CONSENT TO PERSONAL DATA PROCESSING
for the Нейроцентр mobile application
I, acting freely, of my own will, and in my own interest, consent to Individual Entrepreneur Parshin Pavel Borisovich (the “Operator”) processing my personal data when I use the Нейроцентр mobile application (the “Application”) on the following terms.
1. CATEGORIES OF PERSONAL DATA
This consent is granted for processing the following data.
1.1. Identification and account data
- internal user identifier;
- device identifier;
- account data used for authorization and synchronization, if provided by the user.
1.2. User content
- text requests and descriptions for generation;
- photos and other images uploaded by the user;
- image and video generation parameters;
- generated images;
- generated videos;
- generation history.
1.3. Technical data
- device type and model;
- operating system version;
- Application version;
- interface language and region;
- IP address, where required for operation and protection of the service;
- error and performance data;
- Application usage logs;
- information about the number of Image Tokens and Video Tokens used.
1.4. Subscription and payment data
The Operator may process:
- information about the selected tariff;
- subscription status;
- subscription commencement, renewal, or termination date;
- transaction identifier;
- payment amount and currency;
- information about tokens credited and used.
Bank card data is processed by payment services, including Robokassa LLC, Google Play, and Apple App Store.
The Operator does not receive or store full bank-card details, including the card number, expiry date, and security code.
2. PURPOSES OF PROCESSING
Personal data is processed for:
- providing access to Application functionality;
- AI-powered image generation;
- video generation from text requests and images;
- processing uploaded photos and other materials;
- storing and displaying generation history;
- performing obligations under the Public Offer;
- managing the Нейроцентр PRO subscription;
- crediting, accounting for, reserving, and deducting Image Tokens and Video Tokens;
- restoring purchases and synchronizing user data;
- processing payments and confirming payment;
- providing technical support;
- diagnosing errors and ensuring stable Application operation;
- preventing fraud, abuse, and violations of service rules;
- improving the Application;
- analytics, including use of anonymized data;
- complying with the legislation of the Russian Federation.
3. PERSONAL DATA PROCESSING OPERATIONS
The Operator may process personal data by automated, non-automated, and mixed means.
Processing includes:
- collection;
- recording;
- systematization;
- accumulation;
- storage;
- clarification and updating;
- retrieval;
- use;
- transfer and provision;
- anonymization;
- blocking;
- deletion;
- destruction.
4. DISCLOSURE OF DATA TO THIRD PARTIES
The Operator may disclose personal data to the following categories of recipients to the extent necessary for Application operation.
4.1. Payment services
- Robokassa LLC, to process user payments;
- Google Play, for purchases through Google Play Billing;
- Apple App Store, for purchases through In-App Purchases.
4.2. AI providers
Third-party image and video generation services, including Kling and other AI technology providers, may receive:
- text requests;
- uploaded images;
- generation parameters;
- other data necessary to fulfill the user’s request.
4.3. Cloud and technical services
Data may be transferred to organizations that provide:
- data storage and processing;
- server infrastructure operation;
- notification delivery;
- error diagnostics;
- Application analytics and technical support.
4.4. Government authorities
Data may be transferred to government authorities and other authorized persons in cases and according to the procedure provided by the legislation of the Russian Federation.
5. CROSS-BORDER TRANSFER
When foreign AI providers, application stores, cloud, or technical services are used, personal data may be transferred to foreign countries.
Such transfer is made to the extent necessary to provide Application functions and in compliance with the legislation of the Russian Federation.
6. RETENTION PERIODS
Personal data is retained no longer than required for the purposes of processing unless a different period is prescribed by law.
Expected retention periods:
- generation history, uploaded content, and generated content: up to 90 days;
- account data: for the duration of Application use and up to 36 months after the last activity, unless longer retention is required by law;
- payment and transaction information: for the period established by law and the rules of payment services;
- the Operator does not store full bank-card data.
After the processing purposes are achieved or consent is withdrawn, data is deleted or anonymized unless further retention is required by law.
7. USER RIGHTS
I have been informed that I have the right to:
- receive information about processing of my personal data;
- request access to personal data;
- require clarification, blocking, or deletion of incomplete, outdated, inaccurate, or unlawfully processed data;
- withdraw this consent;
- challenge the Operator’s actions or inaction;
- exercise other rights provided by the legislation of the Russian Federation.
8. WITHDRAWAL OF CONSENT
Consent may be withdrawn by sending a request to nowaka67@op.pl.
The request should include information enabling identification of the user and their account.
Upon receiving a withdrawal, the Operator stops processing and deletes personal data unless other lawful grounds for continued processing exist.
Withdrawal of consent may result in:
- deletion of the account;
- deletion of generation history and user content;
- termination of data synchronization;
- inability to use certain functions or the entire Application.
Withdrawal of consent does not affect the lawfulness of processing performed before its receipt.
9. TERM OF CONSENT
This consent is valid from the moment it is granted until:
- the purposes of personal data processing are achieved;
- use of the Application ceases and the established retention periods expire;
- the user withdraws consent;
- the Operator ceases operations.
10. CONFIRMATION OF CONSENT
I confirm that:
- I have read the Нейроцентр Privacy Policy;
- I have read the Нейроцентр User Agreement;
- I have read the Нейроцентр Public Offer;
- I understand the purposes and terms of personal data processing;
- I provide data voluntarily;
- I confirm that I have lawful grounds to upload and process images of third parties.
Consent must be granted through a separate user action, such as selecting a separate checkbox and clicking “Accept” or “Continue”.
Consent to personal data processing must be separate from the User Agreement, the Public Offer, and other documents being confirmed. This complies with the current version of Article 9 of Federal Law No. 152-FZ.
11. OPERATOR INFORMATION
Individual Entrepreneur Parshin Pavel Borisovich
TIN: 540234914672
PSRNIE: 319547600050728
12. CONTACTS
For questions about processing, deletion, or correction of personal data:
Email: nowaka67@op.pl