This is a technical draft of Lotima's personal data processing policy, a placeholder and not a legally binding document. The structure mirrors the requirements of Russian Federal Law No. 152-FZ, but the text has not been reviewed by a qualified lawyer and, until that review is complete, must not be relied on as a source of rights or obligations.

1. General Provisions

This policy (the "Policy") sets out how the operator of Lotima (the "Service") processes the personal data of Service users, in accordance with Federal Law No. 152-FZ "On Personal Data" of 27 July 2006. The Policy applies to every user who registers an account with the Service.

The data controller is PLACEHOLDER: legal entity name, registration number, and registered address (pending the incorporation decision, tracked as Q-CT.B).

2. Personal Data We Process

Lotima processes the following categories of data: registration data (email address and phone number, if provided at signup or account recovery); account data (user identifier, studio settings, and activity history within the dashboard); usage data (technical logs, device and browser information, and feature-usage statistics); uploaded material (the video, audio, and text files a user submits for editing); billing data (the selected plan and payment history). Lotima does not store card details; these are processed directly by the payment partner.

3. Purposes of Processing

We process data to: provide access to the Service's functionality; perform obligations under the accepted public offer; identify and authenticate users; support users and handle inquiries; improve the Service and develop new features; prevent fraud and abuse; and meet legal requirements.

4. Legal Basis for Processing

Processing is carried out on the basis of user consent, for the performance of the contract (the accepted offer) to which the user is a party, and to meet obligations imposed on the controller by law.

5. Manner and Conditions of Processing

Data is processed using automated means and otherwise: collection, recording, systemisation, accumulation, storage, clarification, retrieval, use, disclosure, depersonalisation, blocking, deletion, and destruction.

6. Disclosure to Third Parties

Data may be shared with: payment processors, for billing; infrastructure providers, for video storage and processing; email and SMS delivery providers, for service notifications; and other parties engaged to fulfil obligations to the user. Disclosure is made under agreements that require confidentiality and safeguards consistent with 152-FZ.

7. Cross-Border Data Transfers

PLACEHOLDER: the countries data may be transferred to, and the legal basis for such transfers (Art. 12, 152-FZ), are pending confirmation of the final infrastructure-provider set and legal review.

8. Data Retention

Data is retained for as long as necessary to achieve the purposes described in Section 3, and for any period required by law for accounting or other records. When an account is deleted, data is deleted or depersonalised within a reasonable time, except where retention is legally required. PLACEHOLDER: exact retention periods by data category are pending legal review.

9. Security Measures

Lotima applies organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, or distribution, including encryption in transit, access controls for staff, and logging of access to processing systems.

10. Your Rights

You may: obtain information about the processing of your data; request correction, blocking, or deletion of data that is incomplete, outdated, or unlawfully processed; withdraw consent to processing as provided by law; and lodge a complaint with the competent data-protection authority (Roskomnadzor) or a court.

11. Children

The Service is not directed at individuals under 18. Lotima does not knowingly collect personal data from minors; any such data discovered is deleted.

12. Cookies

The Service uses cookies and similar technologies. See our separate Cookie Policy for details.

13. Changes to This Policy

Lotima may update this policy. The current version and its effective date appear at the top of this page; material changes are additionally communicated to users.

14. Contact

For questions about the processing of your personal data, contact care@lotima.ru. PLACEHOLDER: the data controller's full details (postal address, data-protection contact) are pending legal review.