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)
• AI assistant conversations: messages you exchange with the built-in assistant inside lessons

Bank card data is never passed to the Operator and is not stored by it. It is handled by a licensed payment provider in line with industry payment security standards.

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).

To run the Service, the Operator engages contractors that process data on its behalf and only to the extent their task requires:

• hosting the Service and storing account data;
• payment processing and subscription handling;
• delivery of service emails;
• operation of the built-in AI assistant;
• technical diagnostics and anonymised usage analytics.

Data processing agreements are in place with these contractors. Data is not transferred to third parties for purposes other than those stated in this Policy without the User's separate consent.

Some contractors are located outside the Russian Federation, in countries that provide adequate protection of the rights of personal data subjects. The transfer is carried out with the User's consent, given upon registration in the Service.

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 technical and organisational measures appropriate to the nature of the data processed:

• encryption of data in transit;
• passwords stored only as irreversible hashes;
• access control at the database layer;
• staff access on a least-privilege basis;
• regular updates of the software in use;
• backups of the data.

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