Privacy Policy

1. General Provisions

2. Definitions

• Personal Data — any information relating directly or indirectly to a specific or identifiable individual (data subject).
• Data Processing — any action (operation) or set of actions performed with personal data, including collection, recording, organization, accumulation, storage, clarification, extraction, use, transfer, anonymization, blocking, deletion, and destruction.
• Operator — Kropochev Maxim Olegovich, self-employed, who processes personal data.
• User — an individual using the Service.

3. Data Collected

The Service collects and processes the following categories of personal data:

• Telegram ID (user identifier)
• Name and username from Telegram
• Email and password (for website registration)
• Question texts submitted during readings
• Service usage data (reading history, statistics, activity)
• Subscription and payment data (date, amount, transaction status)
• Referral program data (invitations, points, level)
• Astrological data (birth date and time, city, coordinates — when using astrological features)
• Technical data for additional services (access identifiers, usage volume)

4. Purposes of Processing

Personal data is processed for the following purposes:

• Providing access to Service features
• Generating interpretations using artificial intelligence technologies
• Subscription management and payment accounting
• Crediting referral program bonuses
• Providing technical support
• Content personalization
• Improving Service quality
• Informing the User about updates and promotions (with consent)

5. Legal Basis for Processing

Personal data processing is based on the following grounds:

• User consent — use of the Service constitutes consent to data processing under the terms of this Policy.
• Contract performance — processing is necessary for the performance of the Terms of Service agreement.

6. Data Retention Periods

Personal data is stored for the following periods:

• Account data — for the entire period of Service use
• Reading history and interpretations — for the entire period of Service use
• Astrological data — for the entire period of Service use
• Payment data — 3 years from the date of transaction (in accordance with accounting requirements)
• Analytics data (anonymized) — 90 days

Upon achieving the purposes of processing or expiration of retention periods, data is subject to deletion or anonymization.

Users may at any time request complete deletion of their data by contacting support. Deletion is performed from all Service systems within 10 business days.

7. Data Sharing with Third Parties

The Operator does not share personal data with third parties, except in the following cases:

• Anthropic (Claude AI) — for generating interpretations. Question texts are transmitted without reference to the User identifier (Telegram ID and name are not sent).
• Telegram — the Service operates on the Telegram platform and uses its infrastructure. Telegram operates under its own privacy policy.
• Analytics services — for collecting anonymized analytics (with User consent). Data does not contain personal information.
• Payment processors — for payment processing. Only data necessary for the transaction is transmitted.
• Legal requirements — at the request of authorized government bodies.

Each of the listed services operates under its own data processing policy.

8. Data Protection Measures

The Operator takes necessary and sufficient organizational and technical measures to protect personal data:

• Use of secure data transmission channels (HTTPS/TLS)
• Restriction of access to personal data
• Use of authentication and authorization tools
• Regular data backup
• Security monitoring and unauthorized access detection

9. Payment Data

Payment for services is processed through a secure payment system. The Operator does not process or store bank card data or other payment details of Users.

Only payment facts are stored for accounting purposes: date, amount, and transaction status.

10. Cookies and Analytics

11. User Rights

In accordance with applicable law, Users have the right to:

• Obtain information about processed personal data
• Request clarification, blocking, or deletion of their data
• Withdraw consent for personal data processing
• File a complaint with the relevant data protection authority

A response to User requests is provided within 10 business days of receipt.

12. Policy Changes

The Operator reserves the right to make changes to this Policy. The new version takes effect from the moment of its publication in the Service, unless otherwise specified in the new version.

Continued use of the Service after changes are made constitutes the User's acceptance of the new version of the Policy.

13. Dispute Resolution

In case of disputes, the User may send a complaint to the Operator via email. The complaint review period is 30 calendar days.

Disputes not resolved through the complaint procedure shall be resolved in accordance with applicable law.

14. Contact Information

Operator: Kropochev Maxim Olegovich, self-employed

Email: buh.consult.rf@gmail.com

Telegram: @admiin_i_tochka