Privacy Notice

This notice describes how LLC "Betuple" (MarginLayer, DevOpsFort) processes personal data on marginlayer.app, betuple.ru, devopsfort.ru, under contracts, when providing SaaS access, and for internal HR/accounting. Effective 20 June 2026. Governed primarily by Russian Federal Law No. 152-FZ.

1. Controller and DPO contact

Controller: LLC "Betuple" (INN 9725072930, OGRN 1227700043427), 115280, Moscow, Leninskaya Sloboda St., 17, Russian Federation. Full legal details.

Person responsible for personal data processing: Yevgeny Shamrov, CEO. Contact: sales@marginlayer.app.

2. Data categories

Depending on context, we may process:

• name, surname, patronymic;
• email, phone, Telegram;
• organization name, job title or system role;
• user ID, session and audit log metadata;
• IP address, user-agent, cookies (with consent);
• message content and correspondence;
• contract and accounting details (TIN, bank details if provided);
• employee HR and payroll data as required by law.

3. Processing purposes

3.1. Websites and inbound requests

Demo/pilot/contact forms, sales correspondence, site operation and abuse protection.

3.2. Contracts and invoicing

Licensing, pilots, subscriptions, invoices, acts, contract correspondence, legal accounting.

3.3. SaaS access (MarginLayer, DevOpsFort)

Account provisioning, authentication, audit logs, support and software operations.

3.4. HR and payroll

HR and accounting records for Betuple employees.

3.5. Website analytics

Yandex Metrica statistics — only after cookie-banner consent.

4. Legal bases

• consent (web forms, cookie banner);
• performance of a contract or steps at the data subject's request;
• legal obligations (accounting, tax, employment law);
• legitimate interests — technical logs and IP for security and site reliability.

5. Retention

Processing started on 2 February 2022 and continues until purposes are fulfilled, statutory retention expires, consent is withdrawn where applicable, or the controller ceases operations.

Website leads: up to 3 years or until consent withdrawal. Contract/accounting records: as required by Russian law. SaaS account data: for the contract term and necessary audit periods.

6. Storage location

Personal data of Russian citizens is stored in databases located in the Russian Federation, including Yandex Cloud infrastructure (ru-central1 region).

7. Third parties and cross-border transfers

We share data only as needed: hosting/cloud (Yandex Cloud), email providers, and processors under confidentiality and security agreements.

Cross-border transfer of Russian citizens' personal data is not performed except where expressly required by law or with separate consent.

8. Customer data in SaaS (controller vs processor)

For contracted customers, Betuple acts as controller for user accounts, authentication, and platform support data.

Employee or third-party data imported from customer systems (trackers, ERP, etc.) is processed as processor under a DPA. Data subjects should contact the customer as controller; Betuple assists within contractual limits.

9. Security

Organizational and technical measures include access control, Keycloak authentication, HTTPS/TLS, backups, security logging, and an appointed person responsible for data processing.

10. Cookies and Yandex Metrica

Essential cookies support site operation. Yandex Metrica loads only after cookie consent. You may change consent via the banner, browser settings, or by clearing saved preferences.

11. Your rights

Under applicable law you may request access, rectification, blocking or deletion, withdraw consent, and lodge a complaint with Roskomnadzor or a court.

Send requests to sales@marginlayer.app with your name, contact email, and request type. We respond within statutory time limits.

12. Changes

We may update this notice. The current version is published on this page. Material changes will be communicated by available means.