Privacy Policy of "UCHU" App

Version: 1.1   Effective Date: 16.01.2026

1. General Provisions

1.1. This Policy defines the procedure for processing and protecting the personal data of users of the "UCHU" mobile application (hereinafter — the Application).

1.2. Personal Data Operator: Erik Alexandrovich Minasov, address: <P.O. Box>, e-mail for personal data inquiries: uchuacademy@gmail.com.

1.3. The Operator processes personal data in accordance with the legislation of the Russian Federation, including Federal Laws No. 152-FZ "On Personal Data", No. 242-FZ (localization of databases), and No. 149-FZ.

2. Processed Data and Sources

2.1. The User provides data during registration and use of the Application:

• Name (Contact Info — Name).
• Phone Number (Contact Info — Phone Number).
• Age Group (Demographics; e.g., 14–17, 18–24, 25–34, 35–44).
• Learning Preferences: goals, estimated study time per day, and interactions within the Application (App Interactions/Other Data).

2.2. Technical Data: information about the device and operating system, technical information, and error reports (log files) required for the functioning of the Application (minimum necessary volume).

2.3. The Application does not request access to the microphone/camera/geolocation unless explicitly indicated to the user.

3. Purposes of Processing

1. Creation and maintenance of an account, authentication, user support.
2. Personalization of content and tasks, formation of the curriculum.
3. Ensuring security and preventing fraud/abuse.
4. Product analytics — after separate activation of relevant features (if activated, the purposes will be expanded in App Privacy and this Policy).
5. Compliance with legal requirements and responding to requests from authorized bodies.

4. Legal Grounds for Processing

1. Conditions for personal data processing (Art. 6 of 152-FZ).
2. User consent (Art. 9 of 152-FZ).
3. Performance of a contract (public offer/Application Terms of Use).
4. Fulfillment of legal obligations imposed on the Operator.

5. Processing of Children's Data

5.1. The Application is not intended for persons under 14 years of age. Registration for users under 14 is not available.

5.2. Users aged 14–18 use the Application with the consent of a legal representative if required by law.

6. AI Content and Automated Processing

6.1. Content in the Application may be generated by artificial intelligence systems. Inaccuracies and distortions are possible; the information is for reference only and does not replace specialist consultations.

6.2. Personalization of learning may include elements of automated processing and profiling for selecting content and tasks.

7. Transfer to Third Parties and Processors

7.1. The Operator may engage processors (hosting providers, SMS gateways, etc.) to provide services on behalf of the Operator, subject to compliance with 152-FZ and the conclusion of data processing agreements.

7.2. As of the time of publication, the Application does not use third-party advertising SDKs or cross-site tracking mechanisms (ATT). If analytics/SDKs are connected in the future, the Operator will update this Policy, App Privacy, and Privacy Manifest.

7.3. Data is not sold or disclosed to third parties outside the purposes specified in Section 3, except as provided by law.

8. Cross-Border Transfer

8.1. The primary database of personal data of Russian citizens is stored on the territory of the Russian Federation (242-FZ).

8.2. As part of the Application's operation (generation of educational content), some user data (anonymized requests or learning context) may be transferred to foreign countries that provide adequate protection of the rights of personal data subjects (including the PRC for interaction with DeepSeek services). The Operator will ensure compliance with 152-FZ requirements for such transfers.

9. Storage Periods

9.1. Data is stored for the duration of the account's validity and/or until consent is withdrawn, unless other periods are provided by law.

9.2. Certain information may be stored for periods established by the legislation of the Russian Federation (e.g., statutes of limitations, accounting, and tax periods).

10. Rights of the Personal Data Subject

• to receive information about the processing of personal data;
• to demand updating, blocking, or destruction of data if the data is incomplete, outdated, inaccurate, illegally obtained, or not required for the stated purpose;
• to opt-out of personalized recommendations and withdraw consent;
• to appeal the Operator's actions to Roskomnadzor or a court.

11. Exercise of Rights and Contacts

11.1. Inquiries and statements should be sent to e-mail: uchuacademy@gmail.com or to the address: 9 <P.O. Box>. The Operator will consider the request within the period established by law (usually up to 30 days).

11.2. An account deletion function is available in the Application: Profile → "Delete Account". After confirmation, we will delete personal data, except for that which we are required to keep by law, within a reasonable timeframe.

12. Data Protection Measures

12.1. The Operator applies organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions.

12.2. Access to data is limited; processing is carried out on a minimum necessary basis.

13. Cookies and Similar Technologies

13.1. The Application may use strictly necessary cookies/local storage to ensure functioning (sessions, interface settings). Marketing/advertising trackers are not used.

13.2. If the set of technologies is expanded, the Operator will update this Policy.

14. Changes to the Policy

14.1. The Operator may update the Policy; the new version comes into force from the moment of its publication at: https://uchu.academy/policy.

14.2. Significant changes will be brought to the attention of users in the Application.

15. Acceptance of the Policy

15.1. By installing and using the Application, the user confirms acceptance of the terms of this Policy and gives the Operator consent to process personal data in the volume and for the purposes specified above.

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