Personal Data Processing Policy
Draft of the next revision. The effective date will be set upon approval. This revision is unpublished and does not replace the current documents.
1. Who processes the data
Controller: Жужгов Роман Алексеевич, Russian Federation, Taxpayer ID (INN) 590618061494; individual applying the professional income tax regime. Contact for questions about processing and exercising rights: support@insoweb.ru. This policy applies to accounts, use of Akmelo, enquiries, and contractual relationships. Processing on a corporate client's instructions is additionally governed by the agreed instructions.
2. Purposes, data, and legal bases
| Purpose | Categories of data | Legal basis where applicable |
|---|---|---|
| Account creation, sign-in, settings, and access management | Username, name, email address, profile image and appearance, user preferences, membership and permissions, protected authentication information | Entering into and performing an agreement; separately obtained consent where needed |
| Performing tasks and delivering results | Source settings, instructions, uploaded materials, and results within the agreed scope | Agreement and lawful client instructions; third-party information requires a separate legal basis |
| Service accounting and payments | Transaction identifiers, amounts, status, and the contractual party's details to the extent needed | Agreement and applicable accounting and tax duties |
| Evidence of an agreement, amendments, and delivery of documents | Account identifier, document versions and fingerprints, time and content of confirmations submitted in the form | Entering into and performing an agreement and protecting legitimate interests while respecting data subjects' rights |
| Security and error investigation | Network addresses, times, session information, technical logs, and access events | Legitimate security interests while respecting data subjects' rights; statutory duties |
| Reviewing cloud tasks and investigating violations | Code and necessary task parameters, fingerprints of reviewed revisions, risk categories, reasons for holds, staff decisions, and review history | Contract performance to the extent necessary; legitimate interests in security and protection of rights while respecting the data subject's rights; statutory duties |
| Investigating possible circumvention of restrictions | Protected derivatives of verified sign-in, browser, and verified native application connection identifiers, and their links with accounts | Legitimate interests in protecting cloud infrastructure and other users, subject to proportionality and respect for data subjects' rights |
| Considering appeals | Case identifier, user explanation, necessary evidence, and staff response | Handling the enquiry, contract performance, and duties to protect rights |
| Responding to enquiries and protecting rights | Contact details, the content of an enquiry, and necessary evidence | Handling the enquiry, agreement, fulfilling duties, and protecting legitimate interests |
| Discussing a task with the public assistant and resuming a conversation | Visitor messages, assistant replies, conversation title and times, and a random technical browser identifier | Responding to an enquiry and taking necessary steps towards an agreement at the data subject's initiative; legitimate interests in providing the requested history while respecting the data subject's rights; separately obtained consent where needed |
Opening this policy alone does not constitute consent. Marketing messages are not part of essential service notices and require an appropriate separate basis. Processing is limited to the stated purposes. Sensitive information should not be included in ordinary enquiries.
Derived identifiers that can be linked to an account remain personal data. They are not used for advertising or monitoring visits to other websites. Circumvention checks do not use an IP address to identify a person, a hardware fingerprint, or hidden collection of browser characteristics. A shared browser, device, or network does not establish that users are the same person. Access to account links is limited to staff who need them to review a case.
When the native application is used, a protected derivative of its verified connection's technical identifier provides an additional signal. It identifies an application installation, not a hardware or operating system serial number. Reinstalling the application and deleting its data may change it. The signal helps staff investigate a possible account link but does not establish a person's identity or independently cause a restriction.
3. Operations and recipients
Processing may include collection, recording, organization, accumulation, storage, correction, retrieval, use, transfer to authorized recipients, blocking, deletion, and destruction, with or without automated means. Data comes from the user, the identity service used at sign-in, authorized members of their organization, technical events generated by use, and sources involved in agreed tasks.
Categories and details of required recipients and contracted processors, and grounds for transfers: The inso identity service provides Akmelo with the sign-in identifier, name, email address, and avatar for access and profile display. Authorized personnel maintaining infrastructure and storage in Russia receive only the technical access necessary for their work. The email service processes the recipient address and message content. For an agreed payment, a bank or payment provider processes the necessary payment details, and the Russian Federal Tax Service receives the information required for a professional income tax receipt. When AI features are invoked, AIHubMix and Mistral AI may process the request and selected context needed for an answer; free-form text, code, and attachments may contain personal data, so complete anonymization is not guaranteed. Transfers outside Russia occur only after checking the lawful basis and mandatory procedures. Data is disclosed to public authorities where required by law.. Data is provided to public authorities where legally required and only to the extent needed. Naming contractors does not constitute consent to disclose data to an indefinite group of people.
For mandatory security checks, source code is analysed by the Service's own tools. Additional intelligent assessment uses only prepared technical risk categories and aggregate indicators. Source code, literal strings from it, source addresses, collected content, user profiles, sign-in, browser and application identifiers, account links, and appeal materials are not sent for that assessment. This limitation concerns the security check only.
When a user invokes the automated assistant or an AI method in a script, the text of the request, selected context, code, HTML, or user-supplied data needed for the answer may be sent to an external provider. Akmelo does not include payment details or internal account identifiers as a required part of that request protocol. Free-form text, code, and attachments may nevertheless contain information about people. Such content cannot be treated as guaranteed anonymous merely because the user's name is not sent in a separate field. Do not put personal data or secrets in a request. If they are needed for a particular task, first check the lawful basis and an available safe processing method. Processing by an external provider, including a possible cross-border transfer, requires a separate factual and legal check before the relevant function is enabled.
Territory of Akmelo's primary storage: Russian Federation. This description of storage in the Service does not mean that an external recipient never processes data in another country. Cross-border transfers take place only after meeting applicable requirements concerning legal basis, notices, and restrictions; this policy does not replace those procedures. Localization requirements apply regardless of whether consent has been obtained.
4. Retention and security
The public assistant stores original visitor messages, replies, and conversation titles in encrypted form within the Service so that a conversation can be resumed. Registration is not required. Access to history in the same browser depends on a separate random identifier in a functional cookie. It does not establish the visitor's identity or link the history to an account or visits to other websites. On a shared device, someone using the same browser profile may be able to access the history.
Before the public conversation context is submitted to an external intelligent tool, automated filtering removes sensitive information that it recognises. This does not mean that all personal data has been removed, and it does not change the original conversation stored in the Service. The need to retain original messages and the conditions for transferring the prepared context are assessed separately.
Retention periods by category and the procedures for deletion, backups, and mandatory retention: Active account data, tasks, and results are retained while needed to provide the service. After a verified request to cease processing, data with no other lawful retention ground is erased within the applicable mandatory period, generally no later than 30 calendar days; a shorter legal deadline prevails. Backups containing such data must be cleared within the same period or isolated until safe erasure without resuming active processing. Technical signals linking accounts are retained for no more than 180 days after last observation; closed review materials for no more than 365 days after closure unless a specific lawful ground requires longer retention. Payment and tax records are kept for mandatory accounting periods, and any such exception is explained when a request is reviewed.. Once the purpose has been achieved, data is deleted or destroyed unless another lawful ground for retention remains. Closing an account does not remove mandatory accounting periods or the need to preserve evidence for a dispute.
Technical signals linking accounts, verified sign-in information, a browser, and the native application are retained for no more than 180 days after that signal was last observed. A new sign-in, verified connection, or request that provides the signal again restarts this period. The log of verified native application connections is also limited to 180 days after the last observation. An account link confirmed by staff is effective and retained for no more than 180 days after its creation or most recent staff review. An automated signal match does not itself create a confirmed account link.
The ordinary security review cache, including a protected snapshot of the reviewed code and the analysis result, is retained for up to 30 days after the check. Where a check is linked to a violation case or appeal under consideration, necessary evidence is retained until review ends and for no more than 365 days after the case closes. Closed case records, including decisions, are subject to the same period. Where a specific dispute or statutory requirement continues, further retention is limited to that ground and the necessary scope. Excess material is removed earlier. This information is not used for advertising profiles.
The Service separates access by user and workspace, verifies authority when protected features are used, and logs security and administrative events. Access is granted within assigned permissions. The Controller must maintain proportionate organizational and technical safeguards and respond to incidents. Absolute security is not guaranteed; statutory duties to notify and remedy a breach remain in force.
5. Rights and enquiries
Removing a public assistant conversation from visible history hides it from the visitor and prevents it from being continued, but does not destroy its records in the Service. Records may be retained only for a specific purpose and lawful basis within the stated retention periods. Hiding a conversation does not authorise indefinite retention or replace consideration of a request to cease processing or destroy personal data. The functional cookie's lifetime is not the conversation retention period. Clearing the cookie or allowing it to expire ends browser access to the previous history but does not itself destroy server records.
A data subject may request information about processing, correction, cessation of processing, blocking, or destruction where provided by law; withdraw consent; and challenge actions before a supervisory authority or court. Send a request to support@insoweb.ru with enough information to identify you and locate the data. Additional information is requested proportionately; response periods and grounds are determined by applicable law. Withdrawal of consent does not end processing carried out on another continuing lawful basis.
6. Task review and reconsidering decisions
Automated analysis assesses signs of prohibited activity in a cloud task. A detected signal holds the particular run but does not itself confirm a user violation. An authorised member of staff confirms violations and related account restrictions. A technical match with another account does not independently justify a decision about a person's identity or culpability.
The reason for a hold or restriction is provided in the application. You can object, report an incorrect account link, and obtain a staff response through Account status, or contact support@insoweb.ru about personal data processing. An objection to a decision affecting rights in connection with automated personal data processing is considered within 30 calendar days after receipt, and the result is sent within that period. Shorter mandatory response periods for other data subject requests remain applicable. An appeal does not limit recourse to a supervisory authority or court.