Privacy Policy and Personal Data Processing Policy

1. General Provisions, Parties, Purpose of the Document
1.1. This Privacy Policy and Personal Data Processing Policy (hereinafter referred to as the “Policy”) defines the procedure and conditions for the processing of personal data by Individual Entrepreneur Vera Vladimirovna Korsovskaya (TIN: 505101170548, OGRNIP: 319774600731366, Address: 108851, Russia, Moscow, Shcherbinka, Pushkinskaya St., 3-283), acting in accordance with the legislation of the Russian Federation (hereinafter referred to as the “Operator” or “We”), regarding information about an individual which may be obtained by the Operator from such individual or their legal representative (hereinafter referred to as the “User”, “Personal Data Subject”, or “You”) in the following cases:
a) when using the website https://strongpeopleclub.ru, including all domains, subdomains, pages, content, internet services and software offered by the Operator for use on the Website (hereinafter collectively referred to as the “Website”), as well as when using the Operator’s chatbots in messengers (Telegram, WhatsApp and others), operating on the “Salebot” platform and other communication automation services (hereinafter referred to as the “Chatbot”);
b) when the Operator exercises rights and obligations established by agreements/contracts concluded between the Operator and the User;
c) when processing appeals, complaints, requests, and messages exchanged between the Operator and the User.
1.2. The purpose of this Policy is to ensure the proper legal regime for personal data. The Policy may not contain provisions restricting the rights and freedoms of the personal data subject, establishing cases of processing personal data of minors unless otherwise provided by the legislation of the Russian Federation, as well as provisions allowing inactivity of the personal data subject as a condition for concluding an agreement or expressing consent.
2. Legal Basis for Personal Data Processing
2.1. The legal basis for personal data processing includes:
a) consent to personal data processing expressed in the manner established by law and this Policy;
b) agreements concluded between the Operator and the User;
c) local regulatory acts of the Operator in the field of personal data.
2.2. The personal data subject independently decides to provide their personal data and gives consent to its processing freely, voluntarily, and in their own interest. Silence or inactivity of the personal data subject shall not be considered consent. Consent to personal data processing must be specific, informed, conscious, and unambiguous.
3. Rules for Personal Data Processing
3.1. The Operator processes personal data for the purposes of:
• authentication of the personal data subject for entering into service agreements;
• performance of service agreements;
• communication with Users;
• sending notifications, requests, documents, advertising and informational messages;
• processing requests, complaints and communications;
• ensuring operation of the Website and web analytics;
• conducting informational and marketing communications through Chatbots.
3.2. Categories of processed data may include:
surname, first name, patronymic, email address, phone number, messenger username, Telegram ID, WhatsApp ID, browser and device data, IP address, cookie identifiers, history of interaction with Chatbots, session parameters, visited pages, and other technical information.
3.3. Methods of processing include:
collection, recording, systematization, accumulation, storage, updating, modification, extraction, use, anonymization, transfer (access/provision), blocking, deletion, and destruction of personal data.
3.4. Personal data shall be processed and stored until:
• withdrawal of consent;
• receipt of a request to terminate processing;
• expiration of the applicable storage period established by this Policy.
3.5. The Operator applies all necessary legal, organizational, and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, dissemination, and other unlawful actions.
3.6. Disclosure of personal data may be carried out only in accordance with the legislation of the Russian Federation upon request of courts, law enforcement authorities, or other authorized state bodies.
3.7. The Operator does not verify the accuracy of information provided by the personal data subject and assumes that such information is accurate and up to date.
4. Transfer of Personal Data to Third Parties
4.1. The Operator may transfer personal data to third parties in the following cases:
• when assignment or transfer of rights and obligations under agreements takes place;
• to state authorities, courts, and law enforcement agencies where required by law;
• for legal protection of the Operator’s rights;
• where the personal data subject has given consent;
• where such transfer is necessary for performance of agreements.
4.2. The following third parties may process personal data on behalf of the Operator:
• LeadPay — payment processing and fiscal receipts;
• Selectel — hosting and data center services;
• Salebot — chatbot and communication automation services;
• Paywall — payment and subscription services;
• Yandex.Metrica — web analytics;
• Google Analytics — web analytics.
5. Rights of the Personal Data Subject
5.1. The personal data subject has the right to:
• request information regarding processing of personal data;
• withdraw consent to processing;
• request restriction or termination of processing;
• request correction, blocking, or deletion of personal data;
• submit complaints regarding unlawful processing.
5.2. Requests regarding personal data processing may be sent to the Operator’s email address specified in this Policy.
6. Storage and Cross-Border Transfer of Personal Data
6.1. Personal data of citizens of the Russian Federation shall be processed using databases located within the territory of the Russian Federation.
6.2. Before carrying out cross-border transfer of personal data, the Operator shall ensure that the foreign state provides adequate protection of rights of personal data subjects.
7. Cookies and Web Analytics
7.1. The Website uses cookies to ensure proper functioning of the Website, improve usability, analyze traffic and user behavior, and personalize content.
7.2. Users may independently configure browser settings to disable or restrict cookies. Disabling cookies may affect Website functionality.
8. Amendment of the Policy
8.1. The Operator has the right to amend this Policy. The updated version enters into force from the moment of publication on the Website unless otherwise provided.
8.2. The applicable law governing this Policy and relations between the Operator and the personal data subject shall be the law of the Russian Federation.
9. Operator Details
Individual Entrepreneur Vera Vladimirovna Korsovskaya
TIN: 505101170548
OGRNIP: 319774600731366
Address: 108851, Russia, Moscow, Shcherbinka, Pushkinskaya St., 3-283
Email: info@strongpeopleclub.ru
Publication date of this version: May 5, 2026.