Privacy Policy and Personal Data Processing

This English version is provided for convenience only. In case of any discrepancies, the Russian version published at https://numerium.ru/ru/privacy.html shall prevail.

This Policy sets out the rules for processing and protecting personal data of users of the Numerium service and is prepared in accordance with Federal Law No. 152-FZ “On Personal Data” and other applicable regulations of the Russian Federation.

1. General provisions

1. Personal data operator: Individual Entrepreneur Khoroshilov Maksim Viktorovich, TIN 222406865102, OGRNIP 325774600823872 (the “Operator”).
2. This Policy applies to all personal data that the Operator may receive from the User when using:
   • the website https://numerium.ru;
   • the Telegram bot @numerium_bot;
   • related pages and interfaces of the Service.
3. By using the Service, the User confirms that they have read this Policy. Where processing is based on consent, the User provides consent by performing actions in the interface (entering data, clicking consent buttons, continuing to use the Service after reading, etc.).

2. Terms

1. Personal data — any information relating to an identified or identifiable natural person.
2. Processing of personal data — any action (operation) or set of actions performed on personal data, including collection, recording, systematization, accumulation, storage, updating, use, transfer, depersonalization, blocking, deletion, destruction.
3. User — a person using the Service.
4. Third parties (processors) — persons to whom the Operator delegates processing under an agreement or who process data as independent operators (e.g., payment providers / Telegram).

3. What data we collect

The Operator may process the following categories of data (depending on the usage scenario):

1. Data provided by the User:
   • name (and other profile details provided voluntarily);
   • date of birth;
   • gender (if requested during onboarding and provided by the User);
   • text messages/questions entered in the Bot;
   • e-mail (if the User contacts support or leaves a contact);
   • other information the User voluntarily provides in messages/forms.
2. Technical data collected automatically:
   • website interaction data (IP address, browser/device information, visit date and time, cookies, log data);
   • technical identifiers and metadata of interaction with the Bot within Telegram capabilities (e.g., Telegram ID/username, interface language, subscription status/payment events to the extent available to the Operator).
3. Payment data: The Operator does not store bank card details. Payment information (payment fact, amount, date, status) may be transferred to the Operator by a payment provider/Telegram to the extent necessary to provide access and for accounting/tax purposes.

4. Purposes of personal data processing

The Operator processes personal data for the following purposes:

1. Providing Service functionality, including personalization of content and generation of numerological outputs based on the data provided.
2. Managing subscriptions, granting/restricting access to paid features, processing payments and confirming payment status.
3. Communication with the User (support requests, notifications related to the Service, important changes).
4. Improving the Service and analytics of website usage (including via cookies and analytics tools).
5. Complying with legal requirements (accounting, tax reporting, responding to lawful requests).

5. Legal bases for processing

The Operator processes personal data on the following legal bases:

1. Performance of the agreement (Public Offer) with the User — for data required to provide the Service and manage the subscription.
2. User’s consent — for cases where consent is required (e.g., certain communications), if applicable.
3. Legitimate interest of the Operator — to ensure Service security, prevent abuse, improve the Service, and maintain quality.
4. Legal obligation — where processing is required by applicable law.

6. Processing conditions, storage and retention

1. Processing is performed using automated tools and, where necessary, without automation.
2. Personal data is stored for the period necessary to achieve the processing purposes, unless a longer period is required by law.
3. Messages and inputs in the Bot may be stored to provide the Service, maintain the archive of results and improve quality, unless the User requests deletion where applicable.

7. Transfer of data to third parties

1. The Operator may transfer data to third parties only to the extent necessary to provide the Service (e.g., Telegram, payment providers, hosting/IT providers, analytics providers).
2. Such parties process data on the basis of contracts and/or their own policies and within the scope required for their services.

8. Cross-border transfers

If cross-border transfer occurs (for example, when using foreign hosting or IT services), it is carried out in compliance with applicable requirements of the Russian Federation and with measures to protect data.

9. Cookies and website analytics

1. The website may use cookies and similar technologies to ensure proper operation and to analyze usage.
2. Analytics tools may be used (including Yandex.Metrika) to collect aggregated statistics about visits and behavior on the website.
3. The User can restrict the use of cookies in the browser settings; however, some website functions may become unavailable.

10. User rights

The User has the right to:

1. receive information about the processing of their personal data;
2. request clarification, blocking, or deletion of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose;
3. withdraw consent where processing is based on consent;
4. file complaints with a competent authority, as provided by applicable law.

11. Personal data protection

The Operator takes organizational and technical measures to protect personal data from unauthorized access, alteration, disclosure, destruction, and other unlawful actions.

12. Age restrictions

The Service is intended for users who have reached the age allowed by applicable law. If you are under the required age, please do not use the Service or provide personal data without consent of a legal representative.

13. Operator contacts

1. E-mail: team@numerium.ru
2. Website: https://numerium.ru

14. Policy changes

The Operator may amend this Policy. The current version is published on the website at the addresses indicated above. Continued use of the Service after publication of changes means acceptance of the updated Policy.