Privacy policy

1. General provisions

1.1. This policy describes how Individual Entrepreneur Ivan Vasilyevich Bormotkin, taxpayer number (INN) 673203821665, address: 72 Gagarina Ave., Smolensk, Smolensk Region, 214018, Russia (the “Operator”) processes personal data of users of the SkyEnergy AI service at https://skyenergyai.com (the “Service”), in accordance with Russian Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.

1.2. Questions about data processing, requests and withdrawal of consent — info@skyenergyai.com.

1.3. The policy is publicly available. The Operator does not request special categories of personal data (health, beliefs, etc.) or biometric data, and processing them is not a purpose of the Service (see clause 3.3).

2. What data, why and on what basis

• Account: e-mail address, name, password hash (the password itself is not stored), interface language. Purpose — sign-up, sign-in and providing the Service under the offer. Basis — the agreement (Article 6(1)(5) of Law 152-FZ) and consent.
• Content: question texts, answers, chat titles, attached files (Pro and Max plans). Purpose — answering questions and keeping chat history. Basis — the agreement and consent.
• Technical data: IP address, browser details (User-Agent), time of actions; log of sign-ins and account actions. Purpose — security, protection against hacking and abuse, enforcing the Service rules, handling requests. Basis — the Operator’s legitimate interest (Article 6(1)(7) of Law 152-FZ) and consent.
• Payments: amount, date and status of a payment, payment and card binding identifiers, masked card number. Only the payment service JSC TBank (T-Kassa) receives the full card number. Purpose — payment, auto-renewal, refunds, receipts. Basis — the agreement and the law (Law 54-FZ, the Russian Tax Code).
• Support requests: e-mail address and message text. Purpose — replying to the request. Basis — consent.
• Cookies and browser storage — only what the Service needs to work, see the Cookie policy.

3. How data is processed

3.1. Actions with data: collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer (provision, access), depersonalisation, blocking, deletion, destruction. Processing is automated.

3.2. Recording, systematisation, accumulation and storage of data of Russian citizens take place in databases located in the Russian Federation (Article 18(5) of Law 152-FZ): the Service servers and its database are located in Russia.

3.3. The Service is not intended to process special categories of personal data. Ask questions without identifying details (“a man aged 40…”): do not include full names, document numbers, your health details together with data that identify you, or other people’s data (clause 8.1 of the offer). The Operator uses question content only for answering, chat history, support and checking compliance with the rules (clause 3.5), and a chat can be deleted at any time.

3.4. The Operator makes no decisions with legal consequences for the user solely on the basis of automated processing. An automatic refusal to answer a particular question is not such a decision.

3.5. Only the Operator and persons authorised by it have access to user data, including correspondence and attachments — to answer requests, investigate failures and refunds, and check compliance with the rules (sections 8 and 10 of the offer). Such access is recorded in a log.

4. Who receives data

• OpenRouter, Inc. — the AI model gateway that passes a request to the provider of the selected model (providers are listed on the OpenRouter website). It receives the question text, previous messages of the chat and attached files; e-mail, name and IP address are not sent — a pseudonymous identifier is used instead. Requests are sent with a prohibition on using the data to train models.
• E-mail delivery service — service e-mails (confirmation code, password recovery, notifications): e-mail address, name and message text.
• JSC TBank (T-Kassa) — accepting payments, recurring payments and refunds; card details are entered on its page.
• Hosting providers and telecom operators — hosting the Service servers and transmitting data.
• Government authorities — only in cases provided for by law.

4.1. Cross-border transfer. AI models and some services used by the Operator run abroad, so the data from section 2, to the extent needed for an answer and for service e-mails, may be transferred to foreign states, including states that do not provide adequate protection of data subjects’ rights. The transfer is based on consent and complies with Article 12 of Law 152-FZ.

4.2. The Operator does not sell personal data and does not share it for advertising.

5. Retention periods

• Account, chats and files — while the account exists. A chat deleted by the user is deleted immediately.
• When the account is deleted, the e-mail, name, password and sign-in sessions are deleted immediately, and the e-mail address becomes free. Chats and files are kept separately, unlinked from the e-mail and name, for no more than 30 days — to handle disputes, complaints and violations — and are then destroyed automatically (Article 21(5) of Law 152-FZ).
• The consent record (text version, date, IP address) after account deletion — 3 years: proof that processing was lawful for the limitation period.
• If the account was blocked for a rules violation, after its deletion an irreversible fingerprint of the e-mail address is kept for no more than 5 years, to prevent signing up again to bypass the block.
• Log of sign-ins and actions — 12 months. After the account is deleted, log entries remain unlinked from the e-mail and name.
• Sign-in session — 30 days, extended while in use.
• Payment documents — at least 5 years (Article 29 of the Russian Federal Law “On Accounting”).

6. Your rights

6.1. You may obtain information about the processing of your data, demand that it be corrected, blocked or destroyed, withdraw consent, and appeal against the Operator’s actions to Roskomnadzor or in court.

6.2. Send requests to info@skyenergyai.com from the address of your account. The reply is given within 10 working days (Article 20 of Law 152-FZ).

6.3. You can delete your account yourself in the settings — immediately, confirmed with the password; what is kept after that and for how long — see section 5.

6.4. After consent is withdrawn, the Operator stops processing and destroys the data within 30 days (Article 21(5) of Law 152-FZ), except data it may or must keep by law (section 5).

7. Data protection

• the Operator takes legal, organisational and technical measures to protect data (Article 19 of Law 152-FZ), including:
• a secure connection to the site (HTTPS);
• storing passwords and one-time codes only as a hash;
• encryption and access control for data; a log of actions in accounts;
• in a data incident, the Operator acts under Article 21 of Law 152-FZ.

8. Changes to the policy

A new version is published on this page with its date. If changes require new consent, the Service will ask for it separately. The Russian version prevails in case of discrepancy.