1. General Provisions

This statement (the "Statement") describes what data users of the Lotima service (the "Service", lotima.ru) enter and how the Service works with it. The Service is owned by Individual Entrepreneur Andrey Aleksandrovich Kiselev, OGRNIP 319028000054109, INN 026403139827 ("Lotima").

The security of user data is a priority for the Service: Lotima deliberately collects the minimum possible amount of information and uses no third-party tracking tools.

2. Position on Personal Data Legislation

An email address and a form of address in the Service are sufficient for registration. Last name, patronymic, phone number, date of birth, address, and other information that would identify a specific individual from identity documents are not requested at registration.

Lotima proceeds from the position that the combination of data entered by users in the Service does not make it possible to identify a specific individual, and that Lotima therefore does not process personal data as an operator within the meaning of Federal Law No. 152-FZ "On Personal Data". The viability of this approach with respect to email addresses is supported by individual court decisions (e.g., case No. А40-139096/22).

3. What Data Is Entered in the Service

• email address: entered voluntarily at registration and used for signing in and service notifications (sign-in codes, fiscal receipts, payment notifications);
• form of address in the Service (how to address you): entered after registration to label the interface and name your first studio; this is not a legal full name;
• Telegram identifier: only if you yourself link the bot to the account, so messages arrive in the right chat;
• phone number: only if you join the partner programme and provide it for payouts; it is not requested at ordinary registration;
• technical logs of the Service (access records, device and browser information): used to keep the Service operational and secure, and not used to establish users' identity;
• cookies: first-party only; their composition and management are described in the separate Cookie Policy.

Lotima does not receive or store bank card details: payments, including recurring subscription charges, are processed by the YooKassa payment service independently, within its own secured environment.

Third-party web analytics, advertising pixels, and other tracking tools are not used in the Service; the Service's product analytics is first-party and is not shared with third parties.

4. User Materials

Video, audio, and other files are uploaded by the user solely for their automated processing in the user's own interest. Processing includes: speech recognition, reading text on frames, detecting faces and the speaker's position in the frame for cropping (without identifying the person and without biometric templates), assembling the reel, and captions. Lotima performs only technical operations on the Materials, on the user's instruction and to the extent necessary to provide the service. Lotima does not curate the content of the Materials and does not use them for its own purposes.

Some operations are performed by technical subcontractors, including on servers outside the Russian Federation. Subcontractors receive the audio track and its transcript, selected frames, and the chat request text. These are speech-recognition, language-model, and image-recognition providers. They are engaged on terms that exclude training models on the data passed to them.

The Materials, their transcripts, and the reels produced from them are not used to train models: neither Lotima's own models nor those of its technical subcontractors. Lotima staff do not view the Materials or chat contents; the only exception is a review of a specific session that the user has requested and explicitly consented to in the feedback form. To improve the Service, Lotima uses only technical indicators of its operation (operation statuses and durations, error codes), never the content of the Materials. Any other use of the Materials is possible only with the user's separate explicit consent, which may be withdrawn at any time.

The user independently determines the content of the uploaded Materials and is responsible for the lawfulness of their processing, including obtaining the necessary consents of persons whose images, voice, or other information the Materials contain (Section 9 of the public offer).

5. Security

Lotima applies technical and organisational data protection measures: encryption in transit, encrypted storage, access segregation, and database-level isolation of different users' data. Account data and Materials are stored on servers located in the Russian Federation.

6. Voluntary Provision, Retention, and Deletion

All data is entered by users strictly voluntarily.

Uploaded video and everything derived from it (transcript, recognised on-frame text, working files) is kept for 180 days from last use in a chat or reel. Each view restarts the countdown. Two weeks before deletion Lotima writes to email and to in-Service notifications. You can delete video sooner in the Library: the video menu has a "Delete video" action, and the card shows how long it will be kept.

A finished reel is kept until you delete it. Variants you did not choose, and export files no longer tied to any live reel, are kept for up to 365 days. Chat preview drafts are kept for one day.

Lotima deletes the account and the data associated with it on a request to care@lotima.ru, except for records whose retention is required by law (in particular, payment records).

7. Changes to This Statement

Lotima may update this Statement. The current version, its number, and its effective date are shown on the document page; users are notified of material changes by email or in the Service.

8. Details and Contacts

Individual Entrepreneur Andrey Aleksandrovich Kiselev. OGRNIP: 319028000054109. INN: 026403139827.

For data-related questions, contact care@lotima.ru.