Privacy Policy

Version dated 8 June 2026

This Privacy Policy (hereinafter the "Policy") sets out the procedure for processing and protecting the personal data of natural persons (hereinafter the "User", "you") who use the website lyusya.app and its services (hereinafter the "Site"), as well as those who submit their data through the forms on the Site.

The Policy has been prepared in accordance with the requirements of the applicable personal data legislation, including Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", and applies to all personal data that we receive from the User.

By using the Site and submitting your data through the forms, you confirm that you have read this Policy, understand it and agree to the terms of processing your personal data. If you do not agree with the Policy, do not use the Site and do not submit your data.

1. Definitions

• Personal data — any information relating to a directly or indirectly identified or identifiable natural person.
• Processing of personal data — any action or set of actions performed on personal data (collection, recording, systematisation, accumulation, storage, updating, use, transfer, anonymisation, blocking, deletion, destruction).
• Operator — the person who organises and carries out the processing of personal data, as well as determines the purposes and the composition of the data processed. The Operator's details are set out in Section 2.
• Site — the website lyusya.app and all its pages, forms and services.
• Contractor (processor) — the person who processes personal data on the Operator's instructions.

2. Who processes your data (the Operator)

• Operator: the Lyusya project (lyusya.app).
• Contact for any questions regarding the processing of personal data: [email protected].

For any question about your data, to exercise your rights or to withdraw consent, write to the address indicated. We respond within a reasonable time, as a rule within 30 days.

3. What data we process

We adhere to the principle of data minimisation and collect only the data that you yourself provide in the Site's forms:

• email address;
• messenger nickname (Telegram) — optional, if you have provided it;
• answers to the questionnaire (for example, the age of your children, what tasks you wish to solve, what you currently use) — if you have filled them in;
• technical data that your browser automatically transmits when you visit the Site: IP address, type and version of the browser and device, referral source and advertising campaign tags (UTM), date and time of the visit. This data is used in anonymised form for the operation and security of the Site.

We do not request and do not collect: passport data and other documents, payment and banking data, health information, or special categories of personal data. We do not ask you to enter your children's data on the Site.

4. Purposes of processing

We process your data solely for the following purposes:

• to contact you regarding the launch and development of the Service;
• to send you the launch announcement and the early access offer (founding terms);
• to take your answers into account in order to make the product more useful;
• to ensure the operation, security and stability of the Site, to prevent fraud and spam;
• to comply with the requirements of the law.

We do not use your data for purposes incompatible with those indicated above, and we do not transfer it to third parties for their own marketing.

5. Legal bases for processing

We process personal data on the following bases:

• your consent, which you give by ticking the relevant box when submitting the form (the principal basis for sending announcements and for taking the questionnaire into account);
• our legitimate interest in ensuring the operation, security and protection of the Site (in respect of technical data);
• compliance with the requirements of the law, where processing is directly provided for by it.

Consent is voluntary. You may withdraw it at any time (see Sections 9 and 10).

6. Principles of processing

We process data lawfully and fairly, limit ourselves to the stated purposes, do not collect excessive data, keep it accurate and up to date, and store it no longer than necessary.

7. Storage periods and procedure

We store your personal data until the purposes of processing are achieved — that is, until the launch of the Service and contact has been established with you, or until you withdraw your consent, whichever occurs first. Once the purpose has been achieved or upon your request, the data is deleted or anonymised within a period not exceeding 30 days, unless another period is established by law.

8. Transfer of data to third parties

To operate the Site, we engage contractors who process data on our instructions and only for the purposes indicated above. These are contractors of the following categories:

• a data hosting and storage service (the application database);
• a service for the delivery of internal notifications about new applications;
• a service for recording and handling enquiries.

With such contractors we structure relationships on terms of confidentiality and processing of data solely on our instructions. A full list of contractors is provided upon request at [email protected].

We do not sell your data and do not transfer it to third parties for their own purposes, except in cases directly provided for by law (for example, in response to a lawful request from authorised state bodies).

Cross-border transfer. Part of the processing may be carried out using the infrastructure of contractors. In the event that this entails the transfer of data to the territory of a foreign state, such transfer is carried out on the basis of your consent and with the adoption of reasonable measures to ensure the protection of data. By ticking the consent box when submitting the form, you confirm your consent, including to such transfer.

9. Withdrawal of consent

You have the right to withdraw your consent to the processing of personal data at any time by sending a message to [email protected]. Upon receipt of the withdrawal, we cease processing and delete your data, with the exception of information that we are required to store by law. The withdrawal of consent does not affect the lawfulness of processing carried out before its receipt.

10. Your rights

In respect of your personal data you have the right to:

• obtain confirmation of the fact of processing and information about what data of yours we hold, on what basis and for what purposes we process it;
• demand the updating, blocking or deletion of data if it is incomplete, outdated, inaccurate, obtained unlawfully or not necessary for the stated purpose;
• withdraw consent to processing;
• object to processing and demand that it cease;
• lodge a complaint with the authority for the protection of the rights of personal data subjects (in the Russian Federation — Roskomnadzor; in EU states — the local supervisory authority), as well as with a court.

To exercise any right, write to [email protected]. We may ask you to confirm your identity (for example, by replying from the same email) so as not to disclose data to an unauthorised person.

11. Minors

The Site and the forms are intended for adults (parents and other persons of legal age). We do not knowingly collect the data of minors through the Site's forms and ask that you do not enter children's data on the Site. If we become aware that the data of a minor has been transmitted without the consent of a parent or legal guardian, we will delete it. If you believe that we may have received such data, inform us at [email protected].

12. Cookies and analytics

The Site uses cookies and similar technologies. Details are set out in a separate Cookie Policy. Analytics tools, if they are connected, are activated only after your consent in the cookie banner.

13. Automated decisions

We do not make decisions in respect of you that produce legal consequences solely on the basis of automated data processing, and we do not engage in profiling for such purposes.

14. Data protection measures

We take reasonable and sufficient legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination and other unlawful actions: we restrict access to data, use secure transmission channels and trusted contractors. At the same time, the transmission of data over the internet cannot be guaranteed to be 100% secure, and we cannot be held responsible for the actions of third parties that are outside our reasonable control.

15. Changes to the Policy

We have the right to update this Policy. The current version is always posted on the page lyusya.app/privacy with the date indicated. Where possible, we additionally bring material changes to the attention of Users. Continued use of the Site after the publication of changes signifies agreement with the updated version.

16. Contacts

For all questions related to the processing of personal data, the exercise of rights and the withdrawal of consent:

Operator: the Lyusya project · E-mail: [email protected] · Site: lyusya.app