Personal Data Processing Policy

Effective from 10 May 2026 · Version 1.0

This is an English translation provided for convenience. In the event of any discrepancy, the Russian version published at https://ai2content.ru/policy prevails.

This Policy has been prepared in accordance with Federal Law of the Russian Federation No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by Sole Proprietor Egor Timofeevich Borisenko (the “Operator”).

1. General provisions

1.1. The Operator’s most important objective and condition of its activity is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the rights to privacy and to personal and family secrecy.

1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://ai2content.ru and its subdomains, as well as through the Operator’s other communication channels (email, the Telegram and WhatsApp messengers).

2. Key terms used in this Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

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

2.3. Website means the set of graphic and information materials, computer programs and databases available on the Internet at https://ai2content.ru and its subdomains.

2.4. Personal data information system means the set of personal data contained in databases, together with the information technologies and technical means that ensure their processing.

2.5. Depersonalisation of personal data means actions that make it impossible, without the use of additional information, to determine to which User or other personal data subject the personal data belong.

2.6. Processing of personal data means any action or set of actions performed with or without automation, including the collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer, depersonalisation, blocking, deletion and destruction of personal data.

2.7. Operator means Sole Proprietor Egor Timofeevich Borisenko (Taxpayer Identification Number (INN) 450140217101, Primary State Registration Number of Sole Proprietor (OGRNIP) 326450000015144), who independently organises and carries out the processing of personal data and determines the purposes of processing, the personal data to be processed and the actions performed with them.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the Services.

2.9. User means any visitor to the Website or any representative of a client organisation who contacts the Operator regarding the services of AI2Content (AI2).

2.10. Cookies means a small piece of data sent by a web server and stored on the User’s device, which the web client sends back to the web server when attempting to open a page of the website.

2.11. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or legal entity.

2.12. Destruction of personal data means any actions that irreversibly destroy personal data so that their content cannot be restored.

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 personal data subject;
• if the personal data subject withdraws consent to the processing of personal data, continue processing without consent where there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law.

3.2. The Operator is obliged to:

• provide the personal data subject, at their request, with information concerning the processing of their personal data;
• organise the processing of personal data in accordance with the applicable legislation of the Russian Federation;
• respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the authorised body for the protection of the rights of personal data subjects, at its request, with the necessary information within 10 days;
• publish or otherwise ensure unrestricted access to this Policy;
• take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions;
• stop processing and destroy personal data in the cases provided for by the Personal Data Law;
• perform other obligations provided for by the Personal Data Law.

4. Main rights of personal data subjects

4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws;
• require the Operator to clarify, block or destroy their personal data if the data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
• make prior consent a condition for the processing of personal data for the purpose of promoting goods, works and services;
• withdraw consent to the processing of personal data and demand that processing be stopped;
• appeal against unlawful actions or inaction of the Operator to the authorised body for the protection of the rights of personal data subjects or in court;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Procedure for handling requests from personal data subjects:

• requests and enquiries (on updating, blocking or destroying personal data, withdrawing consent to processing, or providing information about processing) are accepted by the Operator at hello@ai2content.ru;
• the period for considering a request and sending a reply to the personal data subject is 10 (ten) working days from the date the Operator receives the request;
• where it is necessary to confirm the identity of the person making the request, the Operator may request additional information to verify that the request comes from the personal data subject or their legal representative.

5. Principles of personal data processing

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

5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.

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

5.4. Only personal data that meet the purposes of processing are processed.

5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Processing of excessive personal data is not permitted.

5.6. When personal data are processed, their accuracy, sufficiency and, where necessary, relevance to the purposes of processing are ensured.

5.7. Personal data are stored in a form that allows the personal data subject to be identified for no longer than the purposes of processing require, unless a different period is established by federal law or a contract.

6. Purposes of processing, categories of data and legal grounds

6.1. Purposes of processing:

• handling enquiries from Users submitted through the form on the Website, by email and through the Operator’s Telegram and WhatsApp accounts;
• concluding and performing contracts for the provision of content creation services (AI-generated animation, AI characters, renders, merchandise, brand identity and other areas);
• project communication: clarifying the brief and approving interim and final results;
• collecting visit statistics and improving the operation of the Website.

6.2. Personal data processed:

• surname and first name of the client’s representative;
• email address;
• messenger identifier and display name in Telegram or WhatsApp, and the phone number linked to the WhatsApp account (when communicating through these messengers);
• name of the client organisation and position of its representative — when contracts are concluded with legal entities;
• the content of enquiries and of materials provided by the User for the purpose of providing services (briefs, specifications, source materials);
• cookies, IP address, information about the device and browser, and the source of the visit to the Website — for web analytics (only with the User’s consent in the cookie banner, where such a banner is installed).

6.3. Legal grounds for processing:

• performance of a contract to which the personal data subject is a party, or conclusion of a contract at the initiative of the subject (clause 5, part 1, Article 6 of the Personal Data Law) — for providing services and project communication;
• performance of functions, powers and obligations imposed on the Operator by law (clause 2, part 1, Article 6) — for accounting and tax records;
• exercise of the rights and legitimate interests of the Operator, provided that the rights and freedoms of the subject are not violated (clause 7, part 1, Article 6) — for ensuring the security and proper operation of the Website.

7. Cookies and web analytics

7.1. The Website may use cookies and similar technologies to ensure the operation of the website, remember user settings and collect visit statistics.

7.2. The User may disable cookies in their browser settings; in that case some functions of the Website may be unavailable.

8. Conditions of personal data processing

8.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.

8.2. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or a beneficiary, and for the conclusion of a contract at the initiative of the personal data subject.

8.3. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the personal data subject are not violated.

9. Procedure for collection, storage, transfer and other types of processing

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

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

9.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation, or where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil law contract. In particular, the Operator may transfer the minimum necessary personal data to the following organisations:

• Telegram FZ-LLC (Dubai, UAE; policy: telegram.org/privacy) — for the Operator’s communication with Users through the Telegram account @borisenkoegor; data transferred: Telegram ID, username, name, and the text of messages of the User and the Operator;
• WhatsApp LLC (Menlo Park, USA; policy: whatsapp.com/legal/privacy-policy) — for the Operator’s communication with Users through WhatsApp; data transferred: phone number, display name, and the text of messages of the User and the Operator;
• YANDEX LLC (INN 7736207543, OGRN 1027700229193, 16 Lva Tolstogo St., Moscow, 119021, Russia; policy: yandex.ru/legal/confidential) — as the email service for receiving enquiries from Users at hello@ai2content.ru;
• video conferencing and collaboration services (Google Meet, Zoom, Miro, Figma and/or other equivalents chosen by the Operator and the client) — to the extent necessary for meetings and joint work on a project.

9.4. If inaccuracies in personal data are identified, the User may update them by sending a notice to the Operator at hello@ai2content.ru marked “Updating personal data”.

9.5. Periods of personal data processing:

• personal data processed for the performance of a contract (name, contact details, project materials) — for the entire period of the provision of the Services and for 3 (three) years after the Services end (the limitation period under Article 196 of the Civil Code of the Russian Federation);
• accounting and tax data — 5 (five) years in accordance with Article 23 of the Tax Code of the Russian Federation and Article 29 of Federal Law No. 402-FZ of 6 December 2011 “On Accounting”;
• web analytics data (cookies, IP address) — up to 3 years from the date of collection.

9.5.1. When the processing periods expire, personal data are destroyed or depersonalised in accordance with the procedure established by applicable legislation.

9.6. The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator at hello@ai2content.ru marked “Withdrawal of consent to the processing of personal data”. The Operator will reply within 10 (ten) working days from the date the notice is received.

9.7. All information collected by third-party services, including communication services and other service providers, is stored and processed by those parties in accordance with their user agreements and privacy policies. The Operator is not responsible for the actions of third parties.

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

10.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalises, blocks, deletes and destroys personal data.

10.2. The Operator carries out automated processing of personal data, with or without receiving and/or transferring the information obtained via information and telecommunication networks.

11. Cross-border transfer of personal data

11.1. The Operator does not transfer Users’ personal data outside the Russian Federation, except where such transfer is an integral part of the operation of third-party services (for example, messengers and video conferencing services) that the User uses voluntarily.

11.2. Before carrying out its own cross-border transfer of personal data, the Operator must notify the authorised body for the protection of the rights of personal data subjects of its intention to do so, in accordance with the procedure established by the Personal Data Law.

12. Confidentiality of personal data

12.1. The Operator and other persons who have obtained access to personal data must not disclose personal data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.

13. Final provisions

13.1. The User may obtain any clarification on questions concerning the processing of their personal data by contacting the Operator at hello@ai2content.ru.

13.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

13.3. The current version of the Policy is freely available on the Internet at https://ai2content.ru/policy (in Russian) and https://ai2content.ru/policy/en/ (English translation).

14. Operator details