Privacy Policy

This Policy sets out how the personal data of users of the AGINE Academy service (the "Service"), available at academy.agineai.com, is processed.

The personal data operator (the "Operator") is the Individual Entrepreneur Lekhovitskaya. Contact for data-processing matters: privacy@agineai.com.

By using the Service, you confirm your agreement with this Policy. If you do not agree with its terms, please stop using the Service.

While you use the Service, the Operator processes the following data:

• Identity: email address, name (optional), password (stored as a hash)
• Payment: transaction history (without storing card data), subscription status
• Technical: IP address, device and browser information, cookies
• Behavioural: lesson progress, downloaded skills, time of use
• Onboarding: answers to questions about your business (optional)

Bank card payment data is processed exclusively by the CloudPayments payment system in accordance with the PCI DSS standard. The Operator has no access to card data.

Personal data is processed for the following purposes:

• Providing access to the Service and its features
• Identifying and authenticating the User
• Processing payments and managing the subscription
• Sending service notifications (payments, security, changes to terms)
• Improving the Service and analysing user behaviour in anonymised form
• Performing obligations under the Offer Agreement

Processing is carried out on the following grounds:

• Consent of the data subject (Article 6(1)(1) of No. 152-FZ)
• Performance of a contract to which the subject is a party (clause 5)
• Achieving the Operator's legitimate aims while respecting the subject's rights (clause 7)

Data is kept for the duration of the subscription and for 3 years after it ends, for accounting and tax purposes and for the possible resolution of disputes.

After this period, data is deleted or anonymised. At the User's request, data may be deleted earlier (see Section 8).

The Operator engages the following data processors:

• Supabase (Frankfurt, Germany) - storage of accounts and application data. GDPR-compliant.
• Vercel (USA, EU) - application hosting. Transfers to the USA are made on the basis of Standard Contractual Clauses.
• CloudPayments (Russia) - payment processing. Licensed by the Central Bank of the Russian Federation.
• Anthropic (USA) - processing of requests to the AI assistant. Only when the User uses the built-in AI chat. Request content is not stored.
• Resend (USA) - delivery of email notifications.
• Sentry (Germany) - error monitoring. Without transfer of personal data.

Data is not transferred to third parties for purposes other than those stated in this Policy without the User's separate consent.

In accordance with Article 18 of No. 152-FZ, the initial collection and processing of the personal data of Russian citizens is carried out on servers located within the Russian Federation, via the Supabase EU service, with data-transfer protection mechanisms applied.

In the event of a conflict between these requirements and those of foreign providers, the Operator undertakes to ensure technical localisation measures for users in the Russian Federation.

The User has the right to:

• Obtain information about the data processed
• Request clarification, blocking, or destruction of the data
• Withdraw consent to processing

Requests are sent to privacy@agineai.com. The response time is up to 30 days. Deletion of data at the User's request leads to the deletion of the account and the inability to continue using the Service.

The Operator applies the following technical and organisational measures:

• Encryption of data in transit using TLS 1.3
• Hashing of passwords using the bcrypt algorithm
• Row-Level Security (RLS) at the database layer
• Regular software updates
• Access to data on a least-privilege basis
• Encrypted backups

The Service uses the following categories of cookies:

• Strictly necessary: authentication, CSRF protection, session management
• Analytics: anonymous usage statistics (optional, with consent)

Consent to the use of cookies is requested on your first visit to the Service. You can manage your preferences through the cookie settings control at the bottom of the site.

The Operator reserves the right to make changes to the Policy. Material changes are published on the main page of the Service at least 14 days before they take effect. The date of the last update is shown at the top of this document.

Personal data processing questions: privacy@agineai.com
General support: support@agineai.com