This is an English translation of the Russian-language document «Политика обработки персональных данных». In case of any discrepancy, the Russian version shall prevail.
PERSONAL DATA PROCESSING POLICY (PRIVACY POLICY)
of the website https://klikkai.ru and the Klikk AI platform
Chelyabinsk Version dated October 3, 2026
1. GENERAL PROVISIONS
1.1. This Policy sets out the purposes, conditions and procedure for the processing of personal data by Business Robotics LLC (Obshchestvo s ogranichennoy otvetstvennostyu «Biznes Robotiks»; OGRN 1151690101958, INN 1655343152, address: 5V Kurchatova St., Chelyabinsk, Chelyabinsk Urban District, Chelyabinsk Region, 454048, Russian Federation) (the “Operator”) in connection with the use of the website https://klikkai.ru and its subdomains (the “Website”) and the Klikk AI platform (the “Platform”).
1.2. This Policy is issued in accordance with clause 2 of Part 1 of Article 18.1 of Federal Law No. 152-FZ “On Personal Data” of July 27, 2006 (the “Law”) and is published on the Website in accordance with Part 2 of Article 18.1 of the Law.
1.3. The terms “Account”, “Business User”, “Channel”, “Credentials”, “Materials”, “Result”, “Generation”, “AI Model”, “Provider”, “Plan” and “Credits” have the meanings given to them in the Public Offer (Terms of Service) published on the Website (the “Offer”); other terms have the meanings given to them in the Law.
1.4. This Policy does not apply to third-party websites and services, including the platforms on which Channels are hosted.
1.5. Inquiries regarding the processing of personal data shall be sent to apply@biz-robotics.com or to the Operator’s address specified in clause 1.1 of this Policy.
2. DATA SUBJECTS
2.1. The Operator processes the personal data of:
- visitors to the Website;
- users of the Platform who are individuals, including individual entrepreneurs (the “Users”);
- representatives and employees of legal entities and individual entrepreneurs using the Platform;
- persons who have sent the Operator a request, claim or inquiry;
- third parties whose personal data a User has included in the Materials.
2.2. The Operator does not process the personal data of persons under 18 years of age. If such processing is discovered, the Operator blocks the Account and destroys the personal data, except for the information necessary to refund money to the legal representative.
3. PURPOSES, DATA, LEGAL GROUNDS AND PERIODS OF PROCESSING
3.1. Purposes of processing, categories of data subjects, personal data, legal grounds and periods of processing:
Purpose | Data subjects | Personal data | Legal ground | Processing and retention period |
|---|---|---|---|---|
1. Registration and maintenance of the Account, sending service notifications | Users; representatives and employees of Business Users | Email address. When signing in via Yandex ID — identifier, first name, last name, email address, profile picture to the extent permitted by the User. When signing in via Telegram — identifier, first name, last name, username, profile picture. Confirmation of being 18 or older; information about the Plan and the Credit balance. | Clause 5 of Part 1 of Article 6 of the Law — conclusion and performance of an agreement on the terms of the Offer | Until the Account is deleted; after deletion — destruction within 30 days |
2. Payments, refunds, sending fiscal receipts, accounting and tax records | Users; representatives of Business Users | Last name, first name, patronymic — for refunds and for individual entrepreneurs. Email address or phone number for the fiscal receipt. Amount, date and method of payment; payment identifier; masked bank card number; payment token for auto-renewal. Details of an individual entrepreneur (INN, OGRNIP, address); position of a representative. | Clause 5 of Part 1 of Article 6 of the Law; clause 2 of Part 1 of Article 6 of the Law — performance of obligations under Federal Law No. 54-FZ of May 22, 2003, Federal Law No. 402-FZ of December 6, 2011 and the Tax Code of the Russian Federation | Payment token — until auto-renewal is disabled or the card details are deleted. Primary accounting documents — 5 years after the reporting year (Part 1 of Article 29 of Federal Law No. 402-FZ). Other data — until the agreement is terminated. |
3. Connecting Channels, publishing materials and obtaining reach statistics | Users | Names and identifiers of Channels; publicly available Channel profile information. Credentials (stored in encrypted form). Reach statistics of publications. | Clause 5 of Part 1 of Article 6 of the Law | Until the Channel is disconnected or the Account is deleted |
4. Generation and storage of Results | Users; third parties whose personal data is included in the Materials | Personal data contained in the Materials and Results | Clause 5 of Part 1 of Article 6 of the Law; for third-party data included by a Business User — an operator’s instruction (Part 3 of Article 6 of the Law) | Until the Result is deleted by the User or the Account is deleted |
5. Handling requests, claims and inquiries of data subjects | Users; Website visitors; other applicants | Last name, first name; email address; content of the request; Account and payment information necessary for the response | Clause 5 of Part 1 of Article 6 of the Law; clause 2 of Part 1 of Article 6 of the Law — performance of obligations under the Law and the Law of the Russian Federation “On Consumer Rights Protection” | 3 years from the date of the response |
6. Ensuring the security of the Platform and preventing abuse | Users; Website visitors | IP address; browser and device information; date and time of requests; Account activity logs | Clause 7 of Part 1 of Article 6 of the Law — exercise of the rights and legitimate interests of the Operator | 12 months from the date of recording |
7. Web analytics and improving the Website | Website visitors; Users | Cookies and identifiers of the Yandex Metrica service; IP address; browser and device information; actions on the Website; referral source | Clause 1 of Part 1 of Article 6 of the Law — consent | Until consent is withdrawn, but no longer than 12 months from the date of collection |
3.2. In addition to the grounds specified in clause 3.1 of this Policy, the Operator obtains the User’s consent to the processing of personal data upon registration of the Account.
3.3. The Operator does not process special categories of personal data or biometric personal data and does not make decisions based solely on automated processing that produce legal consequences for the data subject (Article 16 of the Law).
4. PROCEDURE AND CONDITIONS OF PROCESSING
4.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion and destruction of personal data with the use of automation tools, including transmission over the Internet, as well as without the use of such tools.
4.2. Recording, systematization, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the territory of the Russian Federation (Part 5 of Article 18 of the Law).
4.3. Bank card details are entered on the side of the payment service. The Operator does not receive or store the full card number, its expiry date or the security code; the Operator receives a masked card number and a payment token.
4.4. Credentials are used only to publish materials on the User’s instructions and to obtain reach statistics. A Telegram channel is connected by adding the Platform’s bot as a channel administrator; the Operator does not obtain access to the User’s private correspondence. From Channels, the Operator obtains only the reach statistics of publications.
4.5. Only the Materials, to the extent necessary for Generation, are transferred to Providers. Account information (email address, name, payment data) is not transferred to Providers. The Operator does not use the Materials and Results to train artificial intelligence models.
4.6. Processing ceases when the purposes of processing are achieved, when the processing period expires, when consent is withdrawn and there are no other grounds, and when unlawful processing is discovered. Personal data is destroyed within the periods established by Article 21 of the Law.
5. TRANSFER OF PERSONAL DATA
5.1. The Operator transfers personal data within the purposes set out in Section 3 of this Policy to:
- NCO YooMoney LLC (the YooKassa service) and credit institutions through which payments are accepted, including via the Faster Payments System — for payments and refunds;
- the fiscal data operator — for sending fiscal receipts;
- YANDEX LLC — for authorization via Yandex ID and web analytics using the Yandex Metrica service;
- persons providing the Operator with computing capacity and data storage services in the territory of the Russian Federation — on the Operator’s instructions;
- electronic document management operators — for exchanging documents with Business Users;
- Providers, including foreign ones — for Generation;
- owners of the platforms on which Channels are hosted — for publishing materials on the User’s instructions;
- public authorities — in cases provided for by law.
5.2. Processing of personal data is entrusted to a third party on the basis of an agreement containing the conditions provided for by Part 3 of Article 6 of the Law.
6. COOKIES
6.1. The Website uses necessary cookies — for authorization, maintaining the session and ensuring security, and analytical cookies — for web analytics using the Yandex Metrica service.
6.2. Analytical cookies are used only after consent given by the visitor by clicking the “Accept” button in the cookie notice. The visitor may refuse analytical cookies in the notice or delete them in the browser settings.
7. RIGHTS OF THE DATA SUBJECT
7.1. The data subject has the right to receive the information specified in Part 7 of Article 14 of the Law; to demand clarification, blocking or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing; to withdraw consent; and to appeal against the Operator’s actions to the authorized body for the protection of the rights of personal data subjects or to a court.
7.2. A request shall be sent to apply@biz-robotics.com from the email address specified in the Account, in the form of an electronic document signed with an electronic signature, or to the Operator’s postal address, and must contain the information specified in Part 3 of Article 14 of the Law.
7.3. The Operator provides information upon request within 10 business days from the date of its receipt. This period may be extended by no more than 5 business days with a reasoned notice (Part 1 of Article 20 of the Law).
7.4. Consent is withdrawn by sending a request to apply@biz-robotics.com. After consent is withdrawn, the Operator ceases processing and destroys the personal data within 30 days, unless there are other grounds for processing (Part 2 of Article 9, Part 5 of Article 21 of the Law).
8. PERSONAL DATA SECURITY
8.1. The Operator takes the measures provided for by Articles 18.1 and 19 of the Law, including:
- appointing a person responsible for organizing the processing of personal data;
- issuing internal regulations on the processing and protection of personal data and familiarizing employees with them;
- determining security threats and the level of protection of personal data in accordance with the requirements approved by Decree of the Government of the Russian Federation No. 1119 of November 1, 2012;
- restricting access to personal data and keeping records of actions with it;
- using encryption for data transmission and for the storage of Credentials;
- performing backups and anti-virus protection.
8.2. If an unlawful or accidental transfer of personal data resulting in a violation of the rights of data subjects is discovered, the Operator notifies the authorized body for the protection of the rights of personal data subjects within 24 hours, and of the results of the internal investigation within 72 hours (Part 3.1 of Article 21 of the Law).
9. FINAL PROVISIONS
9.1. This Policy is valid indefinitely until it is replaced by a new version. A new version takes effect upon publication on the Website, unless otherwise provided therein.