1. General Provisions
1.1. This Privacy Policy (hereinafter — the "Policy") has been developed in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — 152-FZ) and defines the procedure for processing personal data of users (hereinafter — "User") of the Alexmind service (hereinafter — the "Service").
1.2. The personal data operator is II Technologies LLC, which processes personal data in accordance with this Policy.
1.3. This Policy is an integral part of the Service's User Agreement (https://light.alexmind.io/useragreement/) and the Public Offer for paid services of the Alexmind Service (https://light.alexmind.io/public-offer/). By using the Service, the User agrees to the terms of this Policy.
1.4. If the User does not agree with the terms of this Policy, they must immediately cease using the Service.
2. Personal Data Operator
Operator: II Technologies LLC
TIN: 9714008756
KPP: 771401001
OGRN: 1237700281125
Registered address: 125315, Moscow, Leningradsky Ave., 66, office 1H
Bank account: 40702810012010656093
Bank: Sovcombank PJSC
Correspondent account: 30101810445250000360
General Director: Maya Andreyevna Stanislavskaya
Contact email: info@alexmind.io
Service address: https://light.alexmind.io/
II Technologies LLC has notified Roskomnadzor of its personal data processing activities in accordance with Article 22 of 152-FZ.
3. Categories of Personal Data Processed
3.1. Identification data:
— last name, first name, patronymic (if applicable and provided);
— mobile phone number;
— email address.
3.2. Technical data:
— IP address and geolocation (country, region);
— device and browser identifiers (user-agent, device type, operating system);
— cookies and similar identifiers (see Section 8 for details);
— session data, connection time and method.
3.3. Service interaction data:
— message and AI assistant query history;
— uploaded files and content;
— transaction history and payment events (full bank card details are not stored).
3.4. Payment data:
— last 4 digits of bank card and card type (full card details are not stored in Service systems);
— transaction date and amount;
— payment status.
3.5. The Operator does not process special categories of personal data (racial and ethnic origin, political views, religious beliefs, biometric and genetic data, health information), except as expressly required by the legislation of the Russian Federation.
3.6. The Operator does not collect personal data of individuals under the age of 18 without the consent of a legal representative. Upon discovery of processing of a minor's data without proper consent, the Operator takes immediate steps to delete such data.
4. Purposes and Legal Grounds for Processing
4.1. The Operator processes personal data on the following grounds and for the following purposes:
— Registration, authentication, account management — clauses 3.1, 3.2 — Performance of contract (Art. 6, Part 1, Clause 5 of 152-FZ).
— Provision of Service functionality, request processing — clauses 3.1–3.3 — Performance of contract (Art. 6, Part 1, Clause 5 of 152-FZ).
— Payment processing and issuance of fiscal receipts — clauses 3.1, 3.4 — Performance of contract; compliance with legal requirements (54-FZ) (Art. 6, Part 1, Clauses 2 and 5 of 152-FZ).
— Technical support, handling of inquiries — clauses 3.1–3.3 — Performance of contract (Art. 6, Part 1, Clause 5 of 152-FZ).
— Analytics and improvement of Service quality — clauses 3.2, 3.3 — Achievement of legitimate operator purposes (Art. 6, Part 1, Clause 7 of 152-FZ).
— Security, fraud prevention — clauses 3.1–3.3 — Achievement of legitimate operator purposes (Art. 6, Part 1, Clause 7 of 152-FZ).
— Sending service notifications (payments, receipts, terms changes) — clause 3.1 — Performance of contract (Art. 6, Part 1, Clause 5 of 152-FZ).
— Compliance with legal requirements (responses to government authority requests) — clauses 3.1–3.4 — Performance of legal obligation (Art. 6, Part 1, Clause 2 of 152-FZ).
— Sending marketing and promotional messages — clause 3.1 — Subject consent (Art. 6, Part 1, Clause 1 of 152-FZ).
4.2. Processing of personal data for marketing and advertising purposes is carried out only with the User's separate explicit consent and ceases immediately upon its withdrawal.
5. Personal Data Collection Procedure
5.1. The Operator collects personal data in the following ways:
— directly from the User — during registration, login, completion of forms in the Service, or submission of support requests;
— automatically — during use of the Service (technical data, cookies, request logs);
— from payment services — transaction status data required to activate and confirm the Subscription.
5.2. Provision of the data specified in clause 3.1 (identification data) is a necessary condition for registration and access to paid Services. Refusal to provide such data makes it impossible to render the Services.
5.3. The User is responsible for the accuracy of the data provided. If inaccurate data is provided, the Operator bears no responsibility for the inability to render the Services.
6. Transfer of Personal Data to Third Parties
6.1. The Operator transfers the User's personal data to third parties exclusively in the following cases:
a) CloudKassir online cash register service
Purpose: generation and delivery of fiscal receipts in accordance with Federal Law No. 54-FZ of 22.05.2003 "On the Use of Cash Register Equipment".
Data transferred: User's phone number and/or email address, amount and composition of paid Services.
b) Analytics and technical services
Purpose: ensuring the operation and security of the Service, collection of anonymized analytics.
Data is transferred in anonymized or pseudonymized form.
c) Government authorities
Purpose: compliance with mandatory requirements of the legislation of the Russian Federation.
Transfer is carried out exclusively in cases and in the manner prescribed by applicable law.
6.2. All third parties processing data on behalf of the Operator are obligated to maintain confidentiality and ensure protection of personal data at a level no lower than that established by this Policy.
6.3. The Operator does not sell or disclose Users' personal data to third parties for commercial purposes, except as expressly stated in this section.
7. Storage and Protection of Personal Data
7.1. When collecting personal data of citizens of the Russian Federation, the Operator ensures its recording, systematization, accumulation, storage, clarification, and retrieval using databases located on the territory of the Russian Federation, in accordance with Part 5 of Article 18 of 152-FZ.
7.2. Personal data retention periods:
— Account data — Duration of account + 3 years after deletion
— Transaction history and fiscal receipts — 5 years (tax legislation requirements)
— Technical logs — 1 year
— Support correspondence — 3 years
— Data processed on the basis of consent (marketing) — Until consent is withdrawn
7.3. Upon expiration of retention periods, personal data is destroyed or anonymized, unless otherwise required by the legislation of the Russian Federation.
7.4. The Operator applies the following personal data protection measures:
— data encryption in transit (TLS/HTTPS);
— access control to personal data (access restricted to authorized personnel only);
— regular data backups;
— organizational measures: staff training, information security policies;
— technical measures: firewalls, intrusion detection systems, incident monitoring.
8. Cookies and Analytics
8.1. The Service uses cookies — small text files stored on the User's device when visiting the Service. Cookies are necessary for the proper operation of the Service, saving user preferences, and collecting analytics.
8.2. Types of cookies used:
— Essential — Authentication, basic Service operation — Session / up to 1 year
— Functional — Saving user settings and preferences — Up to 1 year
— Analytical — Collection of anonymized visit and behavior statistics — Up to 2 years
8.3. The User may manage cookie settings through browser settings or through the consent management interface in the Service (where available). Disabling essential cookies may result in the inability to use certain Service features.
8.4. The Operator may use tracking pixels, web beacons, and similar technologies to collect anonymized statistics. Data collected through analytical tools does not allow identification of a specific User.
9. Rights of Personal Data Subjects
9.1. In accordance with 152-FZ, the User has the right to:
— access — obtain information about what personal data is being processed, for what purposes, and to whom it is transferred (Art. 14 of 152-FZ);
— rectification — request clarification of inaccurate, incomplete, or outdated data (Art. 21 of 152-FZ);
— erasure — request deletion of data if the grounds for processing have ceased or the data is being processed unlawfully (Art. 21 of 152-FZ);
— restriction of processing — in cases provided for by 152-FZ;
— withdrawal of consent — withdraw consent to personal data processing at any time. Withdrawal does not affect the lawfulness of processing carried out prior to receipt of the withdrawal (Art. 9 of 152-FZ);
— complaint — file a complaint with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor, https://rkn.gov.ru/) in the event of a violation of their rights by the Operator.
9.2. To exercise the rights specified in clause 9.1, the User submits a request to info@alexmind.io stating:
— full name or account identifier;
— contact details (phone number, email);
— description of the request and its legal basis.
9.3. The Operator reviews the request and provides the requested information within 10 (ten) business days of receipt (Art. 14 of 152-FZ). Requests for clarification, blocking, or destruction of personal data are fulfilled within 7 (seven) business days for clarification and blocking, and 30 (thirty) business days for destruction from the date of receipt (Art. 21 of 152-FZ).
9.4. The Operator may refuse to delete data if its processing is required for the performance of a contract, fulfillment of a legal obligation, or in other cases provided for by 152-FZ. In case of refusal, the Operator is obligated to provide a reasoned explanation.
10. Cross-Border Transfer of Personal Data
10.1. Primary personal data processing is carried out on servers located on the territory of the Russian Federation.
10.2. In the event that foreign technical services are engaged (analytics, CDN, cloud infrastructure services), the Operator ensures compliance with the requirements of Article 12 of 152-FZ (as amended by Federal Law No. 266-FZ of 14.07.2022) prior to initiating such transfer: data is transferred only to countries included in the Roskomnadzor list as providing adequate protection, or under an agreement with the recipient that provides for protection measures equivalent to the requirements of 152-FZ.
10.3. Prior to initiating cross-border transfer of personal data, the Operator notifies Roskomnadzor in the manner and form established by the Roskomnadzor order and receives confirmation of receipt of the notification. Data transfer does not commence until this requirement has been fulfilled.
11. Amendments to this Policy
11.1. The Operator reserves the right to make unilateral amendments to this Policy. The new version takes effect upon its publication at https://light.alexmind.io/privacy-policy/, unless a different effective date is specified by the Operator.
11.2. Continued use of the Service after the new version of the Policy takes effect constitutes the User's acceptance of the changes.
11.3. In the event of material changes (changes to processing purposes, engagement of new categories of third parties, changes to retention periods), the Operator will notify Users through the Service interface and/or by email no later than 10 (ten) days before the changes take effect.
12. Operator Contact Information and Details
LIMITED LIABILITY COMPANY
"II TECHNOLOGIES"
TIN: 9714008756
KPP: 771401001
OGRN: 1237700281125
Registered address: 125315, Moscow, Leningradsky Ave., 66, office 1H
Bank account: 40702810012010656093
Bank: Sovcombank PJSC
Correspondent account: 30101810445250000360
General Director: Maya Andreyevna Stanislavskaya
Contact email: info@alexmind.io
Service address: https://light.alexmind.io/
For all matters related to personal data processing, contact: info@alexmind.io
Date of publication of this version of the Policy: March 11, 2026