Privacy Policy

About this translation

This is an English translation provided for convenience. The legally binding original is the Russian version at zalet.pro/privacy; in case of any discrepancy the Russian text prevails.

Operator

Personal data operator: Nedigital 3.0 LLC.

Website: zalet.pro. Email for personal data requests: a@nedigital.ru.

Operator details

• →INN 5041215406
• →KPP 504101001
• →OGRN 1235000140847
• →Registered address: 7 Pobedy street, Reutov, Moscow region, 143960, Russia
• →CEO: Anton Konovalov

What data we collect

• →name
• →email
• →Telegram or another messenger, if you provided it yourself
• →the type of business or activity stated in the request
• →the content of your message or request
• →technical data: cookies, IP address, User-Agent, website analytics data

Purposes of processing

• →handling the request for early access to the Zalet platform
• →communication with the user
• →informing about the launch and the capabilities of the platform
• →website analytics
• →improving the service and the quality of communication

Legal grounds

Personal data is processed on the basis of the user's consent and in accordance with Russian Federal Law No. 152-FZ on personal data.

Retention period

Personal data is stored until the purposes of processing are achieved or until the user withdraws consent, unless a different period is required by law.

Transfer to third parties

The operator may transfer data only to the extent needed to handle the request, run the website and communicate with the user.

• →hosting provider
• →analytics services
• →communication and email services
• →contractors, if they are needed to handle the request

TikTok integration

Zalet lets the user optionally connect their own TikTok account in order to publish their own videos through the official TikTok Content Posting API. The connection is made through TikTok authorization (OAuth) and only on the user's initiative.

When an account is connected we receive and store the minimum necessary data: access tokens (access token and refresh token), the public account identifier (open_id), and the display name and avatar of the author to show them in the account.

• →TikTok data is used solely to publish content uploaded by the user themselves, to their own TikTok account
• →we do not sell TikTok data and do not pass it to third parties
• →we do not use TikTok data for advertising, profiling or model training
• →storage and processing follow the TikTok Developer Terms of Service and the TikTok Community Guidelines
• →the user can disconnect the TikTok account at any moment in the account; the stored access tokens are then deleted

Children's photos and the legal guardian's consent (Zalet Kids)

To create a personal cartoon in Zalet Kids, the parent or another legal guardian uploads a photo of the child. The following data is processed: the child's photo, the child's name (for the plot and the narration) and the child's age, if provided.

By uploading the photo you confirm that you are the child's legal guardian (parent, adoptive parent or custodian - article 64 of the Family Code of Russia) and you give consent to process the child's personal data on their behalf.

• →the photo is used only to generate the cartoon character and the cartoon; we do not use photos to identify a person - the photos are not biometric personal data in the sense of article 11 of Law No. 152-FZ
• →primary collection and storage happen on servers located in Russia; you can delete the photo and the hero in your account at any moment
• →for generation the image is passed to a neural network processing provider; only the image is passed, without the name or contact details (cross-border transfer - article 12 of Law No. 152-FZ)
• →we do not use children's photos for model training, advertising or any other purpose
• →the finished cartoon is available only in your account; showing it in the public examples gallery is possible only with your separate voluntary consent, which can be withdrawn at any moment (see the consent to show the tale in the examples)
• →after a withdrawal we stop the processing and destroy the photo and the related data of the child within no more than 30 days (part 5 of article 21 of Law No. 152-FZ)

Consent to show the tale in the examples (gallery)

Showing a finished tale in the public examples gallery on zalet.pro/kids happens only with a separate voluntary consent of the legal guardian to the distribution of personal data (article 10.1 of Law No. 152-FZ, article 152.1 of the Civil Code of Russia). Full text of the consent: zalet.pro/en/kids/consent-gallery.

The consent is not a condition of service: everything works without it. A bonus of 300 tokens is credited for the consent; withdrawing the consent does not cancel the bonus.

The consent can be withdrawn with the "Remove from gallery" button in the account or by an email to a@nedigital.ru - the video is removed from the gallery within 3 business days (part 14 of article 10.1 of Law No. 152-FZ). Every grant and withdrawal is recorded in the consent log (date, time, text version, IP address).

User rights

• →request a correction of personal data
• →request blocking of personal data
• →request deletion of personal data
• →withdraw the consent to the processing of personal data

How to withdraw consent

To withdraw consent or send a personal data request, write to a@nedigital.ru.

Cookies and analytics

The website may use cookies and analytics tools to understand traffic, the quality of traffic sources and to improve the pages of the site.

The user can limit the use of cookies in the browser settings. Some features of the site may then work differently.

Security measures

The operator takes organizational and technical measures to protect personal data from unlawful access, alteration, disclosure or destruction.

Operator contacts

• →Nedigital 3.0 LLC
• →Email: a@nedigital.ru
• →Website: zalet.pro