Privacy and Personal Data Processing Policy
Version of July 27, 2026
This Policy sets out how personal data is processed and protected when you use the Answerolog service — a chat bot in the Telegram and MAX messengers and the website answerolog.com.
Questions about personal data processing: starostin.media@gmail.com, Telegram @starosting.
1. The Operator
Individual Entrepreneur Artem Valerievich Starostin (the “Operator”):
- INN (taxpayer number) 191002217434
- OGRNIP (state registration number) 321190000011867
- Address: apt. 39, 43 Pionerskaya St., Ust-Abakan urban settlement, Republic of Khakassia, Russia, 655102
1.1. This Policy applies to all personal data processed by the Operator, both by automated means and without them.
1.2. This Policy is available at https://answerolog.com/en/privacy.html.
1.3. Personal data is processed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006 On Personal Data, and other regulations of the Russian Federation.
2. The Operator has two different roles — this matters
The Service works with reviews that guests wrote about a venue. That is why the Operator has two different roles, and the rules for each of them differ.
Role 1 — Operator. With respect to the data of the person who connected and paid for the Service (the “Subscriber”), Individual Entrepreneur A. V. Starostin is the operator: he determines the purposes and scope of processing himself. This is described in sections 3–8 of this Policy.
Role 2 — Processor. With respect to the data of the authors of reviews about the venue, Individual Entrepreneur A. V. Starostin is a party that processes data on the instructions of the Subscriber. In this case the operator is the Subscriber itself — it decided to connect its venue to the Service and it determined the purpose of processing. This is described in section 9 and in section 12 of the Offer Agreement.
3. Processing principles
3.1. The Operator follows these principles: processing is lawful and fair; processing is limited to purposes that are lawful and defined in advance; the composition and volume of data match the stated purposes; data is not excessive; data is kept accurate; data is stored in a form that allows the data subject to be identified no longer than the purposes of processing require; processing is transparent.
3.2. The Operator does not make decisions that produce legal consequences for a data subject solely on the basis of automated processing.
4. Subscriber data processed by the Operator
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| Giving access to the Service, identifying the Subscriber | messenger ID, first and last name from the profile, username, date of connection | performance of the contract (Article 6(1)(5) of Law No. 152-FZ) | the subscription term and 3 years after it ends |
| Running the Service for the Subscriber’s venue | name and address of the venue, links to its listings on the platforms, notification settings | performance of the contract | the subscription term and 30 calendar days after it ends |
| Processing payments, keeping financial records | full name, email, payment records, bank details for refunds; for legal entities and individual entrepreneurs — company details | performance of the contract; tax law requirements | 5 years (accounting law requirements) |
| Technical support | contact details, content of requests, message history | performance of the contract; the Operator’s legitimate interests | 3 years from the date of the request |
| Website analytics | IP address, cookie data, browser and device information, visit statistics | consent given by continuing to use the website | up to 26 months |
| Informational and marketing messages | messenger ID, email | the Subscriber’s separate consent | until consent is withdrawn |
4.1. The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious beliefs, health, sex life, criminal record) or biometric personal data.
4.2. The Operator does not process data of minors. The Service is intended for persons aged 18 and over.
4.3. The Operator does not request access to the Subscriber’s account on the platforms and does not store its logins or passwords: the Service does not need them.
5. Processors and recipients of data
5.1. To run the Service, the Operator engages the following processors:
| Who | What for | Where the servers are |
|---|---|---|
| Yandex.Cloud LLC (Yandex Cloud) | hosting the Service website and database | Russian Federation |
| Payment service provider (YooKassa) | accepting payments and issuing refunds | Russian Federation |
| Railway Corporation | hosting the chat bot and the modules that collect reviews from the platforms | outside the Russian Federation |
| AI services engaged through OpenRouter, Inc. | preparing draft replies to reviews and the analysis of recurring complaints | outside the Russian Federation |
5.2. The Operator discloses personal data to state authorities at their request, within the limits of their competence and in accordance with the laws of the Russian Federation.
5.3. The Operator does not sell personal data and does not share it with third parties for marketing purposes.
Platforms and messengers
5.4. The Service obtains reviews that are publicly available on the 2GIS, Flamp and Yandex Maps platforms. The Operator does not control the platforms and is not responsible for their rules and policies. The relationship between review authors and the platforms is governed by the documents of the relevant platform.
5.5. The Service runs in the Telegram and MAX messengers. The Subscriber’s interaction with a messenger is governed by the terms and policies of the respective messenger operator, to which the Operator is not a party. The Operator receives from the messenger the information required to run the Service, to the extent the messenger’s technical interface provides it.
6. Place of processing and cross-border transfer
6.1. Initial recording, systematization, accumulation and storage of personal data take place on a server located in the territory of the Russian Federation, in accordance with Article 18(5) of Federal Law No. 152-FZ.
6.2. Some technical operations are performed on servers located outside the Russian Federation: retrieving reviews from the platforms, delivering messages to the messengers, and preparing draft replies with AI services.
6.3. What is sent to the AI services is the text of the review, the rating and the publication date. The name of the review author is replaced with a placeholder, and authors’ photographs are not transferred.
6.4. The following is not transferred outside the Russian Federation: payment data and payment records, bank details for refunds, documents provided by the Subscriber, and the content of its support requests.
6.5. Cross-border transfer is carried out in compliance with Article 12 of Federal Law No. 152-FZ: Subscriber data — on the basis of the Subscriber’s consent; data of review authors — on the basis of the Subscriber’s instructions (section 9).
7. Retention periods and destruction
7.1. Reviews, the draft replies prepared for them and the venue settings are stored for the term of the subscription.
7.2. Once the subscription ends, the data of the relevant venue is deleted within 30 calendar days.
7.3. Subscriber data is stored for the periods set out in section 4.
7.4. Processing stops and data is destroyed if: the purposes of processing have been achieved; consent is withdrawn and there is no other legal basis; the periods set out in section 4 have expired; the Operator ceases its activity.
8. Rights of the data subject
8.1. A data subject has the right to:
- receive information about the processing of their personal data;
- get access to their personal data;
- require that data be updated, blocked or destroyed if it is incomplete, out of date, inaccurate, obtained unlawfully or not necessary for the stated purpose;
- withdraw consent to the processing of personal data;
- object to the processing;
- challenge the Operator’s acts or omissions before the authority responsible for protecting the rights of personal data subjects or in court.
8.2. To exercise these rights, send a request:
- email: starostin.media@gmail.com
- Telegram: @starosting
- postal address: apt. 39, 43 Pionerskaya St., Ust-Abakan urban settlement, Republic of Khakassia, Russia, 655102
8.3. A request is reviewed within 10 calendar days. The Operator may ask for information confirming the identity of the person making the request and their connection to the data being processed.
9. Processing of review authors’ data on instructions
9.1. Personal data of review authors is processed by the Operator on the instructions of the Subscriber under Article 6(3) of Federal Law No. 152-FZ. The operator of this data is the Subscriber that connected its venue to the Service.
9.2. Only information that review authors published themselves and to which the platforms give access to an unlimited number of people is processed (Article 6(1)(10) of Federal Law No. 152-FZ): the author’s name or nickname, the text of the review, the rating, the publication date, the review’s identifier on the platform and any reply published to it earlier.
9.3. The data, the list of actions, the purposes and the periods are set out in section 12 of the Offer Agreement.
9.4. When processing data on instructions, Individual Entrepreneur A. V. Starostin undertakes to: process the data only for the purposes set out in the instructions; not disclose it to third parties other than the processors listed in section 5; apply the protection measures required by Article 19 of Federal Law No. 152-FZ; replace the name of the review author with a placeholder before the text is sent to the AI services; destroy the data at the Subscriber’s request or once the subscription ends.
9.5. A review author has the right, using the contacts given in clause 8.2, to approach Individual Entrepreneur A. V. Starostin directly and require information about the processing of their data or its deletion. Such a request is fulfilled within 10 calendar days, and the Subscriber acting as the operator is notified. Deleting data from the Service does not delete the review itself from the platform: it was published by its author and is controlled by the platform.
9.6. Requests from review authors that concern the lawfulness of the processing itself are handled by the Subscriber as the operator. Individual Entrepreneur A. V. Starostin forwards such requests to the Subscriber within 3 business days.
10. Personal data protection measures
10.1. The Operator applies legal, organizational and technical measures to protect personal data against unlawful access, destruction, alteration, blocking, copying and distribution, including:
- storing data on a server in the Russian Federation with restricted network access;
- encryption of data transmission channels (TLS);
- separation of access rights; access to data is granted on a least-privilege basis;
- replacing the name of the review author with a placeholder before the text is sent to the AI services;
- automatic deletion of data once the retention periods expire;
- logging and recording of actions performed with personal data;
- backups with control over how long the copies are kept;
- identifying security threats and periodically checking that the measures taken are sufficient.
10.2. The Operator has no technical way to rule out its own access to the texts of reviews and prepared replies, because that access is required for the Service to work. The access is limited organizationally and technically and is used only to the extent needed to fix malfunctions, at the Subscriber’s request or at the request of authorized authorities.
11. Use of cookies on the website
11.1. The website answerolog.com uses the following categories of cookies:
| Category | Purpose |
|---|---|
| Essential | keep the basic functions of the website working. Without them the website may work incorrectly |
| Analytics | collect anonymized statistics of website visits |
11.2. The Subscriber and any visitor to the website can limit or disable cookies in their browser settings. Disabling essential cookies may cause the website to work incorrectly.
11.3. Cookies are not used to identify a specific visitor to the website.
12. Changes to this Policy
12.1. The Operator may amend this Policy. The date of the current version is shown at the beginning of the document.
12.2. A new version takes effect once it is published on the website, unless the version itself provides otherwise. The Operator gives notice of changes that materially affect the rights of data subjects at least 7 calendar days in advance.
13. Contacts
Individual Entrepreneur Artem Valerievich Starostin
INN 191002217434 · OGRNIP 321190000011867
Address: apt. 39, 43 Pionerskaya St., Ust-Abakan urban settlement, Republic of Khakassia, Russia, 655102
Email: starostin.media@gmail.com
Telegram: @starosting
Phone: +7 903 906-19-19
Support hours: Monday to Friday, 10:00–19:00 (Moscow time).