Privacy Policy

1. Introduction

This Privacy Policy describes how [Foooh LLC] (hereinafter — the "Controller", "we", "us", "our") collects, uses, discloses and otherwise processes personal data of visitors and users of the website https://foooh.ru and the related services (the "Service"). The Policy is drafted in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and, where applicable, the California Consumer Privacy Act ("CCPA"), as amended by the CPRA, and other applicable privacy laws.

By using the Service you acknowledge that you have read and understood this Policy.

2. Data controller

• Legal name: [Foooh LLC]
• Tax ID (INN): [INN]
• Registered address: [registered address]
• General contact: legal@foooh.ru
• Data Protection Officer: dpo@foooh.ru
• Phone: [+7 …]

If you are located in the EU/EEA and we have not designated an EU representative, you may contact the DPO directly using the address above.

3. Categories of data subjects and personal data

We process personal data of the following categories of data subjects: website visitors, registered users, newsletter subscribers, payers.

The personal data we process includes:

• Identifiers: email address, name or alias, Telegram ID (telegram_id), account ID;
• Technical data: IP address, browser type and version, operating system, cookie identifiers, on-site activity logs;
• Transactional data: subscription status and history, payment history, masked payment instrument identifier (provided by the payment processor);
• Communications data: support tickets and message bodies, notification logs (email, push, Telegram).

We do not process special categories of personal data (Art. 9 GDPR) or biometric data.

4. Purposes and legal bases of processing

5. Retention

After expiry, personal data is deleted or irreversibly anonymised.

6. Recipients and processors

We engage the following processors that act on our behalf under data processing agreements:

• CloudPayments — payment processing for subscriptions;
• Timeweb Cloud (S3-compatible storage, servers in the Russian Federation) — user content and backups;
• Yandex Metrica (Yandex LLC) — anonymised website analytics;
• Google Analytics (Google LLC) — additional web analytics, enabled only with the user's consent.

We do not sell personal data and we do not share personal data with third parties for behavioural advertising without your prior consent.

7. International data transfers

Personal data of data subjects in the EU/EEA may be transferred to processors located outside the EEA only where adequate safeguards are in place, namely (i) an adequacy decision under Art. 45 GDPR, (ii) Standard Contractual Clauses approved under Art. 46 GDPR, or (iii) other lawful transfer mechanisms. A copy of the safeguards used for a specific transfer can be requested at dpo@foooh.ru.

8. Your rights under the GDPR

You have the following rights with respect to your personal data:

• right of access (Art. 15);
• right to rectification (Art. 16);
• right to erasure / "right to be forgotten" (Art. 17);
• right to restriction of processing (Art. 18);
• right to data portability (Art. 20);
• right to object (Art. 21), including objection to direct marketing at any time;
• rights related to automated individual decision-making (Art. 22);
• right to withdraw consent at any time (without affecting the lawfulness of processing performed before withdrawal);
• right to lodge a complaint with a supervisory authority (Art. 77).

To exercise any of the above, contact dpo@foooh.ru. We will respond within one month, with a possible extension of two further months for complex requests.

9. Cookies

We use three categories of cookies:

1. Strictly necessary — required for the Service to work (session, locale, consent record). Cannot be disabled.
2. Analytics — help us understand how visitors use the site. Loaded only with your consent.
3. Marketing — used to measure advertising performance. Loaded only with your consent.

You can change your preferences at any time via the "Cookie settings" trigger at the bottom of every page.

10. Children

The Service is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact dpo@foooh.ru and we will take prompt steps to delete it.

11. CCPA addendum (California residents)

If you are a California resident, you have the right to (i) know what personal information we collect, use and disclose; (ii) delete personal information we collected from you; (iii) correct inaccurate personal information; (iv) opt out of the "sale" or "sharing" of personal information; and (v) limit the use and disclosure of sensitive personal information. We do not sell personal information for monetary consideration. To exercise your rights, contact dpo@foooh.ru. We will not discriminate against you for exercising any of your rights.

12. Security

We apply technical and organisational measures appropriate to the risk, including access controls based on least privilege, encryption in transit, regular security reviews and a designated person responsible for the protection of personal data.

13. Changes

We may update this Policy from time to time. The current version is always published at https://foooh.ru/en/legal/privacy. Material changes will be notified by email or through an in-product notice.

14. Contact

For any questions regarding the processing of your personal data:

• general inquiries: legal@foooh.ru
• Data Protection Officer: dpo@foooh.ru
• postal address: [registered address]