Personal data processing policy
for the Elia mini-app and the site elia-app.ru
This Policy is a standalone document of the Operator. The standard VK privacy policy does not apply to the App or the Site.
1. General provisions
1.1. The Policy sets how personal data of users of the Elia mini-app on VKontakte (the «App») and visitors of https://elia-app.ru (the «Site») are processed and protected.
1.2. The Policy is prepared under Federal Law No. 152-FZ of 27.07.2006 «On Personal Data» («152-FZ») and other Russian regulations.
1.3. The User accepts the Policy together with the User agreement before using the App. Until both documents are accepted, the Operator does not create a User profile and does not record answers.
1.4. The legal basis for processing is the User's consent.
1.5. The App is intended for users aged 16 or over.
2. Operator
2.1. Personal data operator (the «Operator», «we»): sole proprietor Алексеев Иван Викторович, INN 615011071608, OGRNIP 322619600000957, registered in the Russian Federation.
2.2. Address and contacts: Республика Калмыкия, Черноземельский муниципальный район, сельское поселение Комсомольское, п. Комсомольский, ул. им. Темира Мускеевича Нимгирова, д. 17; tel. +7 961 817-41-46; e-mail: support@elia-app.ru, alekseev_ivan@mail.ru. Contacts are also on the Contacts page: https://elia-app.ru/contacts.
2.3. The Operator has notified the authorized body for protection of personal-data subjects (Roskomnadzor) of the intent to process personal data under Art. 22 of 152-FZ. Register number: 08-26-000957, date: 30 October 2026.
2.4. The VKontakte platform provides the venue and, with the User's consent, passes the Operator a minimal set of profile data. The Operator, not VKontakte, is responsible for processing inside the App.
3. Data processed
3.1. VKontakte profile data passed by the platform when the App is opened and access is confirmed:
a) numeric identifier (VK ID);
b) first name and last name.
The Operator does not request the friends list, photos, music, messages, phone number or email.
3.2. Data entered by the User:
a) stage: pregnancy trimester or the period after birth;
b) answers to a short questionnaire and the psychotype calculated from them, with trait scores;
c) a stress-level rating, including before and after a technique;
d) diary entries: a mood rating and a text note (if the User wrote one);
e) EPDS answers and the total score (a self-observation result, not a diagnosis);
f) favorite techniques;
g) if the User invites a close person: that person's VK ID after following the invite link, their questionnaire answers, and the User's answers «how I see the partner»;
h) if a technique is gifted: who sent the gift, who activated it, and the access term.
3.3. Data arising from use of the App:
a) which techniques were opened and completed;
b) free-access limit counters;
c) a stress-zone mark;
d) that a crisis scenario fired (which trigger and what was shown);
e) subscription status and payment details (amount, status, VK payment id);
f) hashed login tokens;
g) a platform flag (browser or VKontakte client).
3.4. Server technical data: IP address, device and browser type, request time. They are kept in logs needed to run and protect the service.
3.5. The Operator does not collect precise geolocation, does not keep a medical record, does not request documents, and does not request third-party data except a partner invited by the User.
4. Purposes
4.1. The Operator processes data only for the following purposes and does not use it for other purposes without new consent:
a) selecting techniques for psychotype, stage and stress level;
b) saving progress, favorites and history so the App keeps data between launches;
c) counting free-access limits and providing Premium;
d) showing a crisis scenario when the User's answers indicate it;
e) taking payment and granting access;
f) passing hints to a partner invited by the User;
g) answering requests and confirming that consent was obtained;
h) security: so that third parties cannot act in the User's name and so that requests to the App cannot be automated.
4.2. The Operator records acceptance of the documents: date, User agreement version and Policy version. This is needed to confirm the legal basis of processing on request.
4.3. Product statistics. The Operator stores de-identified events: which screen was opened, which technique was completed, how the stress rating changed. The identifier in these records is hashed and does not let the Operator recover a VK ID. Note texts, questionnaire answers and the EPDS score do not go into statistics. Detailed events are deleted after 180 days; after that only summary numbers remain.
5. Where data is processed
5.1. The App server and database are in the Russian Federation. Hosting provider: Selectel LLC (ООО «Селектел»), data center: Saint Petersburg.
5.2. Collection, recording, systematization, accumulation, storage, updating and retrieval of personal data of Russian citizens are done using databases in the Russian Federation, under cl. 5 Art. 18 of 152-FZ. This also applies to backups and logs.
5.3. The Operator does not transfer personal data across borders. If such a transfer is needed later, the Operator will notify Roskomnadzor under Art. 12 of 152-FZ and update the Policy before the transfer starts.
6. Disclosure and processors
6.1. The Operator does not transfer data to third parties for their own purposes, does not sell it, does not give it to ad networks, and does not use it for scoring or analytical reports for third parties. VK ID is not passed to external analytics.
6.2. The Operator instructs infrastructure providers bound by contracts and confidentiality to process data technically:
a) App hosting and managed database: Selectel LLC (ООО «Селектел»), whose infrastructure is in the Russian Federation;
b) payments: VK payment services. The Operator does not see or store card data.
6.3. Data may be provided to public authorities where Russian law requires it.
6.4. The App does not use external counters. If any are connected, the Operator will update the Policy first.
7. Site: cookies and Yandex Metrica
7.1. Site pages use Yandex Metrica (counter 113125703), which records page views and clicks and records visitor actions (webvisor). This data relates to Site visitors, not App users. VK ID, questionnaire answers and diary notes are not sent to Yandex Metrica.
7.2. The Operator loads Yandex Metrica and webvisor only after the visitor consents via a banner on the Site. Until consent, the counter is not loaded and no data is collected. The visitor may refuse, and the Site remains fully available.
7.3. Webvisor is set not to record input-field contents or other data the visitor types on the Site.
7.4. The visitor may withdraw consent in the banner settings or by deleting cookies in the browser.
7.5. Site-visitor data is processed by Yandex as operator of its own service on Yandex Metrica terms. Purpose: analysing Site use and improving it.
8. Retention
8.1. Data is stored as follows:
a) profile, psychotype, diary, technique history: while the User uses the App and has not deleted the profile;
b) detailed statistics events: 180 days;
c) login tokens: until they expire;
d) partner invites and technique gifts: until the link or access expires;
e) payment details: for the periods set by law for accounting and tax records, including after profile deletion;
f) the fact of document acceptance: for as long as needed to confirm that processing was lawful.
8.2. When the purpose is reached or consent is withdrawn, the Operator stops processing and destroys the data, except what must be kept by law.
9. Withdrawal of consent and deletion
9.1. The App has a privacy section with a profile-deletion button. It deletes the profile, answers, diary, technique history and favorites. The same can be done by writing to the Operator emails in cl. 2.2.
9.2. Withdrawing consent stops processing and destroys the data. The App cannot be used after that, because techniques cannot be selected without the User's answers.
9.3. If the User refused profile-data access, the App explains why it is needed and does not repeat the request insistently. Some functions are unavailable without this data.
10. User rights and response times
10.1. The User may:
a) obtain information on which data is processed, for what purpose and on what basis;
b) demand clarification, blocking or destruction of data;
c) withdraw consent;
d) appeal the Operator's acts to Roskomnadzor or a court.
10.2. Send the request to the emails in cl. 2.2. Give the VK ID or the name used in the App, otherwise the Operator cannot find the record.
10.3. The Operator reviews requests as follows:
a) information about processing: 10 business days from receipt; this may be extended by no more than 5 business days with a reasoned notice;
b) clarification of data: 7 business days from the User providing supporting information;
c) stopping unlawful processing: 3 business days from discovery; if lawfulness cannot be ensured, data is destroyed within 10 business days;
d) stopping processing and destroying data after withdrawal of consent: no more than 30 days from receipt of the withdrawal, unless the law sets another term. Deleting the profile with the in-app button deletes the data immediately.
11. Protection
11.1. The Operator applies these measures:
a) the App can be opened only through a confirmed VKontakte launch with signature checks;
b) the connection uses HTTPS;
c) database access is restricted; service keys are stored only on the server;
d) the statistics identifier is hashed;
e) request rate to the App is limited so data cannot be exported automatically.
12. Personal-data incidents
12.1. In case of unlawful or accidental transfer (provision, dissemination, access) of personal data that violates subjects' rights, the Operator:
a) within 24 hours of discovering the incident notifies Roskomnadzor of what happened, presumed causes and harm, measures taken, and the contact of the person authorized to deal with Roskomnadzor;
b) within 72 hours of discovering the incident notifies Roskomnadzor of the internal investigation and of persons whose acts caused the incident, if identified.
12.2. The Operator also notifies the VKontakte administration and affected Users.
13. Age
13.1. The App is intended for persons aged 16 or over. The Operator does not collect children's data knowingly. If this happens, notify the Operator and the record will be deleted.
14. Additional statements
14.1. The App is not a medical service. A questionnaire score is a self-observation result, not a diagnosis. Techniques are not treatment or psychotherapy.
15. Changes
15.1. The Operator may update the Policy. The new version is published at https://elia-app.ru/privacy with a new date and version number.
15.2. If changes expand processing purposes, the Operator asks for consent again.
16. Contacts
16.1. All requests about data processing, profile deletion and withdrawal of consent go to the emails in cl. 2.2, or to the contacts on the Contacts page.