Consent to Personal Data Processing

Consent to Personal Data Processing

Who this document applies to. This stand-alone consent is a formal requirement of Russian Federal Law No. 152-FZ (as amended by Federal Law No. 156-FZ of 24 June 2025) and is presented to every User at registration regardless of country of residence. The legal bases for processing are set out exhaustively in our Privacy Policy and include, depending on the User's jurisdiction and the specific processing activity: contractual necessity, legal obligation, legitimate interest and — only where expressly indicated — consent. This document does not, by itself, grant a blanket GDPR Article 6(1)(a) consent: separate, purpose-specific consents are obtained where GDPR or comparable laws require them (for example, analytics and non-essential cookies, direct-marketing communications, and any processing of special-category data).

This Consent is specific, informed, conscious and unambiguous. It is provided freely, of the User's own will and in their own interest. Data processed on other legal bases (Article 6 GDPR / Article 6 of 152-FZ) is not covered by this Consent and is described in the Privacy Policy. The form of this Consent follows the requirements of Article 9 of Russian Federal Law No. 152-FZ (as amended by 156-FZ of 24 June 2025).

1. Data Controller

Self-employed individual Nikolai Ivanovich Dubina, TIN 502997275398, Saint Petersburg, Russian Federation.

Contact email: [email protected]

2. Purposes of Data Processing

• User registration and identification in the Service
• Providing access to Service features (OCR, translation, image generation)
• Payment processing and subscription management
• Security and fraud prevention
• Service quality improvement (with separate consent for analytics cookies)
• Fulfillment of obligations under the Terms of Service
• Sending Service-related notifications
• Hosting and technically supporting publications created by the User via the sharing feature (only upon separate acceptance of the Sharing Terms).
• Handling complaints received from rights holders and other persons regarding User materials and providing the User with procedural rights (notification, counter-notification).
• Demonstrating the Operator's good faith in handling complaints and in defending against court claims (maintenance of an audit log).

3. Personal Data Collected

The following personal data is subject to processing:

• Email address
• Google account identifier (when using Google authentication)
• IP address
• Device and browser data (User-Agent)
• Cookies necessary for Service operation
• Payment data (processed by payment providers; the Controller stores only transaction identifiers)
• Uploaded content (images for translation)
• Display name, if explicitly set by the User to appear next to published materials.
• Data on the User's publications: identifiers, access levels, access-change events, the list of email addresses granted access at the "Allowlist" level, and timestamps of the corresponding actions.
• Version and time of acceptance of the Sharing Terms (share_consent_version, share_consent_accepted_at) — together with an entry in the consent log (ConsentLog).
• Data on disputed publications: related complaints, counter-notifications, measures applied and their timestamps.

Data collected from Visitors and complainants is not subject to this Consent: such processing is carried out on the legal bases listed in the Privacy Policy.

4. Data Processing Actions

The data subject consents to the following data processing actions:

Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), anonymization, blocking, deletion, and destruction of personal data.

5. Data Recipients

Personal data may be transferred to the following third parties:

• Google LLC (Gemini API) — transfer of images and text for OCR and translation. Only uploaded images are transferred, without association with the User's email or payment data.
• YooKassa LLC — processing of card and SBP payments. Data necessary for payment processing is transferred.
• Heleket — processing of cryptocurrency payments. Data necessary for payment processing is transferred.
• Yandex (Yandex.Metrica) — analytics data (IP address, cookies, device data, website behavior). Data is transferred only with separate consent for analytics cookies.
• Google (Google Analytics) — analytics data. Data is transferred only with separate consent for analytics cookies.
• Hosting provider — data storage on servers located in the Russian Federation.
• Rights holders and their authorised representatives — to the extent necessary to resolve a substantiated intellectual-property complaint (does not include email, name or IP address of the User unless required by law or judicial order).
• Competent law-enforcement agencies and courts (including those of the Russian Federation, and, in response to valid international legal process, of any other jurisdiction) — upon a lawful request or by way of proactive disclosure when signs of a criminal offence are detected.
• CDN and service-infrastructure providers — to the minimum technical extent necessary to handle requests to public links.

6. Consent Validity Period

This consent is valid for the entire duration of the User's use of the Service and for 30 (thirty) calendar days after the User's account deletion.

7. Consent Withdrawal

The data subject may withdraw this consent at any time by:

• Sending a written request to [email protected]
• Deleting their account in the Service settings

Upon consent withdrawal, the Controller shall cease processing personal data and destroy them within 30 (thirty) calendar days from the date of withdrawal receipt, except where processing may continue on another lawful basis.

8. Processing Methods

Personal data is processed using automated means and/or without such means, including personal data information systems.

9. Data Localization and International Transfers

Primary collection and recording of personal data of Russian Federation citizens takes place on servers located in the Russian Federation, in accordance with Part 5, Article 18 of Federal Law No. 152-FZ. Subsequent transfers to foreign sub-processors (in particular Google / Gemini API / GCP) are made under EU Standard Contractual Clauses (Commission Decision 2021/914) and, where applicable, the UK International Data Transfer Addendum. Full details are set out in the Privacy Policy, § 5.