Draft document, version v0.2 dated October 18, 2026. A lawyer is reviewing this text; we will fill in the fields in square brackets (company details, contact details, dates) before sales begin on October 28. The version published on this page on the date of payment will apply.
PRIVACY POLICY
on the processing of personal data
Version dated [publication date]. Effective as of [date].
1. Who we are
1.1. The personal data controller is Nebesny Osobnyak LLC (Republic of Armenia, Yerevan, state registration number […], tax identification number (ՀՎՀՀ) […], address: […]), hereinafter the “Controller”. Contact details for data-related questions: […e-mail], Telegram […].
1.2. Person responsible for personal data processing: [full name, position, contact details].
1.3. This Policy applies to the website [zverium.com] and Telegram bot [@bot_name] (hereinafter the “Service”) in all three languages of the website. We process data in accordance with the Law of the Republic of Armenia “On Protection of Personal Data.” If you live in the European Union, you also have rights under the EU General Data Protection Regulation (GDPR).
2. Who can use the Service and our policy on children
2.1. The “Memory for Work” Service is only for people aged 18 or older. We do not collect data from anyone under 18. If we learn that a person under 18 has submitted data, we will delete it.
2.2. We do not ask for or collect passport details, bank card details, health information, information about political views or religion, biometric data, photos, or voice recordings. Please do not include any of these in the form or in the bot chat.
3. What data we process, why, on what legal basis, and for how long
| When | What data | Why | Legal basis | Retention period |
|---|---|---|---|---|
| You submit a request on the website | name; contact details (Telegram, email, or phone number, whichever you provide); country; website language; goal (up to 500 characters); source of the request; IP address hash (irreversible) | to contact you, enroll you in a cohort, and answer your questions | your consent (checkbox in the form) | 12 months after the last contact, then deletion |
| You message the bot | Telegram ID, profile name, @username, message text, time, “came from website/channel” tag | to reply, enroll you in a cohort, and retain the conversation context | consent (button in the bot) | 12 months after the last message |
| You purchase the service | contact details for the receipt; payment status and amount (only the acquiring bank receives your card details; we do not see them); selected cohort and language | to enter into and perform the contract, provide payment confirmation, and issue refunds | contract; tax and accounting obligations | the term of the contract + [3 years — to be confirmed by a lawyer]; accounting records — as required by law |
| You take part in the training | answers to exercises and before/after tests, measurement results, completion records, “Your Own Content,” support requests | to show you your progress and reports, create a review schedule, and obtain responses from the AI assistant | contract | for the duration of Access and [3] months afterward; then deletion or anonymization |
| You visit the website | IP address, request URL, browser and device, time | to operate and secure the website and protect it from spam and overload | legitimate interest | server logs — about 14 days |
| You give or withdraw consent | consent text and version, time (UTC), identifier (Telegram ID or contact details), IP address hash | to demonstrate that consent was obtained | legal obligation | [3 years] after withdrawal |
3.1. We keep the amount of data to a minimum: your name, one way to contact you, and your country. For “Goal,” you can choose from a list or write a short response; share only what you are comfortable telling us.
3.2. We do not use the data to make automated decisions that would have legal effects on you.
3.3. We ask for separate consent to send marketing and informational messages. Service-related messages about your cohort are part of the service, not advertising.
4. What we do with data
We collect, record, organize, store, update, and use data; transfer it to the recipients listed in section 5; anonymize it; restrict its processing; and delete it. We process data both by automated and non-automated means.
5. Who receives data
| Recipient | Role | Country | What they receive |
|---|---|---|---|
| Hetzner Online GmbH | hosting for the server that runs the website and bot | Finland (data center); Germany (legal entity) | all data in the database and logs |
| Telegram | communication channel for the bot; notifications to staff about new requests | [to be confirmed] | bot messages; the text of website requests in staff notifications |
| Anthropic PBC | provider of the language model that generates AI assistant responses | United States | the text of your messages and questions to the assistant (without your name or contact details) |
| [Acquiring bank] | processing payments made with Visa, Mastercard, and ArCa cards | Armenia | amount, order number, contact details for confirmation; you enter your card details only on the bank’s page |
| [Email delivery service] | emails with the payment link and access details | […] | email address and message text |
| Public authorities | as required by law | Armenia | data within the scope of a lawful request |
5.1. We will not sell data or share it for third-party advertising.
5.2. Recipients process data on our instructions or independently in accordance with their own policies; we enter into agreements with data processors.
6. International data transfers
6.1. Some recipients are located outside Armenia (section 5). We transfer to them only the data needed to operate the Service and choose recipients that protect personal data.
6.2. We do not send your name, contact details, or payment details in requests to the language model; we send only the text of your question. However, free-text messages can themselves contain personal data, so please do not share other people’s personal data or your own sensitive information with the assistant.
7. How we protect data
7.1. The connection to the website is secured by HTTPS. Server access uses key-based authentication and is limited to those who need it for their work; a firewall is enabled on the server. IP addresses in the database of submitted requests are stored only as irreversible hashes. Backups are stored on the Controller’s secure servers.
7.2. If we learn of a data breach, we will notify the competent personal data protection authority and you within the time limits required by law.
8. Cookies, trackers, and fonts
8.1. The website does not set cookies or use advertising or analytics trackers.
8.2. Fonts, images, and scripts are loaded from our server, so third-party services do not receive your IP address when you view the website. If we decide to add analytics, we will first ask for consent through a banner (“Necessary only” will be the default).
9. Your rights
9.1. You have the right to find out whether we process your data and receive information about the purposes, recipients, retention periods, and international transfers; obtain a copy of your data; request correction, restriction of processing, or deletion; withdraw consent; and lodge a complaint with the Personal Data Protection Agency of the Ministry of Justice of the Republic of Armenia or bring a claim before a court. If you live in the EU, you may also complain to the data protection supervisory authority in your country.
9.2. How to submit a request: email […e-mail] with the subject line “Data” or use the [/mydata] or [/delete] command in the bot chat. We may ask you to confirm that the request is from you (for example, by replying using the contact details you provided in your website request).
9.3. We respond to requests within the time limits required by law — [no later than 10 business days — to be confirmed by a lawyer].
9.4. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal. If you withdraw consent before purchasing, we will stop corresponding with you, discontinue your cohort enrollment process, and delete your data (except data we must retain by law). If you have already purchased the service, we will continue to process the data needed to perform the contract, confirm payment, and issue refunds.
10. AI in the Service
10.1. The host “Timofey Ilyich” and the AI assistant are software programs. Responses are generated automatically and may contain errors; we do not use them to make decisions about you. For more information, see section 7 of the Public Offer.
10.2. Whether the model provider uses your text for training and how long it retains it: [to be completed after reviewing the provider’s terms].
11. Changes to this Policy
We publish each new version on this page with its date. We notify people who have provided contact details of material changes.