Personal Data Processing Policy
Published: March 6, 2026
1. Terms and Definitions
The following terms are used in this Policy:
- Operator — Individual Entrepreneur Grezin Evgeniy Alekseevich, TIN: 505311379909, OGRNIP: 318774600022223.
- Service — software accessible at https://kotia.app.
- User — an individual using the Service; a personal data subject.
- Personal Data — any information relating directly or indirectly to an identified or identifiable User.
- Processing — any action or set of actions performed on personal data, whether by automated means or otherwise.
2. General Provisions
This Policy defines the procedure for processing Users' personal data and ensuring their security and confidentiality. The Policy specifies:
- what personal data the Operator collects and how it is used;
- the fundamental rights of Users as data subjects;
- methods, terms, and storage periods for personal data;
- the procedure for personal data destruction.
The Operator processes personal data on the basis of a contract with the User (clause 5, part 1, article 6 of Federal Law No. 152-FZ "On Personal Data"), as well as consent provided during registration on the Service.
3. Personal Data Processing
Types of processing: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, blocking, deletion, destruction.
The User agrees to this Policy upon registration on the Service.
The personal data processed by the Operator is not biometric and does not fall into special categories.
The Service is not intended for persons under 18. If you believe a minor has provided their data, please contact us at hello@kotia.app.
The Operator processes the following personal data:
- Registration and authorization: email address, username (nickname). Category: general. Term: until the purpose is achieved or consent is withdrawn.
- Service operation: IP address, cookies, browser type, operating system. Category: general. Term: until the purpose is achieved or consent is withdrawn.
Destruction procedure for all categories: deletion from the Operator's database.
Methods of personal data collection:
- through registration and authorization forms on the Service;
- via email and messengers;
- automatically using technologies and cookies.
The Operator stores personal data:
- exclusively on properly protected electronic media;
- using databases located on the territory of the Russian Federation.
4. Access to Personal Data
The Operator provides personal data only to its authorized employees.
The Operator does not distribute or provide Users' personal data to third parties without consent, except in the following cases:
- transfer to components and databases that are part of the Service;
- prevention of unlawful actions by the User, protection of the Operator's legitimate interests;
- upon a justified request from courts or government authorities in cases provided by Russian law.
5. Transfer of Personal Data to Third Parties
With the User's consent, the Operator may transfer personal data to the following counterparties:
- Stripe, Inc. — internet acquiring, payment processing.
- Google LLC — web analytics provider (Google Analytics).
The User has the right to prohibit the Operator from transferring their personal data to third parties.
Transfer is terminated upon the User's request sent to hello@kotia.app specifying the email address and the list of data whose processing should be stopped.
6. Updating and Destruction of Personal Data
The Operator updates personal data when their inaccuracy is confirmed.
The Operator destroys personal data in the following cases:
- a security threat to the Service;
- expiration of the data storage period;
- achievement of the data processing purposes;
- upon the User's request.
Upon withdrawal of consent, the Operator deletes all received information. From that moment, the right to use the Service is terminated.
7. User Rights
The User has the following rights:
- Right of access — to request a copy of the personal data held by the Operator.
- Right to rectification — to request correction of inaccurate or incomplete personal data.
- Right to withdraw — to withdraw consent to data processing.
- Right to erasure — to request deletion of data, except where the Operator is required by law to retain it.
- Other rights provided by Federal Law No. 152-FZ "On Personal Data".
8. Operator Obligations
The Operator is obligated to:
- provide information about processing upon the User's request, or a justified refusal;
- take measures necessary to fulfill obligations under Russian law;
- upon the User's request, clarify, block, or delete personal data if it is incomplete, outdated, inaccurate, or unlawfully obtained;
- ensure lawful processing; if unlawful processing is detected, destroy the data within 10 business days;
- within 30 days of consent withdrawal, cease processing and destroy personal data unless retention is required for processing purposes.
To protect personal data, the Operator implements necessary legal, organizational, and technical measures in accordance with Federal Law No. 152-FZ.
9. Data Subject Requests
The User or their representative may submit a request, including consent withdrawal, to the email address: hello@kotia.app
A consent withdrawal request must include:
- the email address used for registration on the Service;
- representative details and authorization (if submitted by a representative).
The Operator reviews and responds within 10 business days of receiving the request.
All correspondence is treated as restricted information and is not disclosed without the User's written consent.
10. Final Provisions
This Policy applies exclusively to the Service and does not extend to other internet resources.
The Operator may amend this Policy. The new version takes effect upon publication.
Continued use of the Service after Policy changes constitutes agreement with the new version.
Operator Details
Individual Entrepreneur Grezin Evgeniy Alekseevich
TIN: 505311379909
OGRNIP: 318774600022223
Nagatinskaya nab., 34, apt. 258, 115470, Moscow, Russia
Email: hello@kotia.app
Telegram: @kotia_app