Privacy Policy

Last updated: May 19, 2026

This is an English translation of the Russian Privacy Policy. In case of discrepancy, the Russian-language version available at https://neuromia.ru/privacy shall prevail.

Personal Data Processing Policy

1. General provisions

1.1 This personal data processing policy is drawn up in accordance with the requirements of Russian Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the security measures undertaken by sole proprietor Kiselev Sergey Vitalyevich (hereinafter — the Operator).

1.2 Respect for human and civil rights and freedoms when processing personal data — including the right to privacy, personal and family secrecy — is the Operator's most important goal and a condition of its activities.

1.3 This policy on personal data processing (hereinafter — the Policy) applies to all information that the Operator may receive about visitors of the website https://neuromia.ru

2. Key terms used in the Policy

2.1 Automated processing of personal data — processing of personal data using computer equipment.

2.2 Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).

2.3 Website — a collection of graphic and informational materials, as well as software and databases, accessible on the internet at https://neuromia.ru

2.4 Personal data information system — a collection of personal data contained in databases together with information technologies and technical means used for processing them.

2.5 Anonymisation of personal data — actions that make it impossible to determine, without additional information, that personal data belong to a specific User or other personal data subject.

2.6 Processing of personal data — any action (operation) or set of actions (operations) performed with or without automated means involving personal data, including collection, recording, organisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.

2.7 Operator — a state body, municipal body, legal entity or individual that, alone or together with others, organises and/or carries out the processing of personal data and determines the purposes of processing, the composition of the personal data to be processed and the actions (operations) performed with the personal data.

2.8 Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://neuromia.ru

2.9 Personal data permitted by the data subject for distribution — personal data to which access is granted to an unlimited number of persons by the data subject's consent to processing personal data permitted for distribution, in accordance with the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10 User — any visitor of the website https://neuromia.ru

2.11 Provision of personal data — actions aimed at disclosing personal data to a specific person or a defined group of persons.

2.12 Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in the mass media, posting in information and telecommunications networks or providing access to personal data in any other way.

2.13 Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual or foreign legal entity.

2.14 Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to recover them from the information system, and/or in the destruction of the physical media containing personal data.

3. Main rights and obligations of the Operator

3.1 The Operator has the right to:

  • receive accurate information and/or documents containing personal data from the data subject;
  • continue processing personal data without the consent of the data subject if such consent has been withdrawn, on the grounds provided by the Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to comply with the obligations provided by the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.

3.2 The Operator is obligated to:

  • provide the data subject, at their request, with information regarding the processing of their personal data;
  • organise the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • respond to enquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law;
  • provide the authorised body for the protection of the rights of data subjects, upon request, with the necessary information within 30 days of receipt of such request;
  • publish or otherwise ensure unrestricted access to this personal data processing Policy;
  • take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, modification, blocking, copying, provision, distribution and other unlawful actions;
  • cease transfer (distribution, provision, access), cease processing and destroy personal data in the manner and cases provided by the Personal Data Law;
  • perform other obligations provided by the Personal Data Law.

4. Main rights and obligations of data subjects

4.1 Data subjects have the right to:

  • receive information about the processing of their personal data, except where federal laws provide otherwise. Information is provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there is a lawful basis for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • require the Operator to clarify, block or destroy their personal data if they are incomplete, outdated, inaccurate, obtained unlawfully or no longer necessary for the stated purpose, and to take measures provided by law to protect their rights;
  • impose a requirement of prior consent when their personal data are processed for the purpose of marketing of goods, works and services;
  • withdraw consent to the processing of personal data;
  • appeal to the authorised body for the protection of the rights of data subjects or to a court against the Operator's unlawful actions or omissions in processing their personal data;
  • exercise other rights provided by the legislation of the Russian Federation.

4.2 Data subjects are obligated to:

  • provide the Operator with accurate information about themselves;
  • inform the Operator about clarifications (updates, modifications) of their personal data.

4.3 Persons who provide the Operator with inaccurate information about themselves, or information about another data subject without the latter's consent, bear liability under Russian Federation legislation.

5. Personal data the Operator may process about the User

5.1 First name, last name.

5.2 Email address.

5.3 Content of prompts, uploaded files and generation results — processed for the purpose of executing generations through AI providers (OpenAI, Anthropic, Google, ByteDance, Kie.ai and others) and stored in the User's personal cabinet.

5.4 The website also collects and processes anonymous data about visitors (including cookies) via internet analytics services (Yandex Metrica, Google Analytics and others).

5.5 The data listed above are collectively referred to as Personal Data throughout this Policy.

5.6 The Operator does not process special categories of personal data relating to racial or ethnic origin, political views, religious or philosophical beliefs or intimate life.

5.7 Processing of personal data permitted for distribution from among the special categories specified in part 1 of article 10 of the Personal Data Law is permitted subject to the prohibitions and conditions provided by article 10.1 of the Personal Data Law.

6. Personal data processing principles

6.1 Personal data are processed on a lawful and fair basis.

6.2 Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Processing incompatible with the purposes of collection is not permitted.

6.3 Combining databases containing personal data processed for mutually incompatible purposes is not permitted.

6.4 Only personal data corresponding to the purposes of processing are processed.

6.5 The content and scope of processed personal data correspond to the stated purposes. Excessiveness of processed personal data in relation to the stated purposes is not permitted.

6.6 During processing, accuracy, sufficiency and, where necessary, relevance of personal data to the purposes are ensured. The Operator takes the necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.

6.7 Personal data are stored in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law, a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or anonymised once the purposes are achieved or in the event that the need to achieve them is lost, unless federal law provides otherwise.

7. Purposes of personal data processing

7.1 The purposes of processing the User's personal data:

  • registration and authorisation of the User in the personal cabinet;
  • providing access to the AI-aggregator platform and related services;
  • executing generations via third-party AI providers (prompts and results are transferred to the provider for request processing);
  • informing the User by sending emails (password reset, payment notifications, technical messages);
  • ensuring payment operations (top-up of the credit balance).

7.2 The Operator also has the right to send the User notifications of new models, special offers and various events. The User may at any time opt out of informational messages by sending the Operator an email to support@neuromia.ru marked "Notification opt-out".

7.3 Anonymous User data collected via internet analytics services are used to gather information about User actions on the website and to improve the quality of the website and its content.

8. Legal grounds for personal data processing

8.1 The legal grounds for processing personal data by the Operator are:

  • Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies and Information Protection";
  • federal laws and other regulations in the area of personal data protection;
  • the consent of Users to the processing of their personal data and to the processing of personal data permitted for distribution.

8.2 The Operator processes the User's personal data only when the User fills out and/or submits them via special forms on https://neuromia.ru or sends them to the Operator by email. By filling out the relevant forms and/or submitting their personal data to the Operator, the User expresses agreement with this Policy.

8.3 The Operator processes anonymous data about the User if this is permitted in the User's browser settings (cookies enabled and JavaScript allowed).

8.4 The data subject independently decides whether to provide their personal data and gives consent freely, by their own will and in their own interest.

9. Conditions of personal data processing

9.1 Personal data are processed with the data subject's consent.

9.2 Processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or by law, or for the performance of functions, powers and duties imposed on the Operator by Russian Federation legislation.

9.3 Processing is necessary for the administration of justice, the execution of a court order or an act of another body or official subject to execution under Russian Federation legislation on enforcement proceedings.

9.4 Processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, or for entering into a contract at the data subject's initiative, or a contract under which the data subject will be a beneficiary or guarantor.

9.5 Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not infringed.

9.6 Processing of personal data to which access has been granted by the data subject to an unlimited number of persons or at their request (hereinafter — publicly available personal data) is carried out.

9.7 Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for collection, storage, transfer and other processing of personal data

The security of personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to fully comply with the requirements of the current personal data protection legislation.

10.1 The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.

10.2 The User's personal data will under no circumstances be transferred to third parties, except in connection with the enforcement of the current legislation, transfer to AI providers (OpenAI, Anthropic, Google, ByteDance, Kie.ai and others) for the execution of generations at the User's request, or where the data subject has given consent to the Operator to transfer the data to a third party for the performance of a civil-law contract.

10.3 If inaccuracies are found in personal data, the User may update them independently through the personal cabinet or by sending the Operator an email to support@neuromia.ru marked "Personal data update".

10.4 The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by a contract or current legislation. The User may at any time withdraw consent to processing by sending the Operator an email to support@neuromia.ru marked "Withdrawal of consent to processing".

10.5 All information collected by third-party services, including payment systems, communication services, AI providers (OpenAI, Anthropic, Google, ByteDance, Kie.ai and others) and other service providers, is stored and processed by those parties (Operators) in accordance with their Terms of Use and Privacy Policies. The data subject and/or User is responsible for familiarising themselves with these documents in a timely manner. The Operator is not liable for the actions of third parties, including the service providers listed in this clause.

10.6 Prohibitions on transfer (except for providing access) and on processing or conditions of processing (except for granting access) of personal data permitted for distribution, established by the data subject, do not apply in cases of processing personal data in state, public and other public interests as defined by Russian Federation legislation.

10.7 The Operator ensures the confidentiality of personal data when processing them.

10.8 The Operator stores personal data in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law, a contract to which the data subject is a party, beneficiary or guarantor.

10.9 Termination of personal data processing may be triggered by achievement of the processing purposes, expiry of the data subject's consent, withdrawal of consent or detection of unlawful processing.

11. Actions performed by the Operator with the personal data received

11.1 The Operator performs collection, recording, organisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.

11.2 The Operator carries out automated processing of personal data with or without receipt and/or transfer of the resulting information through information and telecommunications networks.

12. Cross-border transfer of personal data

12.1 Before commencing cross-border transfer of personal data, the Operator is obliged to verify that the foreign state to whose territory the transfer is to be made ensures reliable protection of the rights of data subjects.

12.2 Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only with the data subject's written consent to such transfer and/or for the performance of a contract to which the data subject is a party. When using AI providers (OpenAI, Anthropic, Google and others) whose servers are located outside the Russian Federation, the User, by sending a request to the model, consents to the cross-border transfer of the request content to that provider.

13. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose them to third parties and not to distribute them without the data subject's consent, unless federal law provides otherwise.

14. Final provisions

14.1 The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator at support@neuromia.ru

14.2 This document will reflect any changes in the Operator's personal data processing policy. The Policy remains in force indefinitely until replaced by a new version.

14.3 The current version of the Policy is freely available at https://neuromia.ru/privacy

Details

Sole proprietor Kiselev Sergey Vitalyevich
INN: 930500610657
OGRN: 324930100018638
Email: support@neuromia.ru