Personal Data Processing Policy

1. General provisions

1.1. This Personal Data Processing Policy (hereinafter — the “Policy”) sets out the rules for processing and protecting the personal data of users of the “Razvitie & interest” service (hereinafter — the “Service”), available at the following addresses: children.hhivp.com, psipro.ru, razwitiepro.ru, razvitiei.ru, конструкторзаданий.рф.

1.2. Personal data operator:

• Individual entrepreneur — operator of razvitiei.ru
• INN: 771572181938
• OGRNIP: 326774600355591
• Postal address: Russia, Moscow, 127549, P.O. Box 48
• Email for personal data enquiries: privacy@razvitiei.ru

Person responsible for personal data processing was appointed by (order № 1 of 2026-05-18, Art. 22.1 of FZ-152).

The Operator is registered with the Russian DPA (Roskomnadzor) Personal Data Operators Registry: registration number 77-26-553814, order № 273 of 2026-05-25, notification registered 2026-05-22, data processing start 2026-05-18.

1.3. This Policy has been developed in accordance with Federal Law No. 152-FZ “On Personal Data” of 27 July 2006.

2. Purposes of personal data processing

2.1. The Operator processes personal data for the following purposes:

• registration and authentication of users in the Service;
• providing access to the features of the Service (generators and constructors of educational tasks: word-search puzzles, reading texts, crosswords and others; including ready-made tasks and exercises, learning materials);
• processing of subscription payments or purchases of individual materials, sets, and bundled task generations;
• informing users about subscription status and updates to the Service;
• improving the quality of the Service on the basis of anonymised analytics;
• sending advertising and informational messages (subject to a separate consent).

3. List of personal data processed

3.1. Data provided by the user upon registration:

• email address;
• first name and surname (optional);
• password (stored in hashed form using bcrypt).

3.2. Data collected automatically:

• IP address;
• cookie data (subject to consent);
• browser and device information (User-Agent);
• data on actions performed on the website (where analytical cookies are used).

3.3. Payment data is processed by NBCO YuMoney LLC (YooKassa) and is not stored by the Operator.

4. Legal grounds for processing

4.1. Personal data is processed on the following grounds:

• the consent of the data subject (Art. 6, para. 1, sub-para. 1 of Federal Law 152-FZ);
• performance of a contract (the public offer) — Art. 6, para. 1, sub-para. 5 of Federal Law 152-FZ;
• legitimate interest of the Operator in ensuring the security of the Service.

5. Manner of processing

5.1. Processing includes: collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer, anonymisation, blocking, deletion and destruction.

5.2. Personal data is stored on servers located within the territory of the Russian Federation.

6. Processing and storage periods

6.1. Personal data is processed until:

• the user deletes their account;
• consent to processing is withdrawn;
• the purpose of processing has been achieved.

6.2. After processing ceases, personal data is destroyed within 30 days, except in cases provided for by law.

7. Transfer of personal data to third parties

7.1. The Operator may transfer personal data to the following third parties:

• NBCO YuMoney LLC (YooKassa) — for payment processing;
• fiscal data operator (OFD) — for issuing receipts under Federal Law 54-FZ;
• Yandex (Yandex.Metrica) — anonymised analytics data (subject to user consent).

7.2. No cross-border transfer of personal data is carried out.

8. Cookies

8.1. The Service uses cookies of the following categories:

• Strictly necessary (technical) — these ensure the operation of the Service: authentication, session, CSRF protection. They are set without the user’s consent.
• Analytical — these collect anonymised statistics on the use of the Service. They are set only after the user’s consent has been obtained.
• Functional — these remember the user’s settings. They are set only after consent has been given.

8.2. The user can manage cookies through the consent banner on the website or via browser settings.

9. Rights of personal data subjects

9.1. The user has the right to:

• obtain information about the processing of their personal data;
• request the updating, blocking or destruction of personal data;
• withdraw consent to the processing of personal data;
• appeal against the actions of the Operator to Roskomnadzor (77.rkn.gov.ru) or in court.

9.2. To exercise these rights, send a request to: privacy@razvitiei.ru. The response time is up to 10 business days.

10. Personal data protection measures

10.1. The Operator takes the necessary organisational and technical measures:

• data encryption in transit (SSL/TLS);
• password hashing (bcrypt);
• access control to personal data;
• regular backups;
• security incident monitoring.

11. Final provisions

11.1. The Operator is entitled to amend the Policy. A new version enters into force from the moment of its publication on the website.

11.2. The current version of the Policy is available at: /privacy