Personal Data Processing Policy

This document defines the policy of the individual entrepreneur Kolle Stepan Aleksandrovich regarding the processing of personal data and the measures taken to ensure the security of personal data on the Service: http://trychatgpt.ru (hereinafter — the Policy).

The Policy applies to all personal data that the Operator may receive from a personal data subject.

1. Terms and definitions

Operator — individual entrepreneur Kolle Stepan Aleksandrovich, TIN 771618757230.

Service — the Licensor's software located at: http://trychatgpt.ru

User — a natural person using the Service; a subject of Personal Data.

Personal Data — any information relating to a directly or indirectly identified or identifiable natural person (the personal data subject).

Processing — any action (operation) or set of actions (operations) performed on Personal Data, whether or not by automated means.

Payment Agent (Payment System) — the non-bank credit institution "MONETA" (Limited Liability Company), which transfers funds and services electronic wallets on the basis of Bank of Russia licence No. 3508-K dated 02.07.2012.

Transaction — an action by the User to pay for services (to acquire Service functionality) using electronic means of payment through the Payment System.

2. General provisions

2.1. The Policy defines how the Operator processes Users' personal data and ensures the security and confidentiality of such data.

2.2. The Policy specifies:

2.2.1. what personal data the Operator receives and how it uses them;

2.2.2. the main rights of Users as personal data subjects;

2.2.3. the methods, terms of processing and storage of personal data;

2.2.4. the procedure for destroying personal data;

2.2.5. the procedure for transferring personal data to the Payment Agent for the purpose of carrying out Transactions.

2.3. The Operator processes Personal Data on the basis of:

2.3.1. consent to the processing of personal data, given by filling out feedback forms on the Service;

2.3.2. consent to advertising mailings, given by filling out the mailing subscription form on the Service.

3. Processing of Personal Data

3.1. Types of Processing used by the Operator: collection, recording, systematisation, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (provision), blocking, deletion, destruction.

3.2. The User agrees to the Policy when sending their Personal Data to the Operator, including at the moment of:

3.2.1. filling out forms on the Service;

3.2.2. contacting by email;

3.2.3. contacting via a messenger, including through the @trychatgptsupport bot;

3.2.4. making a payment through the Payment System integrated with the Service.

3.3. The Personal Data processed by the Operator are not biometric and do not belong to special categories of Personal Data.

3.4. The Service is not intended for processing the personal data of minors. If you have reason to believe that a child has provided us with their personal data through the data collection forms, please notify us by email at support@trychat.io or via the Telegram account @trychatgptsupport.

3.5.1. Carrying out Transactions and processing payments

In order to fulfil obligations under the contract (payment by the User for the Service's services), the Operator transfers the necessary personal data to the Payment Agent — the non-bank credit institution "MONETA" (Limited Liability Company).

To process the payment and identify the User as the payer in accordance with the requirements of Federal Law No. 115-FZ, the following Personal Data are transferred:

1. Surname, first name, patronymic (if any);
2. Email address;
3. Mobile phone number;
4. Amount and date of the Transaction.

Data on the payment instrument (if the User chooses to pay via an electronic wallet or bank card) are processed exclusively by the Payment Agent in compliance with the requirements of the Payment Card Industry Data Security Standard (PCI DSS).

Period of data processing by the Payment Agent: for the entire term of the contractual relationship between the Operator and the Payment Agent, as well as for the period required to comply with tax legislation and Federal Law No. 115-FZ dated 7 August 2001 "On countering the legalisation (laundering) of proceeds of crime and the financing of terrorism" (5 years from the date of the Transaction).

3.6. Methods by which the Operator collects Personal Data:

3.6.1. through Service forms filled out by the User;

3.6.2. by email, via messengers;

3.6.3. through the Payment System when carrying out Transactions (payment data is received by the Operator in anonymised form or in the amount necessary to perform the contract).

3.7. The Operator stores Personal Data:

3.7.1. exclusively on properly protected electronic media;

3.7.2. using databases located within the territory of the Russian Federation;

3.7.3. on the Service using automated processing, except where non-automated Processing is necessary in connection with compliance with the requirements of the legislation of the Russian Federation;

3.7.4. for all purposes from the moment consent is given until consent is withdrawn or for as long as the purposes of Processing require.

4. Access to Personal Data

4.1. The Operator provides Personal Data only to its authorised employees.

4.2. The Operator does not distribute or provide Users' Personal Data to third parties without their consent, except in the following cases:

4.2.1. when transferring to separate, independently functioning applications and databases that are part of the Service;

4.2.2. for the purpose of preventing or suppressing unlawful actions by the User and protecting the legitimate interests of the Operator and third parties, as well as in cases established by the legislation of the Russian Federation;

4.2.3. upon a reasoned request from judicial authorities, state security bodies, the prosecutor's office, the police, investigative bodies, and other bodies and organisations in cases established by mandatory regulatory legal acts;

4.2.4. to the Payment Agent for the purpose of carrying out Transactions (in the manner and scope established by section 3.5.1 of this Policy).

5. Transfer of personal data to third parties

5.1. With the User's consent, the Operator may transfer (provide) the User's personal data to the following counterparties of the Operator (hereinafter — Third Parties):

• Full name: Non-bank credit institution "MONETA" (Limited Liability Company)
• Short name: NBCI "MONETA" (LLC)
• TIN: 1215192632
• KPP: 121501001
• PSRN: 1121200000316 (registration date: 04.06.2012)
• BIC: 042202750
• Correspondent account: 30103810345372202750 with the Volga-Vyatka Main Branch of the Central Bank of the Russian Federation
• Bank of Russia licence: No. 3508-K dated 02.07.2012 for carrying out banking operations
• Registered address: 424000, Republic of Mari El, city of Yoshkar-Ola, Gogolya St., 2
• Official website: https://www.moneta.ru/
• Email for enquiries: help@moneta.ru

5.2. The transfer of personal data to the Payment Agent is carried out in strict accordance with the requirements of:

• Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data";
• Federal Law No. 161-FZ dated 27.06.2011 "On the National Payment System";
• Federal Law No. 115-FZ dated 07.08.2001 "On countering the legalisation (laundering) of proceeds of crime and the financing of terrorism".

5.3. The conditions for processing personal data by the Payment Agent are determined by:

• the settlement agreement concluded between the Operator and NBCI "MONETA" (LLC);
• the User Agreement and Privacy Policy of NBCI "MONETA" (LLC), posted on the official website https://www.moneta.ru/.

5.4. The User consents to the transfer of their personal data, in the scope specified in this section, to the Payment Agent at the moment of initiating a Transaction (clicking the "Pay" button or a similar action confirming the intention to conclude a purchase agreement). Refusal to transfer data to the Payment Agent makes payment and access to the Service's paid features impossible.

6. Updating and destruction of Personal Data

6.1. The Operator updates Personal Data if their inaccuracy is confirmed.

6.2. The Operator destroys Personal Data in the following cases:

6.2.1. there is a threat to the security of the Service;

6.2.2. the storage period for Personal Data has expired;

6.2.3. the purposes of processing the Personal Data have been achieved;

6.2.4. upon the User's request;

6.2.5. upon expiry of the personal data storage period at the Payment Agent (5 years from the date of the Transaction), unless otherwise provided by the legislation of the Russian Federation on countering the legalisation (laundering) of proceeds.

6.3. The Operator deletes all information received from the User if the User withdraws their consent to Processing. From that moment, the right to use the Service ceases. At the same time, withdrawal of consent to the processing of personal data in the part transferred to the Payment Agent does not entail automatic deletion of such data at the Payment Agent if its storage is required by the legislation of the Russian Federation (in particular, Art. 7 of Federal Law No. 115-FZ).

7. Guarantees and rights of the User

7.1. The User guarantees that:

7.1.1. the Personal Data provided are accurate, up to date and do not violate the legislation of the Russian Federation;

7.1.2. if the Personal Data provided relate to a third party, the User has obtained the third party's consent to transfer the Personal Data to the Operator for Processing.

7.2. The User has the following rights:

7.2.1. right of access — the User may request a copy of the personal data held by the Operator;

7.2.2. right to rectification — the User may ask the Operator to correct inaccurate or incomplete personal data;

7.2.3. right to withdraw — the User may withdraw their consent to data processing;

7.2.4. right to erasure — the User may request the deletion of data held by the Operator about the User, except where the Operator is required by law to retain such data;

7.2.5. other rights provided by the Federal Law "On Personal Data";

7.2.6. the right to contact the Payment Agent in the manner established by its Privacy Policy and Terms of Service to clarify, modify or delete personal data transferred as part of carrying out Transactions.

8. Obligations of the Operator

8.1. The Operator is obliged to:

8.1.1. provide, upon the User's request, information about the Processing or a justified refusal;

8.1.2. take measures necessary and sufficient to fulfil the obligations provided by the legislation of the Russian Federation;

8.1.3. upon the User's request, clarify the Personal Data being processed, block or delete them if they are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of Processing;

8.1.4. ensure the lawfulness of Processing. If it is impossible to ensure the lawfulness of Processing, the Operator must, within a period not exceeding 10 working days from the date of detecting unlawful Processing, destroy or ensure the destruction of the Personal Data;

8.1.5. within a period not exceeding 30 days from the date the User's withdrawal of consent is received, cease Processing and destroy the Personal Data if their retention is no longer required for the purposes of Processing. An exception applies where Processing may be continued in accordance with the legislation of the Russian Federation;

8.1.6. ensure the conclusion of an agreement with the Payment Agent containing conditions on ensuring the confidentiality of personal data and the security of their processing in accordance with the requirements of Art. 18, 19 of Federal Law No. 152-FZ.

8.2. To protect Personal Data, the Operator uses the necessary legal, organisational and technical measures in accordance with the requirements of the Federal Law "On Personal Data".

9. Enquiries from the Personal Data Subject

9.1. The User or their representative may send the Operator an enquiry, including withdrawing Consent to Processing in the form of an electronic document, to the email address: support@trychat.io

9.2. An application to withdraw Consent must contain:

9.2.1. information confirming the User's participation in the relationship with the Operator: the email address provided during registration on the Service;

9.2.2. the representative's details and confirmation of their authority (when a representative applies);

9.2.3. the signature of the User (representative);

9.2.4. if the User's enquiry concerns personal data transferred to the Payment Agent, the Operator, within 10 working days, notifies the User of the need to send such an enquiry directly to the Payment Agent, providing the User with the latter's contact details. This is standard practice provided by Art. 14, 20 of Federal Law No. 152-FZ "On Personal Data".

9.3. All correspondence received by the Operator is treated as restricted-access information and is not disclosed without the User's written consent.

10. Final provisions

10.1. The Policy applies exclusively to the Service and does not apply to other internet resources.

10.2. The Policy applies to all Personal Data that the Operator receives from Users.

10.3. The Operator is not liable for the actions of third parties who have gained access to the User's Personal Data through the User's fault.

10.3.1. Responsibility for the processing of personal data transferred to the Payment Agent, as well as for compliance with the legislation of the Russian Federation on personal data and on the national payment system, lies with NBCI "MONETA" (LLC) in accordance with the concluded agreement and the requirements of applicable law. The Operator is not liable for a data leak that occurred through the fault of the Payment Agent or as a result of the actions of third parties beyond the Operator's control.

10.4. The Operator does not verify:

10.4.1. the User's legal capacity;

10.4.2. the accuracy of the Personal Data provided by the User.

10.5. The Operator may make changes to the Policy. A new version of the Policy takes effect from the moment of its publication.

10.6. If the User continues to use the Service after a new version of the Policy takes effect, this will mean that they have agreed to the terms of the new version.

11. Operator details

Individual entrepreneur Kolle Stepan Aleksandrovich

• TIN: 771618757230
• PSRN: 320774600307311
• Email: support@trychat.io