Privacy Policy

Version 1.0  ·  Effective date: April 10, 2026
RU EN
⚠️ Informational Translation This is an informational translation provided for convenience only. The legally binding version is the Russian text. In case of any discrepancies, the Russian version prevails.
⚠️ Disclaimer This document is a public offer from the personal data operator. It is prepared in accordance with Federal Law No. 152-FZ "On Personal Data" (as amended on 24.06.2025) and current requirements of Roskomnadzor. By using the FitGeniusAI service, you confirm that you have read this Policy.

1. Personal Data Operator

Entity: Individual entrepreneur / natural person — owner of the FitGeniusAI service

Website: fitgeniusai.ru

DPO Email: dpo@fitgeniusai.ru

Application: FitGeniusAI (iOS / Android / macOS)

Jurisdiction: Russian Federation. This Policy is developed in accordance with Art. 18.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".

2. Terms and Definitions

3. Categories of Collected Data

The Operator collects the following categories of personal data:

DataCollection methodPurposeLegal basis
Email addressWaitlist form on the websiteNotification about service launchConsent (Art. 9 152-FZ)
Email addressRegistration in the applicationAuthorization, notificationsContract performance (cl. 5 Art. 6)
OAuth account data (VKontakte, Yandex, Sber)Authorization via OAuthUser identificationConsent (Art. 9 152-FZ)
IP addressAutomatically upon server accessSecurity, fraud preventionLegitimate interest / security (Art. 19)
Health and physical parameter dataEntered by user in the applicationGeneration of personalized workoutsExplicit consent (Art. 10 152-FZ)
Website behavior data (Yandex.Metrica)Analytical cookiesService improvement, analyticsConsent (Cookie Policy)
Training activity dataEntered/generated by user in the applicationCreation of training programsContract performance

📍 Special Categories of Data

Data on health status and physical parameters (height, weight, fitness level) belong to special categories of personal data under Art. 10 152-FZ. Their processing is carried out exclusively with separate explicit consent from the User, obtained in the FitGeniusAI application during registration. Transfer to third parties is not carried out.

4. Purposes of Personal Data Processing

5. Legal Bases for Processing

BasisNormApplies to
Consent of the PD subjectcl. 1 pt. 1 Art. 6; Art. 9 152-FZEmail waitlist, analytical cookies, marketing
Contract performance with subjectcl. 5 pt. 1 Art. 6 152-FZApplication operation, training data
Ensuring securityArt. 19 152-FZIP addresses, server logs
Explicit consent (special categories)cl. 1 pt. 2 Art. 10 152-FZHealth and physical parameter data

6. Data Storage and Protection

🗄️ Data Localization

In accordance with pt. 5 Art. 18 152-FZ and requirements effective from July 1, 2025, all personal data of citizens of the Russian Federation is collected, recorded, systematized, accumulated, stored, updated, and extracted exclusively using databases located on the territory of the Russian Federation.

🔐 Security Measures

In case of personal data breach, the Operator undertakes to notify Roskomnadzor within 24 hours, and PD subjects — within 72 hours (Art. 21 152-FZ, 2025 ed.).

⏳ Retention Periods

DataRetention period
Email (waitlist)Until consent withdrawal + 30 days, but no more than 12 months from subscription date
Application account dataUntil account deletion + 30 days
Health and workout dataUntil account deletion
IP addresses (logs)30 days
Consent records3 years from the date of consent

7. Data Transfer to Third Parties

The Operator does not sell or transfer personal data to third parties for commercial purposes. Transfer is possible only in the following cases:

RecipientDataPurposeBasis
Yandex (Yandex.Metrica)Behavioral data, cookiesTraffic analyticsUser consent
UnisenderEmail addressSending email notificationsUser consent
VKontakte / Yandex / Sber (OAuth)OAuth identifierAuthenticationUser consent
Russian government authoritiesUpon requestLaw enforcementRF legislation

Cross-border data transfer to third parties outside the Russian Federation is not carried out without prior notification to Roskomnadzor in accordance with pt. 4 Art. 12 152-FZ (2025 ed.).

8. Rights of the Personal Data Subject

In accordance with Art. 14–21 of Federal Law No. 152-FZ, the User has the right to:

To exercise your rights, send a request to dpo@fitgeniusai.ru. The Operator must respond within 10 business days (Art. 20 152-FZ), and in complex cases — no later than 30 days.

9. Consent and Its Withdrawal

Consent for PD processing is provided by the user explicitly by:

Silent consent, pre-checked boxes, and continued use of the site as the sole method of recording consent are not used. Consent can be withdrawn at any time without negative consequences by writing to dpo@fitgeniusai.ru. After withdrawal, data is destroyed within 30 days.

10. Minors

The FitGeniusAI service is intended for users over 18 years of age. The Operator does not intentionally collect personal data of persons under 18 years of age. Upon discovery of such data, it will be immediately deleted.

11. Yandex.Metrica and Analytics

The website uses Yandex.Metrica — a Russian analytical service owned by Yandex LLC (Russia). Yandex.Metrica may use the "Webvisor" feature, which records user actions on the page. Data is processed by Yandex LLC servers on the territory of the Russian Federation in accordance with the Yandex Privacy Policy. You can opt out of analytics through Cookie settings on our website.

12. Notification to Roskomnadzor

The Operator is registered (or is in the process of registration) in the Register of Personal Data Operators of Roskomnadzor in accordance with Art. 22 152-FZ. Operator registration number: [to be entered after submitting notification on pd.rkn.gov.ru].

13. Changes to the Policy

The Operator has the right to make changes to this Policy. The current version is always available at fitgeniusai.ru/privacy. Users will be notified of material changes by email at least 10 days before they take effect. Continued use of the service after the changes take effect means acceptance of the new version of the Policy.

14. Applicable Law and Dispute Resolution

This Policy is governed by the legislation of the Russian Federation. Any disputes are resolved in a pre-trial claim procedure (response period — 30 days), and if no agreement is reached — in court at the Operator's location.

📬 Contact the Data Protection Officer (DPO)

For questions about personal data processing, exercising your rights, or complaints:

Email: dpo@fitgeniusai.ru

Website: fitgeniusai.ru

Roskomnadzor (complaints): pd.rkn.gov.ru