PRIVACY POLICY

of the “GIDIO” digital service · Version dated 14.06.2026

This Privacy Policy (hereinafter — the “Policy”) defines the procedure for the processing and protection of the personal data of users of the “GIDIO” digital service, available on the following platforms: Telegram Mini App, Mini App in the Max (VK) messenger, the “GIDIO” mobile application (hereinafter jointly — the “Service”), owned by Individual Entrepreneur Mesropyan David Davidovich (hereinafter — the “Operator”).

The Policy has been developed in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and other applicable regulatory acts of the Russian Federation.

1. Personal data operator

Name: Individual Entrepreneur Mesropyan David Davidovich

INN (Taxpayer Identification Number): 540133672385

OGRNIP (Primary State Registration Number of an Individual Entrepreneur): 324547600037031

Registered: 04.03.2024, Interdistrict Inspectorate of the Federal Tax Service of Russia No. 16 for the Novosibirsk Region

E-mail for personal data requests: gidiotravel@yandex.ru

Website: gidio.ru

Platforms of the Service: Telegram Mini App, Mini App in the Max (VK) messenger, the “GIDIO” mobile application

2. What data we collect and on what grounds

2.1. Data processed by virtue of the performance of the contract:

• the identifier of the user's account in Telegram or Max (User ID) — for identification in the Service;
• the user's name in Telegram / Max (username / first name) — for personalization;
• account data in the “GIDIO” mobile application (the e-mail address or telephone number used upon registration) — for identification and access to the Service;
• the history of use of the Service: completed routes and scenarios, marks of visited places, saved impressions and comments — for ensuring the functionality of the Service;
• technical information on payments: payment status, amount, date, transaction identifier, masked card number — for keeping records of the Subscription, granting access, refunds and the resolution of disputed situations.

2.2. Data processed on the basis of the user's consent:

• an e-mail address or other contact — for marketing and informational mailings;
• analytics data on the use of the Service — for improving the product.

2.3. The Operator does not process full bank card details — they are processed by the payment provider. The Operator does not collect special categories of personal data.

3. Purposes of the processing of personal data

• granting access to the Service on all platforms and ensuring its functionality;
• keeping records of the Subscription, processing payments and refunds;
• sending service notifications: upcoming charges, changes to the terms, the status of the Subscription, technical maintenance;
• synchronization of the user's data between platforms (Telegram, Max, the mobile application);
• improving the quality of the Service and developing new functions;
• sending marketing and informational materials where separate consent has been given;
• compliance with the requirements of the legislation of the Russian Federation.

4. Data retention periods

Account data: until deletion of the account + 3 years.

History of use of the Service: until deletion of the account + 1 year.

Payment information (transactions): 5 years.

Marketing consents: until withdrawal of consent + 3 years.

5. Transfer of data to third parties

The Operator does not sell or transfer personal data to third parties for commercial purposes. Data may be transferred:

• to the payment provider — for the processing of payments;
• to the Telegram and VK (Max) platforms — to the extent necessary for the functioning of the Mini App on the relevant platform, in accordance with the privacy policies of Telegram and VK;
• at the request of authorized state authorities in accordance with the legislation of the Russian Federation;
• in depersonalized form — to providers of analytics tools where the user's consent has been given.

6. Rights of the user

The user has the right to obtain information about the processing of their data; to demand the clarification, blocking or destruction of the data; to withdraw consent to the processing; to appeal against the actions of the Operator to Roskomnadzor or in court.

In order to exercise these rights, the user shall send a request to gidiotravel@yandex.ru. The period for consideration is 10 working days.

Withdrawal of consent to the processing of the data necessary for the performance of the Contract may entail the termination of access to the Service. Refunds are made in accordance with the rules of the Public Offer.

7. Data protection

The Operator takes organizational and technical measures to protect data: restriction of access at the level of systems and employees; transmission via secure channels (HTTPS/TLS); regular monitoring of the security of the infrastructure.

8. Platforms and third-party services

The Service operates on several platforms, each of which has its own privacy policy:

• Telegram: telegram.org/privacy
• Max (VK): vk.com/privacy
• The “GIDIO” mobile application: gidio.ru/privacy

The Operator does not control the data collected directly by the platforms.

9. Amendment of the Policy

The Operator has the right to make amendments to this Policy. The current version is available at gidio.ru/privacy. In the event of material changes, the Operator shall notify users through the interface of the Service.

10. Contacts

E-mail: gidiotravel@yandex.ru

Person responsible for the processing of personal data: Individual Entrepreneur Mesropyan David Davidovich

Website: gidio.ru