1Scope
This Controlled Information Object applies to the public PELARON.org website and to PELARON-controlled public web pages that adopt this statement. It governs the use of cookies, browser or device storage, website tracking technologies, language-preference handling, external social-media links, and the distinction between passive website use and information that a user actively submits through a PELARON web form.
This statement does not replace the PELARON Privacy & Personal Data Processing Policy. Personal data submitted through contact, enquiry, training, product-interest or similar forms is governed by that policy and by any separate consent presented at the point of collection.
2Purpose
The purpose of this document is to provide a clear, internationally suitable and privacy-conscious statement of how PELARON.org handles cookies and website data. It establishes a data-minimisation baseline for the website, supports transparent communication with users, and defines controls that must be reviewed before any optional analytics, advertising or behavioural-tracking technology is introduced.
3Governing principles
Principle
PELARON digital services shall not collect, store or transmit personal data merely because the technology makes it possible. Website data processing must serve a defined and legitimate operational purpose and must be limited to what is reasonably necessary for that purpose.
PELARON.org shall, by default, avoid third-party advertising, behavioural tracking, visitor profiling and unnecessary external tracking technologies.
Where consent is required for a processing activity or optional technology, the relevant processing shall remain inactive until the user has made the required affirmative choice. Consent for one purpose shall not automatically be treated as consent for an unrelated purpose.
5Information actively provided by users
5.1 Contact and enquiry fields
PELARON.org may provide contact, enquiry, training or product-interest forms. When a user chooses to submit such a form, PELARON may process the information entered by that user. Depending on the form, this may include the user's name, email address, telephone or messenger contact details, preferred method of communication, preferred language, diving experience or certification level, training or equipment interests, and information included in a free-text message.
This information is not collected through advertising or behavioural-tracking cookies. It is information actively and voluntarily supplied by the user for a stated purpose.
5.2 Purpose limitation
Information submitted through a form shall be processed only for the purpose or purposes communicated at the point of collection, such as responding to an enquiry, discussing requested training or services, taking requested pre-contractual steps, or handling an expressed interest in a PELARON product or service.
Submitting an enquiry does not automatically constitute consent to receive unrelated marketing communications. Where a separate consent is required, it shall be presented clearly and separately from other matters.
5.3 Data minimisation in forms
PELARON web forms shall request only information reasonably necessary for the stated purpose. Sensitive or unnecessary information should not be requested through general contact forms.
7Language preference
PELARON.org may read language preferences supplied by a user's browser or device in order to offer an appropriate language version of the website. This may include offering a Russian-language site to a browser configured to prefer Russian once that site is available.
PELARON does not need to determine a user's precise geographic location for this purpose. Language detection shall not be used as a substitute for determining nationality, citizenship or legal residence. A language suggestion shall not automatically redirect the user away from the current site; the user remains free to continue in the current language.
8Analytics and future changes
PELARON does not currently use website visitor analytics. PELARON may reconsider privacy-conscious aggregate measurement in the future only where a defined operational need exists.
Before introducing analytics, advertising, embedded social-media tracking or another optional tracking technology, PELARON shall review the intended purpose, data flows, storage location, third parties, retention, applicable consent requirements and cross-border implications. This statement shall be updated before or when the relevant functionality is activated.
9Personal data and privacy documentation
The processing of personal information actively submitted through PELARON.org is governed by the applicable PELARON Privacy & Personal Data Processing Policy and, where required, a separate consent presented at the point of collection.
The applicable privacy documentation shall identify the responsible legal operator, categories and purposes of processing, legal bases, retention rules, recipients or processors, storage and processing locations, applicable international transfers, security arrangements, user rights and the means by which those rights may be exercised.
PELARON shall design the international PELARON.org site and any future localized site, including a Russian-language site, so that the underlying data-processing architecture remains compliant with the legal requirements applicable to the relevant processing. A domain name or language version shall not be treated as a substitute for compliant data handling.
10Contact and document control
Questions concerning cookies, website data or PELARON's processing of personal information may be submitted through the official contact methods published on PELARON.org.
The responsible legal operator and dedicated privacy contact details shall be published in the PELARON Privacy & Personal Data Processing Policy before personal-data collection is enabled for commercial launch. Until those details are published, this document does not authorize deployment of a live personal-data collection form.
This statement shall be reviewed at least annually and whenever a material change is made to website technology, tracking, analytics, external integrations or personal-data collection.
Appendix AWebsite technology register
The production website shall be technically audited before commercial launch and after material technology changes. The register below states the approved launch baseline. Any technology found during audit that is not represented here must be assessed before launch or publication of the revised statement.
Approved launch baseline:
- Cookies / optional browser storage
- None intentionally deployed for advertising, behavioural tracking or visitor analytics.
- Visitor analytics
- None.
- Advertising / marketing pixels
- None.
- Embedded Instagram tracking
- None. Ordinary outbound link only.
- Embedded Telegram tracking
- None. Ordinary outbound link only.
- Language preference
- Browser/device language preference may be read locally to offer an optional language-site suggestion; no precise geolocation is required.
- Contact forms
- May collect user-entered personal data only after the privacy policy, responsible legal operator, storage architecture and required consent wording have been finalized and implemented.
RevisionHistory
| Version | Date | Description | Approved by |
|---|---|---|---|
| 1.0 | 25 August 2026 | Initial approved issue for publication on PELARON.org. | PELARON Management |
6Social media and external services
PELARON.org may contain ordinary outbound links to PELARON-controlled pages or communities on external services, including Instagram and Telegram. The launch implementation shall prefer ordinary links over automatically loaded third-party social-media widgets or tracking scripts.
When a user chooses to follow an external link, the user leaves PELARON.org. The external service may then process information under its own privacy, cookie and data-processing terms. PELARON does not control the technologies used by those external websites.