Personal Data Processing Policy

Version of 7 November 2026. Effective 7 November 2026.

1. Operator and scope

The Operator is Pavel Igorevich Shepshelevich, a professional income tax payer, Russian INN 772990579929. Contact: support@open-learn.ai.

This Policy covers visitors, users of the website, chat, studios, mini apps and Telegram bot, gallery authors, mailing recipients and people contacting support. Service and payment terms are in the offer and terms.

2. Data

• Account: email, name and avatar if provided, language and settings; passwords are stored as hashes. Yandex supplies identifiers and available profile fields for sign-in; Telegram supplies information needed for linking after sign-in, bot use and notifications. Third-party passwords are not supplied to OpenLearn.
• Sign-in protection: TOTP secret and backup codes if enabled, public passkey keys and security events. Private passkey keys stay on the device.
• Requests and results: messages, prompts, files, images, video and audio, history, extracted text, memory and personal instructions.
• Usage and payments: model, processing volume, technical operation identifiers, cost, balances, payment amount, currency and status. Payment details are entered with the payment provider; the Service does not store full card numbers.
• Technical information: IP address, browser and device, cookies, error and security logs. Signup attribution may include campaign tags, referral code, referring domain and landing page.
• Support and choices: correspondence and records of consent, publications and their cancellation to the extent described below.

Do not upload special-category data, health information, biometric identification data, protected secrets or other people's personal data without a lawful basis. Requests are processed to perform the selected function; automated processing does not make them anonymous.

Derived data including extracted text, search representations and vectors, temporary files and technical caches may be used for the relevant functions. Service AI stages such as titles, memory and search refinement may also receive necessary context.

3. Purposes and bases

Consent does not replace a contractual basis or the Operator's legal duties. The current email signup form separately requires processing consent; the advertising option is independent and off by default. Signup attribution is described in section 10 and is separate from permission for Metrica.

4. Processing operations

Collection, recording, organization, accumulation, storage, correction, retrieval, use, access, transfer, restriction, deletion and destruction are performed for the relevant purpose. Processing is mainly automated; the Operator handles support. Publication disseminates selected information to an unlimited audience.

5. Transfer and safeguards

Account safeguards include sessions, password hashing and available sign-in protection. The public website uses HTTPS. Access to private files is checked; some files are delivered using temporary signed links. Avatars and explicitly published materials are available through their public routes. Do not share signed links with others.

These measures are not a promise of absolute security, certification or compliance with every foreign legal regime. See security.

6. Storage

The Service's primary deployment is intended to be in Russia: the database and server application in Moscow, object storage in St Petersburg through Timeweb Cloud. This does not mean that every processing stage occurs only in Russia: external APIs and technical intermediaries participate in the transfers below. Database backups are encrypted before external copying. Different copies have different retention rules (section 11).

7. Recipient categories

• Timeweb Cloud: application, database, file and backup hosting.
• OpenRouter and providers of selected models: AI requests across modalities, including speech transcription and synthesis. Depending on the function, context history, content and file links, memory, instructions and technical user/request identifiers are transmitted. A model name does not always identify the ultimate processor: routing among providers is possible.
• Technical network intermediaries: external API traffic and Telegram interactions. Their involvement does not imply that content is inaccessible at every stage.
• Resend: service and, with separate consent, advertising email; address, required template information and delivery records.
• Platega: ruble payments, including amount, currency, status and technical payment identifiers.
• Yandex and Telegram: Yandex for sign-in; Telegram for linking after sign-in, bot use and notifications. These services have their own rules; deleting OpenLearn does not automatically delete their copies.
• SearXNG and connected search engines, or OpenRouter's search partner: search queries that may include message fragments.
• Websites whose pages the Service reads: the URL including parameters, server IP and technical request headers. Page text may be sent to the model. Reference tools including Wikipedia and open-meteo.com receive necessary query data, such as a city name.
• Yandex Metrica: visit statistics after permission (section 10).
• Visitors to shared links and the gallery: material you explicitly made public. Copies held by visitors and search engines can remain outside the Service's control.

Disclosure to competent authorities may occur where required by law. Recipients receive information for their function; avoid unnecessary personal information in requests and file names.

8. International transfers

Model processing, email, third-party interactions, search and transit through foreign infrastructure may transfer information outside Russia. Geography depends on the function, ultimate provider and its contractors; not every route is limited to one country.

A contractual basis does not replace Article 12 of Russian Law 152-FZ: recipient information, required notifications, restrictions and prohibitions must be addressed separately. This Policy and a user's action do not themselves establish that the Operator has fulfilled those duties. Do not send information that must not leave your jurisdiction if foreign processing is unacceptable.

9. Model training

OpenLearn does not train its own models on user conversations. Data is sent to external AI services to perform requests. Recipients' use, technical retention and training depend on the terms and settings of each route. A universal prohibition on training or zero retention is not guaranteed across every model, modality and fallback. Do not submit information that requires an unverified guarantee of this kind.

10. Cookies and statistics

Cookies and localStorage support sessions, sign-in protection, language, theme, preferences and the analytics choice. External sign-in state is time limited.

Yandex Metrica loads only after “Accept” when the counter is enabled in this website build. “Necessary only” or closing the banner does not permit Metrica. It may use _ym_* cookies, a browser identifier and information about pages, device and key actions. This is not a promise of anonymity. Session replay and click maps are disabled. Chat content and files are not sent as Service events. The Service does not send hits or goals in the admin panel or Telegram Mini App.

Use “Cookie settings” in the footer to change the choice. On refusal, Metrica cookies and storage managed by the Service are cleared and an active page reloads. Previously transmitted information is not automatically recalled. Choice, time and banner version are stored in the browser, not in a server consent archive. See Yandex's policy.

Signup attribution is separate: campaign tags, referral code, referring domain and landing page may be remembered on first visit for up to 30 days and sent to a new account after sign-in. Refusing Metrica does not itself disable this mechanism. Optional analytics and referral reward accounting are not the same purpose.

11. Retention and deletion

Publications, shared links and individual data can be managed in the interface. Ending account access does not immediately unpublish every material: the Operator accounts for publications when manually handling the deletion request. Automatic removal of third-party copies is not guaranteed. On a processing termination request the Operator determines the applicable bases and deadlines, stops processing and arranges destruction under the law. A contract or mandatory rule may require some records to be retained. See help.

An account deletion request immediately ends access and all sessions and stops new AI requests and advertising sends. The Operator manually reviews the request and grounds for retaining specific records within 3 working days. Primary account data, including history, memory, files and related derived data, is deleted no later than 30 calendar days after receiving the request, except records retained on an independent lawful basis. Shorter mandatory deadlines take priority. The Operator informs the user of completion and any retained records, their grounds and retention periods. Backup handling is considered separately; the primary-data deadline is not a promise to destroy every backup within the same period.

The Operator receives a request notification at support@open-learn.ai containing only the account ID, request date and a link to the administrative account page. User conversations and files are not included in that notification.

12. Rights and enquiries

You may request information, access, correction, restriction or destruction where legally applicable, withdraw consent and contact a competent authority or court. Settings provide an export; its contents are not all technical records and files held by the Service.

Write to support@open-learn.ai. Proportionate account ownership verification may be necessary. Responses and fulfilment follow applicable legal deadlines. Foreign-law rights and applicability require separate assessment; unconditional GDPR/CCPA compliance is not claimed.

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