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 information, dates) before sales begin on October 28.

Consent to the Processing of Personal Data (version consent-v0.2 dated [date])

1. Data controller: Nebesny Osobnyak LLC, Republic of Armenia, Yerevan, Taxpayer Identification Number (ՀՎՀՀ) […], address […], email […]. Person responsible for processing: [full name].
2. Who gives consent: a visitor to [zverium.com] who is at least 18 years old and has checked the box on the sign-up form.
3. Purpose: to contact you about your sign-up request, answer your questions, enroll you in a Memory for Work cohort, and send you a payment link.
4. Data processed: name; contact details (Telegram, email, or phone number, whichever you provide); country; site language; goal (selected from a list, up to 500 characters); source of the sign-up request; technical data (an irreversible hash of the IP address and the time).
5. Processing activities: collection, recording, organization, storage, updating and correction, use, transfer to the recipients listed in item 6, blocking, and deletion.
6. Who may receive the data: hosting provider Hetzner Online GmbH (Germany; servers in Finland); Telegram (to notify a staff member of your sign-up request); [the acquiring bank in Armenia — only the amount, order number, and contact details for payment confirmation]. Some recipients are located outside Armenia.
7. Retention period: 12 months from the last contact about your sign-up request if you have not purchased the service; for customers who have purchased the service, for the term of the contract and any retention periods required by law. The data is then deleted.
8. How to withdraw consent: email […email] or send the command [/delete] in the chat with the bot. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Data that must be retained by law is deleted when the required retention period ends.
9. Your rights and responses to requests are described in the Privacy Policy (section 9).

You confirm your consent by checking the box on the form. The date, time, version of the consent text, and identifier are recorded in a log.