Privacy Policy

1.1. The data controller (the person who decides how personal data is processed) is Aleksey Evgenyevich Chekunin, a self-employed individual (NPD) in the Russian Federation, TIN 774332566739 (the “Operator”).

1.2. Contact: alexey.chekunin@gmail.com · Telegram: @alexey_chekunin. We do not have a separate data-protection officer or an EU/UK representative.

1.3. This Policy applies to the KidMind Site (kidmind.xyz / kidmind.ru and related services), including the waitlist, accounts, lessons, conversations and payments.

1.4. Using the Site means you have read this Policy. Paid use is also subject to the Subscription Terms; other use is subject to the Terms of Use.

2.1. Depending on how you use KidMind, we may process:

• account data: email address, Telegram account identifier and, if you send it via Telegram, display name and avatar;
• authentication data: session cookies and a refresh token needed to keep you signed in;
• waitlist data: email address, the plan you are interested in, and survey answers (including an age range for the child you are signing up for, and a short description of the situation);
• usage data: progress through levels, energy and similar game-state, timestamps, and technical logs;
• messages typed in conversations with Anna, Robbie or similar characters — these may include things a child writes while using your account;
• payment metadata: the fact of a payment, amount, currency, period and provider identifiers. We do not store full card numbers; the payment provider processes those;
• support messages you send by email, Telegram or the on-site chat widget;
• cookies and similar technical data, including approximate device and browser information.

2.2. We do not require a child’s legal name, school, address, photo or date of birth to create an account. A parent may still type personal details into a conversation or a survey. Please do not send documents, health records or other sensitive data unless we ask for them in writing.

2.3. We do not show third-party advertising on the Site, and we do not sell personal data.

3.1. KidMind is built for children ages 5–10, but the account and the contract are with the parent or guardian. We ask you not to let a child create their own account.

3.2. We do not use children’s data for marketing to children, for profiling aimed at children, or for sale to advertisers.

3.3. If you are in the United States, we intend KidMind to be used by parents. We do not knowingly collect personal information from a child under 13 for the child’s own account. If you think we have, contact alexey.chekunin@gmail.com and we will delete it.

3.4. You are responsible for supervising your child’s use and for what is typed in conversations.

4.1. We process data to:

• create and run your account, provide lessons and conversations, and keep progress — this is needed to perform the contract with you;
• take payment and keep records we are required to keep for tax and accounting;
• run the waitlist and tell you when access opens, if you asked us to;
• answer support requests;
• keep the Site secure and prevent abuse;
• understand how the landing pages are used (see section 7);
• comply with law, including Russian personal-data and bookkeeping rules.

4.2. Where a privacy law such as the EU/UK GDPR applies to you, the typical legal bases are: contract (account and paid access); legitimate interests (security, basic product improvement, defending legal claims); consent (non-essential cookies/analytics, waitlist messages beyond what is needed to deliver the request); and legal obligation (tax records). You may withdraw consent without affecting processing that does not rely on consent.

4.3. For users in the Russian Federation, processing is carried out under Federal Law No. 152-FZ “On Personal Data”, including on the basis of your agreement to this Policy and the need to perform a contract.

5.1. We share data only as needed to run KidMind, and with:

• payment providers (currently YooKassa for ruble payments; other providers if named at checkout) — to take and refund payments;
• Telegram — if you sign in or write to us that way;
• hosting and infrastructure providers, including Cloudflare, which delivers the Site;
• the language-model provider used to generate in-lesson conversations — messages in those conversations are sent to that provider in order to produce a reply;
• the on-site support widget (Chatwoot), if you open it;
• Yandex Metrica, for the analytics described in section 7;
• authorities, if we are legally required to disclose data.

5.2. We do not sell your data and we do not share it with advertisers. A provider acts on our instructions or as its own controller under its own policy (for example, Telegram or a card scheme).

6.1. We use cookies and similar storage that are required to sign you in (including a refresh token) and to keep the Site working. These are necessary for the service you asked for.

6.2. We also use analytics cookies as described in section 7. You can block cookies in your browser; if you block necessary cookies, sign-in and some features will not work.

7.1. On the production Site we use Yandex Metrica (counter 103383687). It records visits, clicks and, in its current configuration, session replay (Webvisor). That means a recording of how a page was used may be stored by Yandex. This is marketing analytics for the Operator, not advertising to children inside the lessons.

7.2. We may also send anonymised or pseudonymised events to a browser data layer for the same purpose.

7.3. If you open the support chat, Chatwoot processes the conversation in order to deliver it to us.

7.4. If you want analytics cookies limited, use your browser settings or write to alexey.chekunin@gmail.com. We will not pretend a third-party analytics tool is off if it is still loading.

8.1. The Operator is in the Russian Federation. Personal data is processed in the Russian Federation and in other countries where our providers operate (including Cloudflare’s network and the countries of the payment, messaging and analytics providers above).

8.2. The Russian Federation does not currently benefit from an EU adequacy decision. If you are in the EEA, the UK or Switzerland, this is an international transfer. We transfer data because the Operator and the service are based there, and because you chose to use the Site. We do not claim that EU Standard Contractual Clauses are in place with every provider.

8.3. If you are not comfortable with that transfer, do not create an account and do not submit the waitlist form.

9.1. Account and progress data are kept while the account exists. If you ask us to delete the account, we delete or irreversibly anonymise personal data within 30 calendar days, except records we must keep by law (for example, payment and tax records, which may be kept for the statutory period — typically several years).

9.2. Waitlist emails are kept until we have written to you about launch, you ask to be removed, or we close the list.

9.3. Support correspondence is kept as long as needed to handle the request and any related dispute.

10.1. We take technical and organisational measures we consider appropriate for a small educational service (access control, encrypted transport, limited staff access). No method of transmission or storage is fully secure. We do not claim certification (ISO, SOC or similar).

10.2. We are not responsible for a breach at a provider we do not control (payment systems, Telegram, hosting, analytics), except where mandatory law says otherwise.

11.1. You may ask us to:

• tell you whether we process your data and provide a copy;
• correct inaccurate data;
• delete data or close the account;
• restrict or object to certain processing, where the applicable law gives you that right;
• withdraw consent, where processing is based on consent;
• receive data in a portable form, where the applicable law gives you that right.

11.2. Write to alexey.chekunin@gmail.com from the address on the account. We may need to verify that it is you. We will respond within 30 days, or sooner if the law requires.

11.3. If you are in the EEA or the UK, you may also complain to your local data-protection authority. If you are in the Russian Federation, you may complain to Roskomnadzor.

12.1. We may update this Policy by publishing a new version on the Site. The new version applies from the “Last updated” date unless a later date is stated.

Operator: Aleksey Evgenyevich Chekunin

Status: self-employed individual (NPD), Russian Federation

TIN (INN): 774332566739

Email: alexey.chekunin@gmail.com

Telegram: @alexey_chekunin