This is an English translation provided for convenience. In case of any discrepancy, the Russian version prevails.

Personal Data Processing Policy

This Policy sets out the procedure for processing personal data in the service “VARIA” (https://getvaria.ru) in accordance with Federal Law No. 152-FZ “On Personal Data”.

1. Operator

Self-employed individual (NPD) Maksim Yurievich Karlov, Tax ID (INN) 631552185647, phone +7 927 718-81-41, email maxikarlov@gmail.com.

2. What data is processed

2.1. Telegram identifier (ID), username and name from the Telegram profile — for authorization and tracking the balance.

2.2. Payment data (fact and amount of payment, order number) — for accounting. Card payment details are processed exclusively by the Robokassa payment service; they are not transferred to or stored by the Operator.

2.3. Uploaded media files (video, photos, music), including the user's image and voice in videos — for providing the service. Files for reposting are deleted within a few hours after processing; files uploaded for auto-edit videos are stored for 14 days after rendering (for edits and re-rendering), edited videos for 30 days; both may be viewed by service staff to improve auto-edit quality.

3. Purposes of processing

Provision of the service, user identification, accounting of payments and balance, support.

4. Legal grounds

Consent of the user (starting to use the service), performance of the contract (public offer), legal requirements.

5. Transfer to third parties

Data is not transferred to third parties, except for the payment service Robokassa (to process payment), the processing technology providers listed below, and cases provided for by law.

To provide the auto-edit service, the Operator entrusts processing to technology providers that use the data only to fulfill the request: the audio track of the uploaded video — to the speech recognition service ElevenLabs Inc. (USA), including via the fal.ai service (Features and Labels Inc., USA); individual video frames and the speech transcript — to analysis services (neural networks) fal.ai (USA), polza.ai and gen-api (Russia).

6. Storage, protection and cross-border transfer

Data is stored on servers located in the Russian Federation, with restricted access. Retention periods for media files are set out in clause 2.3.

Transfer of the audio track, individual video frames and speech text to providers in the USA constitutes cross-border is a transfer to a state that does not ensure adequate protection of the rights of personal data subjects. It is carried out on the basis of the user’s consent (Consent to the processing of personal data), only to the extent necessary to provide the service, and does not include the user ID or username.

7. User rights

The User may request information about the processing of their data, its correction or deletion, withdraw consent — by writing to the e-mail maxikarlov@gmail.com.