Personal Data Processing Policy

Last updated 23.10.2026

1. Operator and scope

The operator is Sergey Misakovich Durgalyan, a payer of professional income tax, taxpayer identification number (INN) 232018676341, based in Sochi, Russian Federation. This policy applies to LifeProgress at lifeprogress.create-products.com and its Telegram bot. Processing is governed by Federal Law No. 152-FZ “On Personal Data” and applicable regulations of the Russian Federation. Reading this policy does not itself constitute consent.

2. Purposes, data and legal bases

  • Account and login: name, email address, password hash and email verification status; when Telegram is chosen, identifier, name and username. The bases are separate consent and provision of the requested service.
  • Development profile: the life areas, skills, levels, goals, plans, completion records and settings you enter. These are used to store and display your profile.
  • AI features: messages, assistant suggestions, profile context and generated portraits. Permission to transfer data to AI services is included in the separate consent given during registration under the version dated 23 October 2026; for earlier accounts, permission is given in settings.
  • Service communications: email for address verification, access recovery and replies to requests. Data are not sold and advertising emails are not sent.
  • Security: IP address, request time, browser details, cookies and token hashes, as well as the date, version and method of obtaining consent. The bases are protection of the service, compliance with the operator’s obligations and legitimate interests while respecting users’ rights.

Do not enter diagnoses, medical documents, information about intimate life or other special categories of data: the service is not intended to process them. Portraits are not used to establish identity or perform biometric identification.

3. Processing methods and storage

The service’s main data are stored on servers in the Russian Federation. When collecting data about Russian citizens, databases located in the Russian Federation are used. Automated processing includes collection, recording, organization, accumulation, storage, updating, retrieval, use, disclosure at your choice, blocking, deletion and destruction.

Access is limited to service maintenance needs. Passwords are stored as strong hashes; the live service uses HTTPS, access controls, session protection and backups.

4. External services and data transfers

Hosting and email infrastructure support the service and service emails. Processors receive only the access they need under the conditions required by law and contracts. Telegram processes data for the login method you choose under its own rules. When external fonts are loaded, your browser contacts Google Fonts and sends technical request information.

The assistant uses OpenRouter (USA) and selected model providers. Messages and the necessary profile context are sent to them only after your separate consent: during registration under the current version or when enabling AI in settings. You can withdraw it in settings: new requests stop and the rest of the application continues to work. Recipients may process data under different conditions; withdrawal does not reverse processing already carried out. At your choice, a face photo may be sent for portrait drawing after separate permission on the generation screen. LifeProgress does not retain the original photo or use it for identification; only the generated result is stored in the gallery.

The operator must comply with Article 12 of Federal Law No. 152-FZ for cross-border transfers, including required notifications and restrictions. User permission does not replace these obligations. Other transfers may take place on grounds established by law, including lawful requests from competent authorities.

Your profile is accessible only to you by default. When “Share” is enabled, selected information becomes available to holders of the link. Access can be revoked; copies previously obtained by others do not disappear automatically.

5. Retention and deletion

Profile data are retained for the lifetime of the account. When the account is deleted, all associated information is immediately removed from the live database and portrait files are also deleted. Information is removed from backups within 14 days. Server logs containing technical information are retained for up to 30 days. If the law requires certain information to be retained, only the necessary information is stored for the prescribed period.

After withdrawal, processing based solely on consent stops; destruction takes place within the periods required by law, generally no later than 30 days unless other grounds apply. Correction, blocking and deletion of unlawfully obtained or unnecessary data are carried out within the periods specified in Articles 20–21 of Federal Law No. 152-FZ.

6. Cookie

lp_session keeps you signed in for up to 30 days, renewed with use; lp_tg links your browser to a Telegram login request and lasts up to 5 minutes. Appearance settings are stored in your browser and profile. Advertising and analytics cookies are not used. You can delete or block cookies in your browser, but login may stop working.

7. Rights and requests

You have the right to learn about processing, obtain a copy, request correction, blocking or destruction of data, withdraw consent, and complain to Roskomnadzor or a court. For a copy: “Settings” → “Export data”; for deletion: “Settings” → “Delete account”. Permission for AI is withdrawn separately in settings.

Send your request to mail@create-products.com. Identify your account and describe your request. Do not send passwords or login codes. If necessary, the operator will ask you to verify ownership of the account.

Information about processing is provided free of charge within 10 working days; an extension of no more than 5 working days is possible with a reasoned notice. Other requests are handled within the periods specified by applicable law.

8. Changes

The current version is published here with its revision date. New purposes or operations requiring consent are not authorized merely by continued use: consent is requested separately.

Contact details

Sergey Misakovich Durgalyan. Requests: mail@create-products.com, based in Sochi, Russian Federation.