This Privacy Policy (hereinafter, the “Policy”) has been developed in accordance with Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006 and defines the procedure for processing and protecting the personal data of users of the “Klatto” service, hosted at klatto.com and accessible via the Telegram bot @bitiy_pixel_bot (hereinafter jointly, the “Service”).
01General provisions
The personal data Operator (hereinafter, the “Operator”) is:
Individual Entrepreneur Pushkin Timofey Denisovich
TIN: 781710381627
OGRNIP: 326784700058213
E-mail: klatto.ai@yandex.ru
By using the Service, the User confirms that they have read this Policy and agree to its terms, as well as to the terms of the Public Offer and the Personal Data Processing Consent.
02Key definitions
- Personal data — any information relating to a directly or indirectly identified or identifiable natural person (data subject).
- Personal data processing — any action (operation) or set of actions (operations) performed with personal data, whether using automation tools or not.
- User — the natural person using the Service.
- Cookies — small text files stored on the User's device to keep the Service running and to collect analytics data.
03Categories of personal data processed
The Operator processes the following categories of User data:
- identifiers and contact details: Telegram ID, first name, last name, username, phone number (if provided by Telegram), e-mail (when using e-mail sign-in), OAuth provider identifiers (Google, VK, Yandex);
- payment and subscription data: amount, status, payment date, payment ID in the YooKassa payment system; bank card details are not transmitted to the Operator;
- user content: images, texts and other materials the User uploads to the Service to generate product cards;
- technical data: IP address, device type, browser type and version, operating system, interface language, visit parameters, UTM/yclid/gclid advertising tags;
- data on activity within the Service: generation history, support inquiries, ratings and reviews, plans used, and referral codes.
04Purposes of personal data processing
The Operator processes personal data for the following purposes:
- providing access to the Service and its functionality;
- identifying the User and ensuring account security;
- performing settlements and fulfilling obligations to the User for paid services;
- informing the User about new features, promotions, plans and Service updates;
- processing inquiries and providing technical support;
- researching, analyzing and improving Service quality (including via web analytics systems);
- complying with the requirements of the legislation of the Russian Federation.
05Legal grounds for processing
The legal grounds for processing personal data are:
- the consent of the data subject, expressed when using the Service;
- the conclusion and performance of a contract to which the data subject is a party (the Public Offer);
- fulfilling obligations imposed on the Operator by the legislation of the Russian Federation (including tax and financial legislation).
06Processing procedure and periods
Personal data is processed both with and without the use of automation tools. The Operator ensures the recording, systematization, accumulation, storage, clarification, extraction, use, transfer (provision, access), blocking, deletion and destruction of personal data.
Personal data is stored in a form that allows the data subject to be identified for no longer than required by the purposes of processing. Financial and payment information is stored in accordance with the requirements of the legislation of the Russian Federation (at least 5 years).
Processing is terminated once the processing purposes are achieved, upon expiry of the consent, or upon its revocation by the User, unless otherwise provided by law.
07Transfer of personal data to third parties
The Operator does not sell personal data. Data is transferred to third parties only to the extent and in cases necessary to provide the Service's services, in particular:
- the YooKassa payment system (NKO YooMoney LLC) — for processing payments;
- infrastructure providers (hosting providers) — for hosting and operating the Service;
- Yandex.Metrica web analytics services — for analyzing user behavior in anonymized form;
- OAuth providers (Google, VK, Yandex) — when the User uses the corresponding sign-in method;
- email delivery services — for sending service and marketing messages (only with the User's consent);
- authorized government bodies of the Russian Federation — upon their lawful request.
08Cookies and analytics
The Service uses cookies and similar technologies to maintain sessions, interface settings, and to collect anonymized visit statistics (including via Yandex.Metrica and WebVisor). The User can disable cookies in their browser settings, but this may limit the Service's functionality.
09Rights of data subjects
The User has the right to:
- receive information about the processing of their personal data;
- request the clarification, blocking or destruction of their personal data;
- withdraw previously given consent to the processing of personal data;
- appeal the actions or inaction of the Operator to Roskomnadzor or in court.
Requests are sent to: klatto.ai@yandex.ru. Response time — no more than 30 days from receipt of the request.
10Protection of personal data
The Operator takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, disclosure, distribution, and other unlawful actions: encryption of the communication channel (HTTPS), access-rights separation, secure storage of passwords and tokens, regular backups, and security monitoring.
11Changes to the Policy
The Operator has the right to amend this Policy. The current version is always available at /app/legal/privacy. Material changes are published within the Service and/or sent to the User via available communication channels.
12Contacts
For all questions related to the processing of personal data, please contact:
Individual Entrepreneur Pushkin Timofey Denisovich
TIN: 781710381627 · OGRNIP: 326784700058213
E-mail: klatto.ai@yandex.ru
Telegram support: @bitiy_pixel_support
