Personal Data Processing Policy

2. Legal Basis for Personal Data Processing

The Operator processes personal data on the following grounds:

• Consent of the data subject (Art. 6(1)(1), Art. 9 of 152-FZ) — provided by pressing the /start command in the Bot and completing the onboarding procedure
• Performance of a contract to which the data subject is a party (Art. 6(1)(5) of 152-FZ) — the Terms of Service (public offer) published on the Website at redakto.ai/en/terms/
• Legitimate interests of the Operator (Art. 6(1)(7) of 152-FZ) — improving the quality of the Service, website usage analytics

3. Categories of Personal Data Processed

3.1. Data received via Telegram API

• Telegram user identifier (telegram_id)
• Telegram username
• First and last name (if specified in the Telegram profile)

3.2. Data received during Service usage

• Content of connected Telegram channels (for writing style analysis)
• User settings (timezone, publication schedule, content sources)
• History of generated posts and moderation actions (approval, rejection, editing)
• Subscription plan and status data

3.3. Data received during payment

• Transaction details (amount, date, status) via payment systems Telegram Stars, YooKassa, Prodamus
• The Operator does not process or store Users' payment details (card numbers, CVV, etc.) — processing is performed directly by the payment providers

3.4. Data collected automatically on the Website

• IP address
• Browser type and version, operating system
• Referral source (referer)
• Website behavior (pages viewed, time on site, clicks)
• Cookies (via Yandex Metrika service)

4. Purposes of Personal Data Processing

The Operator processes personal data for the following purposes:

• Providing the User with access to the Service functionality
• User identification when using the Service
• Channel writing style analysis for content generation
• Payment processing and subscription management
• Sending notifications to the User about Service operation (via the Bot)
• Improving the quality of the Service and analyzing usage statistics
• Fulfilling obligations under the Terms of Service
• Compliance with the legislation of the Russian Federation

5. Procedure and Conditions for Personal Data Processing

5.1. Processing methods: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), anonymization, blocking, deletion, destruction.

5.2. Processing means: processing is carried out using automated means (information systems).

5.3. Processing period: personal data is processed until the User deletes their account (/delete_account command in the Bot or a request to support@redakto.ai) or until consent is withdrawn.

5.4. Log retention: action and operation records are stored for 90 (ninety) days from the date of creation, after which they are automatically deleted.

5.5. Data deletion: upon account deletion, the following data is destroyed: User profile, connected channel data, content sources, publication queue, generated posts, style profiles, subscription data. Deletion is irreversible.

6. Transfer of Personal Data to Third Parties

6.1. Cross-border transfer of personal data

Users' personal data is stored and processed on servers located in the Netherlands (hosting provider Timeweb, Amsterdam). Server placement outside the Russian Federation is due to technical necessity: ensuring minimal latency when interacting with the Telegram API.

The Netherlands is a member state of the European Union, providing adequate protection of data subjects' rights in accordance with Regulation (EU) 2016/679 (GDPR).

Cross-border transfer is carried out in accordance with Art. 12 of 152-FZ.

6.2. List of third parties with access to personal data

6.3. The Operator does not sell, transfer, or distribute personal data to third parties for marketing or advertising purposes.

6.4. The Operator may transfer personal data upon request of authorized government bodies of the Russian Federation in cases provided by law.

7. Rights of the Data Subject

The User has the right to:

• Obtain information regarding the processing of their personal data (Art. 14 of 152-FZ), including: confirmation of processing, legal grounds and purposes, methods used, name and location of the Operator, processing and storage periods
• Require the Operator to clarify their personal data, block or destroy it if the data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing (Art. 14(2) of 152-FZ)
• Withdraw consent to personal data processing by sending a corresponding request to support@redakto.ai (Art. 9(2) of 152-FZ)
• Delete their account and all associated data using the /delete_account command in the Bot or by sending a request to support@redakto.ai
• Appeal the actions or inaction of the Operator to the authorized body for the protection of data subjects' rights — Roskomnadzor (77, Moscow, Sadovaya-Sukharevskaya St., 16; rsoc.ru)

Contact procedure. Requests and inquiries should be sent to support@redakto.ai. The Operator's response time is 10 (ten) business days from receipt. Request fulfillment time is 30 (thirty) business days.

8. Personal Data Protection Measures

8.1. Organizational measures

• Appointment of a person responsible for organizing personal data processing — IE Smoleychuk R.A.
• Familiarization of persons processing personal data with legislative requirements and internal documents
• Internal monitoring of personal data processing compliance with 152-FZ requirements

8.2. Technical measures

• Data encryption during transmission over communication channels (TLS/SSL)
• Access control to information systems containing personal data
• Encrypted storage of API keys and tokens (environment variables / Vault)
• Action logging in information systems
• Request rate limiting to prevent unauthorized access

9. Cookies

9.1. The website redakto.ai uses cookies through the Yandex Metrika service (Yandex LLC).

9.2. Types of cookies used:

• Technical — necessary for the proper functioning of the Website
• Analytical — used to collect anonymized visitor statistics

9.3. The User may disable cookies in their browser settings. Disabling cookies may affect the availability of certain Website features.

9.4. By continuing to use the Website, the User consents to data processing using cookies.

10. Final Provisions

10.1. The Operator reserves the right to make changes to this Policy without prior notice to Users. The current version of the Policy is posted on the Website at redakto.ai/en/privacy/.

10.2. The new version of the Policy takes effect from the moment of its publication on the Website, unless otherwise provided by the new version.

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

10.4. For all questions related to personal data processing, the User may contact us at: support@redakto.ai.

10.5. This version of the Policy takes effect on April 1, 2026.