Privacy Policy
Version 1.3 · Effective date: September 27, 2026
Personal Data Operator: Individual entrepreneur Alexey Anatolyevich Mironov, OGRNIP 325547600160662
Operator's address: Novosibirsk, Russia. The full address is provided to a personal data subject upon request sent to the email address indicated below (Section 8).
Website: fitgeniusai.ru
DPO Email: dpo@fitgeniusai.ru
Application: FitGeniusAI (iOS / Android / macOS)
Jurisdiction: Russian Federation. This Policy is developed in accordance with Art. 18.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".
The Operator collects the following categories of personal data:
| Data | Collection method | Purpose | Legal basis |
|---|---|---|---|
| Email address | Waitlist form on the website | Notification about service launch | Consent (Art. 9 152-FZ) |
| Email address | Registration in the application | Authorization, notifications | Contract performance (cl. 5 Art. 6) |
| OAuth account data (VKontakte, Yandex, Sber) | Authorization via OAuth | User identification | Consent (Art. 9 152-FZ) |
| IP address | Automatically upon server access | Security, fraud prevention | Legitimate interest / security (Art. 19) |
| Health and physical parameter data | Entered by user in the application | Generation of personalized workouts | Explicit consent (Art. 10 152-FZ) |
| Website behavior data (Yandex.Metrica) | Analytical cookies | Service improvement, analytics | Consent (Cookie Policy) |
| Training activity data | Entered/generated by user in the application | Creation of training programs | Contract performance |
| Food photos | Uploaded in the application | AI analysis of composition and calories | Explicit consent (Art. 10 152-FZ) |
| Text of requests to AI assistants (coach, nutritionist) | Chats in the application, on the website, in MAX | Generation of personalized responses and recommendations | Contract performance |
Data on health status and physical parameters (height, weight, fitness level) belong to special categories of personal data under Art. 10 152-FZ. Their processing is carried out exclusively with separate explicit consent from the User, obtained in the FitGeniusAI application during registration. The volume of such data necessary for generating personalized recommendations is transferred to the AI providers listed in Section 7 — as part of request content and without user identifiers (email, phone number, and account identifiers are not transferred).
| Basis | Norm | Applies to |
|---|---|---|
| Consent of the PD subject | cl. 1 pt. 1 Art. 6; Art. 9 152-FZ | Email waitlist, analytical cookies, marketing |
| Contract performance with subject | cl. 5 pt. 1 Art. 6 152-FZ | Application operation, training data |
| Ensuring security | Art. 19 152-FZ | IP addresses, server logs |
| Explicit consent (special categories) | cl. 1 pt. 2 Art. 10 152-FZ | Health and physical parameter data |
In accordance with pt. 5 Art. 18 152-FZ and requirements effective from July 1, 2025, all personal data of citizens of the Russian Federation is collected, recorded, systematized, accumulated, stored, updated, and extracted exclusively using databases located on the territory of the Russian Federation.
In case of personal data breach, the Operator undertakes to notify Roskomnadzor within 24 hours, and PD subjects — within 72 hours (Art. 21 152-FZ, 2025 ed.).
| Data | Retention period |
|---|---|
| Email (waitlist) | Until consent withdrawal + 30 days, but no more than 12 months from subscription date |
| Application account data | Until account deletion + 30 days |
| Health and workout data | Until account deletion |
| IP addresses (logs) | 30 days |
| Consent records | 3 years from the date of consent |
The Operator does not sell personal data and does not transfer it to third parties for independent marketing.
Personal data is processed by the Operator as well as by processors engaged by the Operator under an assignment (Art. 6 part 3 of Federal Law No. 152-FZ) to the extent necessary for the operation of the Service. The user's email address is used exclusively for identifying the user within the Service and delivering service emails: it is stored in encrypted form, is not used for any other purposes, and is not disclosed to third parties for their own purposes.
For certain functions of the Service (including generating workout programs and AI coach responses, and food photo recognition), only depersonalized information is transferred to the external computing environment — without direct user identifiers (email, name, account credentials). Images of people in photos are not transferred to external processors: frames with faces are blocked by technical controls; the exception is the exercise technique check function, where the face in the uploaded frame is masked (blurred) automatically. The composition of depersonalized information, the platforms used, and the selection procedure are defined by the Operator's internal policy; this policy may be revised by the Operator, including for economic reasons, and is not fixed. Up-to-date information about the processors in use is provided upon user request in accordance with Section 8.
No cross-border transfer of personal data is performed.
In accordance with Art. 14–21 of Federal Law No. 152-FZ, the User has the right to:
To exercise your rights, send a request to dpo@fitgeniusai.ru. The Operator must respond within 10 business days (Art. 20 152-FZ), and in complex cases — no later than 30 days.
Consent for PD processing is provided by the user explicitly by:
Silent consent, pre-checked boxes, and continued use of the site as the sole method of recording consent are not used. Consent can be withdrawn at any time without negative consequences by writing to dpo@fitgeniusai.ru. After withdrawal, data is destroyed within 30 days.
The FitGeniusAI service is intended for users over 18 years of age. The Operator does not intentionally collect personal data of persons under 18 years of age. Upon discovery of such data, it will be immediately deleted.
The website uses Yandex.Metrica — a Russian analytical service owned by Yandex LLC (Russia). Yandex.Metrica may use the "Webvisor" feature, which records user actions on the page. Data is processed by Yandex LLC servers on the territory of the Russian Federation in accordance with the Yandex Privacy Policy. You can opt out of analytics through Cookie settings on our website.
The Operator is included in the Register of Personal Data Operators of Roskomnadzor in accordance with Art. 22 of 152-FZ. The current record is available in the public register of operators: pd.rkn.gov.ru/operators-registry.
The Operator has the right to make changes to this Policy. The current version is always available at fitgeniusai.ru/privacy. Users will be notified of material changes by email at least 10 days before they take effect. Continued use of the service after the changes take effect means acceptance of the new version of the Policy.
This Policy is governed by the legislation of the Russian Federation. Any disputes are resolved in a pre-trial claim procedure (response period — 30 days), and if no agreement is reached — in court at the Operator's location.
For questions about personal data processing, exercising your rights, or complaints:
Email: dpo@fitgeniusai.ru
Website: fitgeniusai.ru
Roskomnadzor (complaints): pd.rkn.gov.ru