Privacy Policy

Data Controller

The controller responsible for the processing of personal data in connection with this website is:

Natalia Kulpin
Jupiterstr. 6a
86179 Augsburg
Germany

Email: neoxx@neoxx.org
Website: https://alexkulpin.com

No data protection officer has been appointed because there is currently no legal requirement to appoint one.

General Information

Personal data means any information relating to an identified or identifiable natural person. This may include names, contact information, online identifiers, IP addresses or information contained in a message.

This website does not intentionally request special categories of personal data.

When you access the website, certain technical information may be processed automatically. This is necessary to display the website, protect it against misuse, diagnose errors and maintain its secure operation.

Hosting Provider

This website is hosted by:

IONOS SE Elgendorfer Str. 57 56410 Montabaur Germany

IONOS provides the technical infrastructure required to store and deliver the website.

Where IONOS processes personal data on behalf of the website operator, the processing is carried out in the context of the hosting relationship and the applicable data-processing arrangements.

Server Log Files

When you visit this website, the hosting infrastructure may automatically process technical access information in server log files.

Depending on the hosting configuration, this information may include:

• the IP address or an anonymised form of the IP address;
• the date and time of access;
• the requested page or file;
• the amount of data transferred;
• the referring website;
• the browser type and browser version;
• the operating system;
• the hostname of the accessing device;
• the access status;
• the HTTP status code.

This information is processed to:

• deliver the requested pages and files;
• maintain the technical stability of the website;
• detect and analyse errors;
• protect the website against attacks, misuse and unauthorised access;
• ensure the security of the hosting infrastructure.

The legal basis for this processing is Article 6(1)(f) GDPR.

The legitimate interests are the secure, stable and efficient operation of the website, the prevention of misuse and the investigation of technical problems.

Server log data is retained only for as long as required for technical operation, security monitoring, troubleshooting or the investigation of a specific incident. It is then deleted or anonymised unless a longer retention period is required by law or is necessary for the establishment, exercise or defence of legal claims.

Language Preference and Local Storage

The website is available in Russian and English.

When you select a language, the chosen language preference may be stored locally in your browser. This allows the website to remember and display your preferred language when you return.

The stored value contains only the selected language setting. It does not contain your name, email address or other directly identifying information.

The language preference is not used for:

• advertising;
• analytics;
• behavioural tracking;
• profiling;
• cross-site tracking;
• measuring marketing performance.

The preference remains stored until you change it, delete the website data through your browser settings or clear your browser storage.

The language setting is used solely to provide the multilingual functionality requested by the visitor.

Where the processing involves personal data, the legal basis is Article 6(1)(f) GDPR. The legitimate interest is providing a convenient and user-friendly multilingual website.

The storage is technically limited to the functionality requested by the user.

Cookies

This website does not currently use advertising, analytics or marketing cookies.

No cookies are currently used for:

• behavioural advertising;
• visitor profiling;
• cross-site tracking;
• advertising measurement;
• retargeting;
• marketing automation.

The website may rely on technically necessary browser functionality required to deliver the website and preserve the visitor’s selected language.

If cookies or similar technologies are added in the future, the website must be reviewed before they are activated. This Privacy Policy and any required consent mechanism must then be updated.

Analytics, Advertising and Tracking

This website does not currently use:

• Google Analytics;
• Google Tag Manager for tracking purposes;
• Meta Pixel;
• TikTok Pixel;
• LinkedIn Insight Tag;
• Microsoft Advertising tracking;
• Hotjar;
• behavioural analytics;
• advertising networks;
• remarketing tools;
• tracking pixels;
• fingerprinting technologies.

No visitor profile is created for advertising or marketing purposes.

The website keeps an anonymous aggregate count of book-download requests. The counter records only the total number of requests and the language version from which the download was started. It does not store IP addresses, cookies, device identifiers or individual download histories.

Personal data collected through the technical operation of the website is not used to monitor visitors across unrelated websites or services.

If an analytics, advertising or tracking technology is added in the future, it must not be activated until the privacy documentation and any required consent system have been updated.

Locally Hosted Fonts

Fonts used on this website are intended to be stored and delivered locally through the website’s own hosting infrastructure.

The website does not intentionally establish a connection to Google Fonts, Adobe Fonts or another external font provider when a page is loaded.

The technical delivery of locally hosted font files is covered by the processing described under “Hosting Provider” and “Server Log Files”.

If an external font service is added in the future, this Privacy Policy must be updated before the service is activated.

Locally Hosted Images and Graphics

Images, portraits, book-cover graphics and other visual assets displayed on this website are intended to be hosted locally.

Loading these files does not intentionally establish a direct connection to an external image-hosting or social-media provider.

The delivery of locally hosted images and graphics may generate the same technical server-log information described above.

Locally Hosted Video

The introductory video displayed on this website is intended to be hosted locally through the website’s hosting infrastructure.

Playing the video does not intentionally establish a connection to YouTube, Vimeo or another external video platform.

Technical data required to load, buffer and deliver the video may be processed by the hosting provider. This processing is covered by the sections on hosting and server log files.

The website does not use autoplay with sound.

If the video is later embedded from YouTube, Vimeo or another provider, the Privacy Policy and any necessary consent mechanism must be updated before the external embed is activated.

Book and PDF Downloads

The book “Против течения” may be provided as a direct PDF download from this website.

No registration, user account, newsletter subscription or payment is required to access the PDF.

When the PDF file is hosted locally, downloading or opening it results in the technical processing necessary to deliver the file and an increment to an anonymous aggregate download counter. This processing is described in the sections on hosting and server log files.

The website does not create a reader profile based on the download.

If the book or another PDF is later delivered through an external platform, cloud-storage provider or email-marketing system, this Privacy Policy must be updated before that service is used.

External Links

This website contains links to external websites and services.

These may include:

• Telegram;
• Instagram;
• Facebook;
• external Telegram posts;
• Telegram channels;
• Telegram bots;
• other websites selected by the website operator.

External services are linked through ordinary links and are not intended to be loaded automatically as embedded social-media plugins.

No connection to the external provider is intentionally established merely because the link is displayed on this website.

When you click an external link, you leave alexkulpin.com. The external provider may then process personal data according to its own terms and privacy information.

Depending on the service, the processed information may include:

• your IP address;
• browser and device information;
• account information;
• identifiers stored by the external provider;
• the date and time of the interaction;
• information about the page or link you accessed;
• information about your activity on the external service.

The website operator does not control the independent processing performed by the external provider.

You should review the relevant provider’s privacy information before using the external service.

Telegram Channels, Posts and Bots

Some links on this website lead to Telegram channels, Telegram posts or Telegram bots.

Materials accessible through Telegram may include:

• audio visualisations;
• meditation recordings;
• PDF workbooks;
• business information;
• educational materials;
• personal publications;
• other downloadable resources.

Displaying a Telegram link on this website does not itself transmit your personal data to Telegram.

A connection to Telegram is established only after you actively click the relevant link or button.

When you use Telegram, Telegram may process data under its own responsibility. This may include:

• Telegram account information;
• your username;
• profile information;
• IP address;
• device information;
• interaction data;
• message content;
• files you send or receive;
• information about your use of Telegram.

The use of Telegram is voluntary.

You may browse the publicly available pages of alexkulpin.com without using Telegram.

Contact Through Telegram

The website does not currently use a contact form.

If you choose to contact Alexandr Kulpin through Telegram, the information you provide is processed for the purpose of reading and responding to your enquiry.

The processed data may include:

• your Telegram display name;
• your Telegram username;
• your profile image;
• your message content;
• attached images or documents;
• voice messages;
• the date and time of communication;
• any other information you voluntarily provide.

Where the communication concerns steps taken at your request before entering into a contractual or business relationship, the legal basis is Article 6(1)(b) GDPR.

For general enquiries, the legal basis is Article 6(1)(f) GDPR. The legitimate interest is responding to enquiries and maintaining professional communication.

Telegram messages are retained only for as long as reasonably necessary to respond to the enquiry and handle any related matter, unless legal retention obligations apply or continued storage is necessary for the establishment, exercise or defence of legal claims.

Please do not send health information, identification documents, financial account information or other sensitive personal data through Telegram unless it is strictly necessary and you understand the privacy implications of using the platform.

Instagram and Facebook Links

This website may provide ordinary links to profiles or pages on Instagram and Facebook.

The website does not currently use embedded Instagram feeds, Facebook Like buttons, Meta social plugins or Meta tracking pixels.

A connection to Meta or its services is established only when you actively click the corresponding external link.

After you leave this website, Meta may process personal data under its own responsibility and in accordance with its own privacy information.

The website operator has no control over the data processing performed by Instagram or Facebook after you access those services.

No Newsletter and No Email Marketing

This website does not currently offer a newsletter.

It does not collect email addresses for email marketing, automated campaigns or promotional mailing lists.

No visitor is required to provide an email address to browse the website, read its pages or download the locally hosted book.

If a newsletter or email-marketing system is introduced in the future, this Privacy Policy and the required consent process must be updated before any email addresses are collected.

No Online Store or Payment Processing

This website does not currently operate an online store.

It does not directly process:

• payments;
• bank information;
• credit-card information;
• billing information;
• purchase histories;
• customer accounts.

Links may lead to information about external businesses, products or services. Any data processing carried out on an external website is governed by the privacy information of the relevant external provider.

If direct purchases or payments are added to this website in the future, the Privacy Policy must be updated before the functionality is launched.

No User Accounts

The website does not provide account registration or password-protected user profiles.

It does not maintain a user database for website visitors.

Visitors are not required to create an account to access the public content of the website.

Legal Bases for Processing

Where personal data is processed through this website, the processing is based on one or more of the following legal grounds:

Article 6(1)(a) GDPR

Processing is based on consent where you have voluntarily given consent for a specific purpose.

Article 6(1)(b) GDPR

Processing is necessary to perform a contract or to take steps at your request before entering into a contract.

Article 6(1)(c) GDPR

Processing is necessary to comply with a legal obligation.

Article 6(1)(f) GDPR

Processing is necessary for the purposes of a legitimate interest, provided that the interest is not overridden by your fundamental rights and freedoms.

The legitimate interests relevant to this website may include:

• securely operating the website;
• making the website technically available;
• protecting the website against attacks and misuse;
• diagnosing technical errors;
• responding to enquiries;
• presenting the website in the visitor’s selected language;
• establishing, exercising or defending legal claims.

Recipients of Personal Data

Personal data may be processed by technical service providers where this is necessary to operate, secure and maintain the website.

The main hosting provider is IONOS SE.

Personal data may also be disclosed:

• where required by law;
• in response to a lawful request by a competent authority;
• where necessary to protect legal rights;
• where necessary to investigate misuse or a security incident;
• where necessary for the establishment, exercise or defence of legal claims.

Personal data collected through this website is not sold to advertisers or data brokers.

International Data Transfers

The website itself is intended to be hosted through IONOS.

When you voluntarily click a link to an external service such as Telegram, Instagram or Facebook, the relevant provider may process personal data outside Germany or outside the European Economic Area.

Any international processing performed by the external service is governed by that provider’s own privacy documentation and legal safeguards.

Provided that the website uses ordinary links rather than embedded third-party content, the website operator does not intentionally initiate a connection to the external provider until you click the relevant link.

Data Retention

Personal data is retained only for as long as necessary for the purpose for which it was processed.

The applicable retention period depends on the nature of the data and the reason for processing.

Data may be retained for a longer period where:

• retention is required by law;
• a security incident is being investigated;
• misuse must be documented;
• a dispute remains unresolved;
• retention is necessary for the establishment, exercise or defence of legal claims.

When the relevant purpose no longer applies and no legal retention requirement exists, the data is deleted or anonymised.

Data Security

Appropriate technical and organisational measures are used to protect the website and personal data against:

• unauthorised access;
• accidental loss;
• unlawful destruction;
• alteration;
• unauthorised disclosure;
• misuse.

The website is intended to use encrypted HTTPS connections.

However, no method of electronic transmission or storage can guarantee absolute security.

Visitors should not transmit confidential or sensitive information unless it is necessary and an appropriately secure communication method is available.

Your Rights

Subject to the requirements of applicable data-protection law, you may have the following rights:

Right of access

You may request information about whether personal data concerning you is being processed and obtain access to that data.

Right to rectification

You may request the correction of inaccurate personal data and the completion of incomplete personal data.

Right to erasure

You may request the deletion of personal data where the legal requirements are met.

Right to restriction of processing

You may request that the processing of personal data be restricted where the legal requirements are met.

Right to data portability

Where applicable, you may receive personal data you provided in a structured, commonly used and machine-readable format and may request its transmission to another controller.

Right to object

You may object to certain processing based on legitimate interests.

Right to withdraw consent

Where processing is based on consent, you may withdraw your consent at any time.

The withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Right to lodge a complaint

You have the right to lodge a complaint with a competent data-protection supervisory authority.

Right to Object to Processing

Where personal data is processed on the basis of Article 6(1)(f) GDPR, you have the right to object to the processing on grounds relating to your particular situation.

Following an objection, the personal data will no longer be processed unless compelling legitimate grounds for the processing can be demonstrated which override your interests, rights and freedoms, or unless processing is necessary for the establishment, exercise or defence of legal claims.

Exercising Your Rights

To exercise your data-protection rights or ask a question about this Privacy Policy, contact:

Natalia Kulpin
Email: neoxx@neoxx.org

The privacy contact email must be inserted before publication.

Additional information may be requested where this is reasonably necessary to verify the identity of the person making the request and protect personal data against unauthorised disclosure.

Right to Lodge a Complaint

You have the right to lodge a complaint with a data-protection supervisory authority if you believe that the processing of your personal data infringes applicable data-protection law.

For a private-sector controller established in Bavaria, the competent supervisory authority is generally:

Bavarian State Office for Data Protection Supervision Promenade 18 91522 Ansbach Germany

You may also contact another competent supervisory authority where permitted by applicable law.

Automated Decision-Making and Profiling

This website does not use automated decision-making within the meaning of Article 22 GDPR.

The website does not create profiles for automated decisions, credit scoring, insurance decisions, employment decisions or comparable purposes.

Children’s Data

This website is intended for a general audience and is not specifically directed at children.

The website does not knowingly request personal data from children through registration forms, accounts, newsletters or contact forms.

If you believe that a child has provided personal data in connection with this website, please use the privacy contact details provided above.

Changes to This Privacy Policy

This Privacy Policy may be updated when:

• the website’s functionality changes;
• new service providers are introduced;
• new external services are linked or embedded;
• analytics or marketing technologies are added;
• legal requirements change;
• the technical hosting configuration changes.

The current version will always be published on this page.

Last updated: July 2026