Privacy Policy

1. General Provisions

1.1. This Personal Data Processing Policy (hereinafter the Policy) sets out the procedure for processing personal data and the measures taken to ensure its security by the administration of the Service (hereinafter the Operator) in respect of the users of the Service.

1.2. The Service means the software product available to the user through a chatbot and an application in the Telegram messenger, as well as the web pages associated with it.

1.3. Use of the Service constitutes the User's unconditional consent to this Policy and to the terms of processing of their personal data set out herein. If the User does not agree with the terms of the Policy, the User must stop using the Service.

1.4. This Policy is an integral part of the Terms of Service.

2. Definitions

2.1. Personal data means any information relating to a directly or indirectly identified or identifiable natural person (the data subject).

2.2. Processing of personal data means any action (operation) or set of actions performed on personal data with or without the use of automated means, including collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer, anonymisation, blocking, deletion and destruction.

2.3. User means a natural person using the Service.

2.4. Operator means the administration of the Service, which independently organises and carries out the processing of personal data and determines the purposes of processing, the scope of the data processed and the actions performed on it.

3. Data Processed

3.1. The Operator processes the following data provided by the Telegram messenger when the Service is launched: the user's identifier in the messenger, username, the name indicated in the profile, and the interface language.

3.2. The Operator processes data provided by the User in the course of using the Service: Service settings and the content of requests to the support service.

3.3. The Operator processes information about payments made by the User: amount, currency, date, status and payment method, and the transaction identifier. Payment instrument details are not transferred to the Operator and are processed exclusively by payment providers.

3.4. The Operator does not process special categories of personal data or biometric personal data.

4. Purposes of Processing

4.1. The Operator processes personal data for the following purposes:

• providing the User with the functionality of the Service and performing the Terms of Service;
• identifying the User and maintaining their account;
• accounting for payments made and services rendered;
• handling requests and providing support;
• sending notifications related to the operation of the Service;
• ensuring the security of the Service and preventing fraud and abuse;
• meeting the requirements of payment providers;
• improving the Service, including on the basis of anonymised statistical data.

5. Legal Grounds for Processing

5.1. The legal grounds for processing personal data are the User's consent, expressed by starting to use the Service, and the need to perform the Terms of Service to which the User is a party.

6. Procedure and Conditions of Processing

6.1. Personal data is processed using automated means.

6.2. The Operator does not transfer personal data to third parties, except where necessary to provide the functionality of the Service and to fulfil obligations to the User: to payment providers, to the extent required to process a payment; to infrastructure and computing service providers, to the extent required for the operation of the Service; and in cases provided for by applicable law.

6.3. The Operator does not sell personal data and does not transfer it to advertising networks.

6.4. The Telegram messenger processes the User's data in accordance with its own privacy policy, for which the Operator bears no responsibility.

7. Processing Periods

7.1. Personal data is processed until the purposes of processing are achieved, the account is deleted at the User's request, or consent is withdrawn, unless otherwise provided by applicable law, after which the data is deleted or anonymised.

8. Cookies and Local Storage

8.1. The Service uses cookies and the browser's local storage to ensure the correct operation of the application and to store the session and interface settings.

8.2. The User may disable cookies in the browser settings, in which case certain functions of the Service may become unavailable.

9. Rights of the User

9.1. The User has the right to:

• receive information about the processing of their personal data;
• request that personal data be corrected, blocked or deleted;
• withdraw consent to the processing of personal data;
• change the Service settings, including notification preferences.

9.2. To exercise these rights, the User submits a request to the Service's support service. The Operator may request confirmation that the request originates from the account holder.

9.3. Withdrawal of consent to the processing of personal data results in termination of access to the Service.

10. Data Protection Measures

10.1. The Operator takes the necessary organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution and other unlawful actions by third parties.

10.2. Data is transmitted between the User and the Service over a secure connection.

10.3. Access to personal data is granted only to persons who require it to perform their duties.

11. Age Restrictions

11.1. The Service is intended exclusively for persons aged 18 and over. By using the Service, the User confirms that they have reached that age. The Operator does not knowingly collect personal data of minors; if such an account is identified, it is deleted.

12. Final Provisions

12.1. The Operator may amend this Policy. A new revision takes effect from the moment of its publication, unless otherwise provided by the new revision.

12.2. The current revision of the Policy is available via the link in the User's profile and on the start screen of the Service.

12.3. Questions related to this Policy are to be sent to the Service's support service.

Revision of 22 September 2026.