Personal Data Processing Policy

This is a translation. In case of discrepancies, the Russian version prevails.

Version 1.0 of October 25, 2026

1. Who processes your data

1.1. Personal data operator: Alisa Pavlovna Arseneva, self-employed (professional income tax payer), Taxpayer ID (INN) 504724549300 (the "Operator", "we").

1.2. This Policy applies to the Telegram bot @lbchinese_ai_bot and the LinguaBridge "Chína" mini app inside Telegram (together, the "Service").

1.3. How to contact the Operator about personal data:

• Telegram @LingBridg;
• the /feedback command in the bot.

1.4. This Policy has been prepared in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data". The Policy is publicly available, and you can find a link to it in the bot (/privacy) and in the mini app (Profile → Documents).

2. What data we process

2.1. Data from Telegram:

• Telegram ID;
• first and last name as shown in Telegram;
• username;
• Telegram interface language.

We do not receive or ask for your phone number.

2.2. Learning data:

• HSK level;
• completed lessons and tests;
• answers in exercises and mistakes;
• words in review;
• exam results;
• day streak and rewards;
• leaderboard points and pack (team);
• settings: reminder time, pinyin mode, language.

2.3. Data you send us yourself:

• messages and voice messages to Chína and the teacher;
• essays and written answers;
• photos and texts for the scanner;
• reviews and messages to support.

Please do not send the Service information about your health, political or religious views, identity documents or other sensitive data. The Service does not need it.

2.4. Payment data:

• subscription type, term and status;
• amount;
• Telegram Stars and Tribute payment IDs.

We do not receive your bank card details: payments are processed by Telegram and the Tribute payment service.

2.5. Technical data:

• date and time of requests;
• service logs about how the Service works;
• data the mini app stores in your device's memory (localStorage): your place in a lesson, settings, an unfinished exam.

3. Why we process data

• To give you access to the Service: lessons, review, exams, chatting with Chína, the scanner, leaderboards.
• To save your progress and pick exercises that match your level and mistakes.
• To check answers, essays and voice messages using artificial intelligence.
• To set up and renew your "Chína Premium" subscription, answer payment questions and make refunds.
• To send study reminders and service messages, for example, about your subscription ending.
• To send informational and promotional messages — only if you have given separate consent to receive them.
• To show the weekly and pack leaderboards: your name (first word only), HSK level and points.
• To show learner reviews in the mini app: name (first word only), level and review text.
• To improve the Service, fix bugs and comply with the law.

4. Legal grounds

We process data on the following grounds:

• performance of the user agreement and public offer to which you are a party (clause 5, part 1, article 6 of Law 152-FZ);
• your consent to the processing of personal data, given as a separate document (clause 1, part 1, article 6 and article 9 of Law 152-FZ);
• separate consent to receive promotional messages (article 18 of the Federal Law "On Advertising");
• compliance with obligations imposed by law (for example, tax obligations).

5. How we process data

5.1. Actions performed with data: collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer (provision, access), anonymization, blocking, deletion, destruction. Processing is carried out using automated means.

5.2. Where data is stored: [server country and city].

5.3. We do not sell personal data and do not use it to train third-party artificial intelligence models.

6. Who we share data with

Data is shared only to the extent needed for the Service to work.

Data may be provided to government authorities where required by law.

7. How long we keep data

7.1. We keep your data for as long as you use the Service. If you have not used the Service for 3 years, we delete your data.

7.2. Your data is deleted:

• at your request (the /deleteme command);
• if you withdraw your consent;
• if the Service shuts down.

7.3. Payment data is kept for as long as tax law requires.

7.4. Voice messages are not stored after recognition. Scanner photos are not stored — only the recognized text and its breakdown are saved, so you can come back to it in "My breakdowns".

8. Your rights

You can:

• find out what data of yours we process and get a copy of it;
• ask us to correct, block or delete your data;
• withdraw your consent to personal data processing and your consent to promotional messages;
• opt out of reminders (/reminders) and promotional messages;
• delete your data with the /deleteme command in the bot;
• file a complaint about the Operator's actions with Roskomnadzor (the Russian data protection authority) or in court.

You can send a request via Telegram @LingBridg or /feedback in the bot. We reply within 10 business days.

9. Data protection

Only the Operator has access to the database. The server is protected by a password and an encrypted connection (HTTPS). Requests from the mini app to the server are verified using Telegram's signature. In the event of a data breach, we will notify users and Roskomnadzor (the Russian data protection authority) within the time limits set by law.

10. Children

The Service is intended for users aged 14 and over. If a learner is under 14, consent to data processing must be given by their parent or legal guardian.

11. Changes to this Policy

We may update this Policy. A new version takes effect when it is published. We will let you know about significant changes in the bot or in the mini app and ask you to confirm your consent again if the law requires it.