Consent to Personal Data Processing

Version of 26.10.2026 (version 2026-10-26).

This is an English translation provided for convenience. Only the Russian version is legally binding.

By ticking the box "I consent to the processing of personal data" in a form on the website https://108records.com (the "Site"), I, the data subject, freely, of my own will and in my own interest, specifically, objectively, in an informed and conscious manner (Article 9 of Russian Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", the "Law") consent to the processing of my personal data by the Operator on the terms below. The terms depend on the form in which I tick the box: release request — section 2; release questionnaire and contract details — section 3; donation — section 4. General terms — sections 1 and 5–8.

1. Operator

Sole proprietor (individual entrepreneur) Alexander Olegovich Titov, INN 770301623108, OGRNIP 319774600078733, address: 1A Pistsovaya St., Moscow 127015, Russia; email: info@108records.com (the "Operator").

2. Release request

The "Leave your contact" form on the /ru/release page.

• Personal data: name (as I entered it); contact — phone number, email address or Telegram username.
• Purposes: considering my request to release music; contacting me; sending me a personal link to the release questionnaire and the contract details form.
• Term of consent: until the purposes are achieved, but no longer than 1 year from the date of the request if no licence agreement is signed; or until consent is withdrawn.

3. Release questionnaire and contract details

The forms on the /ru/release/anketa and /ru/release/dogovor pages, opened via a personal link.

• Personal data in the release questionnaire: surname, first name, patronymic; contact (phone, email or Telegram); stage name; links to my pages on music platforms; release details (titles, lyrics, genre, language, dates, link to files).
• Personal data in the contract details: surname, first name, patronymic; date of birth; email; phone number; passport details (series and number, issuing authority and date, subdivision code); registered address; SNILS (insurance number); INN (taxpayer number); bank details (bank name, account number, BIC, correspondent account, the bank's INN and KPP); legal form (individual, self-employed, individual entrepreneur, company).
• Purposes: preparing, concluding and performing a licence agreement with the Operator, including signing it with an electronic signature in the Nopaper service; preparing and releasing the release, including crediting my stage name in the release metadata; paying me royalties; complying with the Operator's legal obligations (including as a tax agent).
• Details of other persons. If I enter the names and pseudonyms of other persons in the questionnaire (authors of the music and lyrics, sound engineers, producers, musicians, a second artist), I confirm that those persons are aware of their data being provided to the Operator to prepare and release the release and to credit them in its metadata.
• Term of consent: until the purposes are achieved: if no licence agreement is signed — no longer than 1 year from the date the questionnaire or contract details were sent; if signed — for the term of the agreement plus 5 years after it ends; or until consent is withdrawn.

4. Donation

The form on the /ru/support page.

• Personal data: email; amount and frequency of the donation; payment details provided by the CloudPayments payment service (date, amount, status and transaction ID, masked card number). I enter my card details in the CloudPayments window; they are not transferred to the Operator.
• Purposes: accepting the donation, including monthly charges if I chose them; sending the receipt to my email; answering my requests, including cancellation of a monthly donation.
• Term of consent: until the purposes are achieved or until consent is withdrawn. Payment and receipt records are kept for 5 years after the end of the year of payment, as required by accounting and tax law.

5. Operations and methods of processing

5.1. I consent to the following operations with my personal data: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.

5.2. Processing is mixed — with and without automation.

5.3. The Operator may entrust processing of my data — to the extent necessary for the purposes and subject to confidentiality — to the following persons: the Site hosting provider and IQHost (servers in Moscow) — to receive form data and pass it to the CRM; 1C-Bitrix LLC (Bitrix24 service) — to keep records of requests, questionnaires and contract details; the Nopaper electronic document service — to sign the agreement (section 3); the CloudPayments payment service — to accept the donation and generate the receipt (section 4).

5.4. Personal data is recorded, stored and processed on servers located in the Russian Federation. The Operator does not transfer data from Site forms abroad.

6. Legal basis

Article 6(1)(1) and Article 9 of the Law. If an agreement has been signed with me or processing is required by law, the Operator also processes the data under Article 6(1)(2) and (5) of the Law.

7. Withdrawal of consent

7.1. I may withdraw my consent at any time by sending a notice to info@108records.com or by post to the Operator's address. The notice must state my surname, first name and the contact (phone, email or Telegram) I entered in the form on the Site.

7.2. After consent is withdrawn, the Operator stops processing and destroys my personal data within 30 days of receiving the withdrawal (Article 21(5) of the Law), unless it has other grounds for processing under the Law — for example, to perform an agreement signed with me or to comply with tax law (Article 9(2) of the Law).

7.3. If consent is withdrawn before a licence agreement is signed, the Operator will not be able to consider the request or prepare the agreement.

8. Other terms

8.1. Processing is described in detail in the Privacy Policy, which also sets out the data subject's rights and how to exercise them.

8.2. When a release request, questionnaire or contract details are sent, the Operator records my consent: the version of this document, the date and time of consent and the form in which it was given.

8.3. This consent does not cover advertising or newsletters.