use YooKassa. Full card details are entered with the payment service; the shop receives information needed to confirm payment and fulfil the order. See the YooMoney / YooKassa privacy policy.
- When you start an episode, the Platformcraft video delivery network receives technical request details, including IP address and browser information, to deliver the video.
- If you open the pickup-point map, OpenStreetMap supplies map tiles and receives technical request details and the viewed map area. Pickup points can also be selected from a list. See the OpenStreetMap Foundation privacy policy.
- Staff and service providers receive access limited to their tasks. Information is provided to public authorities as required by law. Customer information is not intended for public posting.
The main website is hosted on a server in Russia. Collection of Russian citizens’ personal data is subject to the Russian database requirements in Article 18(5), Law No. 152-FZ. External video, payment and map services have their own terms and infrastructure; this policy does not state that all processing by every external provider takes place only in Russia. Cross-border transfer requirements apply separately under Article 12 of that law.
4. Processing, retention and security
Information is processed automatically and, for enquiries and orders, by authorised personnel. Operations are limited to the relevant purpose and may include collection, recording, organisation, storage, updating, use, provision to a service provider, depersonalisation, blocking, deletion and destruction.
Information is kept until the purpose is fulfilled or no longer necessary unless a law or contract requires another period. Consent-based processing is also subject to withdrawal. Order, payment and legal claim records may be retained on an independent legal ground. Cookie lifetime, sign-in session duration and purchase-record retention are different periods. Ask the relevant operator for details about your processing.
Protection includes HTTPS, access restrictions and information-system security measures. Once no lawful ground remains, data is deleted or depersonalised under the procedure and deadlines required by law. Clearing browser cookies does not delete a server-side order or account.
5. Choices and your rights
Metrica is not loaded before you allow analytics. “Essential only” lets you continue using the site. “Cookie settings” in the footer lets you change your choice and stop further analytics from this browser. See the cookie policy and separate analytics consent.
You may request information about processing, correction, blocking or destruction where provided by law, and withdraw consent. Contact info@sanporto.ru about the website and use the seller’s contacts for purchases. Identify the domain, your request and information needed to locate the relevant enquiry or order. The operator may request proportionate identity or representative-authority verification. Please do not send a passport copy unless it is requested and necessary.
Withdrawal does not undo processing already carried out or prevent processing supported by another lawful ground. Requests and termination of processing are handled within the statutory deadlines. You can complain to Roskomnadzor or a court if your rights are infringed.
6. Children and parents
Episodes can be watched without entering a name, phone number or address. Purchases, customer accounts and personal-data enquiries are intended for adult customers and legal representatives. Children should ask a parent or other legal representative for help before submitting personal information or choosing analytics. Do not include children’s information in an order unless it is necessary to fulfil it.
Where a representative gives consent on a child’s behalf, their authority must be checked as required by law. If you believe a child sent unnecessary information, contact info@sanporto.ru so that the operator can consider restricting processing and deleting information where no other legal ground exists.
7. Updates and contact
The current policy is published on this page. A policy update does not replace separate consent or automatically broaden a previously chosen purpose. Website contact: info@sanporto.ru.
Documents and primary sources
- Russian Federal Law No. 152-FZ on Personal Data: Articles 5, 6, 9, 14, 18, 18.1 and 19–22
- Roskomnadzor: obligations of personal data operators
- Roskomnadzor: personal data questions and answers
- SAN PORTO LLC: operator information
- KUSHA LLC: seller privacy policy
- Yandex Metrica: protecting identifying information