# Consent to Personal Data Processing

Version of 12 October 2026

This consent is given under Article 9 of Russian Federal Law No. 152-FZ "On Personal Data" separately from the other documents of the Service. It is given by ticking the box "I give my consent to the processing of personal data" when creating an account. The box is unticked by default; without consent an account is not created, because the purposes listed below cannot be achieved without processing the data.

I, an individual creating an account in the OpenLearn AI service and identified by the email address or the Google, Yandex ID or Telegram account identifier provided at signup (the "Data Subject"), freely, of my own will and in my own interest give my consent to

**the Operator** — Pavel Igorevich Shepshelevich, a self-employed individual (payer of professional income tax in Russia), INN 772990579929, contact [support@open-learn.ai](mailto:support@open-learn.ai), website https://open-learn.ai (the "Operator"),

to process my personal data on the terms below.

## 1. Purposes

1. Creating and maintaining my account, authentication and sign-in protection.
2. Processing my requests by AI models and returning the results; storing my chat history, files, memory notes and personal instructions in the account.
3. Usage accounting, balance, debits and receipts.
4. Service messages about the account (email verification, password reset, account notices).
5. Security of the Service: logging, rate limiting, detecting and stopping abuse.
6. Recording the signup source to evaluate acquisition channels.
7. Handling my support requests.

Consent to the newsletter and consent to showing my name in the gallery are not covered by this document and are given separately: [newsletter consent](/consent-marketing), [gallery publication terms](/consent-gallery).

## 2. Personal data covered

- email address; password as an irreversible hash; name and avatar (if provided); interface language;
- account identifier and profile fields received from Google, Yandex ID or Telegram when signing in with them;
- TOTP secret, recovery codes and passkey public keys (if enabled);
- request content: chat messages, prompts, uploaded files and images, generation results, memory notes, personal instructions;
- usage data: chosen model, volume processed, cost and debits, timestamps;
- identifier, amount, currency and status of payment operations (without card or bank details);
- IP address, browser and device information, approximate region, session cookies;
- signup source: UTM tags, referral code, referring site domain, landing page;
- date, time, text version, IP address and user agent at the moment this consent is given.

## 3. Actions

Collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), anonymisation, blocking, deletion, destruction — by automated means and, for support correspondence, also manually.

## 4. Processors and recipients

I consent to the processing being entrusted to, and my data being provided to, the parties listed in section 7 of the [Personal Data Processing Policy](/privacy), to the extent needed for their function:

- **JSC "TimeWeb"** (Timeweb Cloud, Russia) — hosting of the database and files;
- **Resend** (USA) — email delivery;
- **the Operator's gateway in the Netherlands** — technical egress point for requests to model providers;
- **OpenRouter** (USA) and the providers of the models I choose (USA, EU, China and other countries); **OpenAI** (USA) — speech recognition and synthesis;
- **Platega** (Russia) — payment acceptance;
- **Telegram**, **Google LLC**, **Yandex LLC** — when signing in with the respective service.

## 5. Cross-border transfer

I acknowledge and agree that when my requests are processed their content is sent to model providers located in the USA, the EU, China and other countries, some of which are not included in the list of states providing adequate protection of data subjects' rights, that it passes through the Operator's gateway in the Netherlands, and that emails are sent via Resend (USA). Transfers are described in sections 7–8 of the [Personal Data Processing Policy](/privacy). Data necessary to perform the agreement is processed under Article 6(1)(5) of Law No. 152-FZ; cross-border transfers are governed by Article 12. This consent does not replace the Operator's duties to notify Roskomnadzor and comply with transfer conditions, prohibitions and restrictions. I understand that I may choose not to send data that must not leave my jurisdiction.

## 6. Term and withdrawal

This consent is valid from the moment it is given until the account is deleted or the consent is withdrawn. It may be withdrawn at any time by writing to [support@open-learn.ai](mailto:support@open-learn.ai) from the address linked to the account, or by deleting the account in Settings. After withdrawal the Operator stops processing and destroys the data within 30 days, except data that must be kept by law (payment records — for the periods set by tax law; the record of giving and withdrawing consent — 3 years).

## 7. Other

I confirm that I have read the [Personal Data Processing Policy](/privacy), including my rights (section 12) and the database location (Moscow, Russian Federation). The Operator records the fact of consent with the date, time, version of this text, IP address and device information.