1. General provisions
1.1. This policy sets out how personal data of users of And Action AI (the bot @and_action_ai_bot, the Mini App and the website and-action-ai.ru) is processed and protected in accordance with Russian Federal Law No. 152-FZ “On Personal Data”.
1.2. The data operator is Mikhail Volkov, self-employed, TIN (INN) 784001231801, email and-action-ai@mail.ru (the “Operator”).
1.3. Photos and other data uploaded to the Mini App are processed on the basis of a separate Data Processing Consent.
2. Data we process
- Telegram data: user ID, name, username, interface language.
- Hero photo — including a photo of a minor uploaded by their parent or legal guardian — and the character reference created from it.
- Texts: idea and script descriptions entered by the User.
- Created Videos and Storyboard frames.
- Payment data: amount, currency, method, status, invoice number, date. The Operator does not receive bank card data — it is processed by the payment provider.
- Technical data: Service logs (request times, errors), IP address when visiting the website.
- Cookies and Yandex Metrica data on the website — only with the visitor’s consent (section 9).
The Operator does not use facial images to identify a person and does not process biometric personal data.
3. Purposes
- creating Videos and providing the Service’s features;
- accepting payments, accounting for tokens, issuing receipts, refunds;
- notifications about finished Videos, subscriptions and charges;
- content moderation and preventing violations;
- user support and handling requests;
- compliance with tax law;
- website traffic analysis (with cookie consent).
4. Legal grounds
Performance of a contract with the User (Art. 6(1)(5) of 152-FZ) — for the account, payments and notifications; the User’s consent (Art. 6(1)(1)) — for processing photos and cross-border transfer; legal obligations — for tax accounting.
5. Retention
| Data | Period |
|---|---|
| Original photo and character reference | until the Video is assembled, at most 24 hours if the Storyboard is not rendered |
| Finished Videos | 30 days or until deleted by the User |
| Account data and texts | until the account is deleted |
| Payment data | 5 years (tax accounting) |
| Logs | up to 90 days |
6. Recipients
- Telegram — to operate the bot, the Mini App and Telegram Stars payments.
- YooKassa (NBCO YooMoney LLC) — to accept card, SBP and SberPay payments.
- Selectel JSC — hosting: servers, the database and file storage are located in the Russian Federation. Personal data of Russian citizens is recorded, systematised, accumulated and stored in databases located in Russia (Art. 18(5) of 152-FZ).
- Neural network providers — photos, texts and frames are transferred to create Videos, including to providers whose servers are located outside Russia (cross-border transfer). The list of countries will be published once providers are selected.
- Yandex LLC — Yandex Metrica on the website, only with cookie consent.
The Operator does not sell personal data or share it for third-party advertising.
7. Security
The Operator applies organisational and technical measures: encrypted connections (HTTPS), access control, secrets stored separately from code, limited photo retention, backups.
8. User rights
The User may request information about the processing of their data, its correction, blocking or deletion, withdraw consent, and delete Videos and the account. Requests are sent to the bot @and_action_ai_bot or to and-action-ai@mail.ru; we reply within 10 business days. The User may also contact Roskomnadzor.
9. Cookies
9.1. The website and-action-ai.ru uses Yandex Metrica cookies to analyse traffic and advertising effectiveness: which pages are viewed, where visitors come from, whether they click the button to open Telegram.
9.2. Metrica is loaded only after the visitor clicks “Accept” in the cookie notice. If they click “Decline”, Metrica is not loaded. The choice is stored in the browser; to change it, clear the site data in the browser.
9.3. The Mini App does not use advertising cookies.
10. Children
The Service is used by adults. A photo of a minor is uploaded by their parent or other legal guardian, who consents to processing on the child’s behalf.
11. Changes
The Operator may amend this policy by publishing a new version on and-action-ai.ru. The current version is always available on this page.