NOXARGENT CLUB Personal Data Processing Policy
Translation for convenience; prepared under Russian Federal Law No. 152-FZ "On Personal Data". The Russian version prevails. Buyers in other jurisdictions (e.g. the EU) may have additional rights under local law; this policy does not claim automatic compliance with all foreign laws.
1. Controller
Лекторович Евгений Павлович, Самозанятый, INN 731103735984, address: [NOT SET: SELLER_ADDRESS], e-mail: williamlester484@gmail.com.
2. Data processed
- Telegram ID; username and name (if any) — to identify the buyer and manage access;
- plan, orders, subscription terms — to perform the contract;
- payment history: order number, amount, currency, payment system transaction ID, status, dates;
- acceptance records: document versions, time (UTC), method, order number;
- e-mail (only for external-channel payments when a receipt is required);
- support requests and claims;
- technical security logs.
Card data is never collected or stored. No special categories or biometric data are processed.
3. Legal bases
Performance of a contract (Art. 6(1)(5) 152-FZ); legal obligations (Art. 6(1)(2)); legitimate interest in security (Art. 6(1)(7)); separate consent for promotional messages (can be withdrawn at any time without affecting access).
4. Retention
Orders, payments, acceptance records — for the contract term and 3 years after the last subscription ends, or longer if tax law requires. Claims — 3 years after resolution. Technical logs — up to 90 days.
5. Sharing
Data is not sold. It is shared only with payment services (to process payments/refunds), the hosting provider (under a processing agreement), and authorities where required by law. The database is hosted in the Russian Federation. Telegram processes user data under its own privacy policy.
6. Security
Restricted DB access, secrets stored outside code, HTTPS, no logging of payment tokens, secrets or personal links, backups, admin access by Telegram ID only, admin action log.
7. Your rights
Access, rectification, blocking or deletion of unlawfully processed or inaccurate data, withdrawal of consent, complaint to Roskomnadzor or a court. Requests: williamlester484@gmail.com or "Support" in the bot, with your Telegram ID; answered within 10 business days.