Consent to Personal Data Processing

Version: 20 September 2026.

This consent is given in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" ("Law No. 152-FZ"). The Russian version of this document is the binding original; this English text is a reference translation.

1. Personal Data Operator

Individual Entrepreneur Bunin Ivan Vladimirovich (the "Operator"), OGRNIP 315352800001170, INN 352829204994, address: 162624, Vologda region, Cherepovets, Russia, email: chernobelenkiy@gmail.com.

2. Data Subject

2.1. The data subject is a user (the User) of the vSebe service (the Service) who has separately given this consent.

2.2. Consent is given by a distinct affirmative action after reviewing its text. Use of the Service or acceptance of the User Agreement alone does not give this consent.

3. Purposes of Processing

3.1. The Operator processes personal data for the following purposes:

(a) registration and authentication of the User, including via Google, Yandex and Telegram providers;

(b) provision of Service functionality (text chats with the AI companion, voice mode, personal journal, gallery of generated images, personalised recommendations);

(c) personalisation of AI companion responses based on dialogue history and User preferences;

(d) performance of the agreement, including accepting payments, refunds and issuing receipts under Russian law;

(e) communication with the User regarding Service operations, technical support and handling of complaints;

(f) compliance with Russian legislation;

(g) prevention of fraud and other abuse of Service functionality;

(h) production of aggregated statistics and internal research to improve the Service.

4. Categories of Personal Data

4.1. The Operator processes the following categories of personal data:

- surname, first name, middle name (if applicable);

- email address;

- third-party authentication identifiers (Google ID, Yandex ID, Telegram ID), Telegram username, avatar URL;

- subscription information: type, start date, end date, payment amount, payment identifier;

- content of User chats with the AI companion, journal entries, images generated by the Companion, voice messages and their transcriptions;

- technical data: IP address, device and browser information, cookie data, access timestamps;

- interface language, time zone, user preferences.

- age information, the selected Companion mode, and the version and time of acceptance of its terms.

4.2. This consent does not cover special categories of personal data, including information about health and intimate life. Processing them requires a separate statutory basis. Including such information voluntarily in a message does not replace any required consent in the legally prescribed form.

5. Legal Basis

5.1. Processing is based on the grounds established by Article 6 of Law No. 152-FZ, including: (a) this User consent; (b) performance of a contract to which the User is a party; (c) the legitimate interests of the Operator provided that the rights and freedoms of the User are not violated.

6. Processing Actions

6.1. The Operator performs: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access) to the extent necessary for the purposes of processing, depersonalisation, blocking, deletion, destruction of personal data.

6.2. Processing is carried out both with and without automation (mixed processing).

7. Third-Party Recipients

7.1. For the purposes specified in Section 3, the Operator may transfer personal data to the following categories of third parties:

(a) payment service operators (including LLC NBCO YuMoney, INN 7750005725) — for payment acceptance and refunds;

(b) cloud infrastructure and data storage providers located in the Russian Federation;

(c) providers of the AI models used, through the Russian aggregator Polza.ai (FLEILI LLC, INN 0272928204) — to process messages and the necessary context to generate replies. Processing may occur outside Russia. A lawful basis and compliance with applicable cross-border transfer requirements are necessary. Information about actual recipients, countries, processing and retention terms may be requested at chernobelenkiy@gmail.com;

(d) Yandex.Metrica analytics service — subject to the User's prior consent to the use of cookies and similar technologies;

(e) authorised state bodies — in cases provided for by Russian law.

8. Place of Storage

8.1. Recording, systematisation, accumulation, storage, clarification and extraction of personal data of Russian citizens is performed by the Operator using databases located in the Russian Federation (Article 18 of Law No. 152-FZ).

9. Processing Period

9.1. This consent is valid from the moment it is given and until it is withdrawn by the User or until the purposes of processing have been achieved.

9.2. Personal data is retained for no longer than necessary for the processing purposes. After account deletion, the User may restore the account within 30 calendar days. After that period personal data is deleted automatically, except for data that must be retained by law (e.g. payment records — up to 5 years for tax and accounting purposes).

10. User Rights

10.1. At any time, the User has the right to: (a) obtain information about the processing of personal data (Article 14 of Law No. 152-FZ); (b) require clarification, blocking or destruction of personal data if it is incomplete, outdated, inaccurate, obtained unlawfully or no longer necessary for the declared processing purposes; (c) withdraw this consent by deleting the account in the Settings section, emailing chernobelenkiy@gmail.com or using the /delete command in the Telegram bot; (d) appeal against the actions or inaction of the Operator with the authorised data protection authority (Roskomnadzor) or in court.

11. Withdrawal of Consent

11.1. The User may withdraw consent by: (a) deleting the account in the Settings section of the Service; (b) sending a written request to the Operator's email address: chernobelenkiy@gmail.com.

11.2. After withdrawal, the Operator stops consent-based processing and ensures deletion within the applicable statutory time limits, unless another lawful basis permits continued processing or retention.

12. Security

12.1. The Operator implements organisational and technical measures to protect personal data in accordance with Article 19 of Law No. 152-FZ, including transport encryption, access restrictions, backups and integrity controls.

13. Related Documents

13.1. This consent is a standalone document. The User Agreement and the Privacy Policy are available separately; accepting them does not replace giving this consent.

14. Operator Details

Individual Entrepreneur Bunin Ivan Vladimirovich

Address: 162624, Vologda region, Cherepovets, Russia

INN 352829204994

OGRNIP 315352800001170

Email: chernobelenkiy@gmail.com