Personal Data Processing Policy

COREXO service

1. General provisions

1.1. This Policy sets out the procedure for processing the personal data of users (the “Data Subjects”) by the COREXO service (Telegram Mini App and web interface).

1.2. The personal data operator is Individual Entrepreneur D.A. Shishnev (OGRNIP 326774600424037, INN 790600849762) (the “Operator”).

1.3. Reading this Policy does not replace separate consents. Processing that requires consent starts after an explicit user action in the interface; optional AI features need not be used.

2. Scope of personal data processed

2.1. The Operator processes the following categories of personal data:

• Identification: Telegram ID, username, first name, surname (if provided).
• Contact: telephone number, email (if provided for fiscal receipts and notifications).
• Capsule and commitment data: intention texts, Definition of Done (DoD), Proof artifacts (photos, files, links, geodata), completion statuses.
• Voice data: voluntarily sent voice messages and other audio recordings, their technical format parameters and the resulting transcripts.
• Financial data: transaction history, reserved amounts (the payment details themselves are not processed by the Operator and are transmitted directly to the licensed payment provider, Tochka Bank).
• Technical: IP address, cookie data, device type, user agent.
• Special categories (optional): health and lifestyle data (calories and macronutrients, biometrics) within “Body” capsules. These are processed only with separate explicit consent and using server-side envelope encryption.

3. Purposes of personal data processing

3.1. Providing access to the Service’s features (creating capsules, managing commitments).

3.2. Speech recognition in voluntarily sent voice messages to fulfil the user’s request.

3.3. Automated processing of intentions using AI (task decomposition, Proof verification).

3.4. Initiating reservation and release of funds through the payment provider.

3.5. Resolving disputes (COREXO Arbitration) based on audit_log data.

3.6. Complying with the requirements of the legislation of the Russian Federation (including Federal Laws No. 152-FZ and No. 54-FZ).

4. Processing principles and conditions

4.1. The Operator processes personal data lawfully and fairly, limited to achieving specific purposes.

4.2. Encryption at rest: Server-side envelope encryption (AES-256-GCM) is applied to sensitive data (for example, “Body” capsules). Data is stored encrypted; decryption is performed on the Operator’s side to the extent necessary for the Service to operate and is restricted to technical services.

4.3. Pseudonymisation: In the immutable event log (audit_log), user identifiers are stored as hashes (SHA-256) to ensure cryptographic integrity while also protecting personal data.

5. Data Subject rights

5.1. A Data Subject has the right to access, rectification, blocking or destruction of their personal data.

5.2. Export and deletion: A user may request an export of their data in a machine-readable format (JSON) and deletion of their account by sending a request to info@corexolife.io.

5.3. If an account is deleted, personal data is destroyed within 30 days, except for data that the Operator is required to retain by law (for example, financial transaction data and the audit_log in depersonalised form — 3 years).

6. Transfer of data to third parties

6.1. The Operator does not sell personal data. To the extent necessary for the stated purposes, data may be provided to:

• The licensed payment provider (Tochka Bank) to carry out settlements.
• Cloud/server infrastructure providers to host the primary database in the Russian Federation.
• Yandex.Cloud LLC (OGRN 1187746678580, INN 7704458262, Yandex SpeechKit) — for speech recognition in a voluntarily sent voice message. The request includes only the audio content and format parameters, without the Telegram ID, username or chat history; server-side logging is disabled. After receiving the transcript, COREXO sends a request to delete the recognition result; if immediate deletion fails, the documented period for which the provider retains the result does not exceed 3 days.
• DeepSeek — to process text AI requests.
• Inter LLC (OGRN 1147017006950, INN 7017351722, RouterAI service) and providers of the selected OpenAI GPT-5.6 Terra model (OpenAI or Microsoft Azure) — to route and process vision requests. RouterAI technically forwards the request to the model provider; its servers and the model provider’s servers may be located outside the Russian Federation.
• Authorised bodies of the Russian Federation upon a lawful request.

6.2. The original audio recording is transferred only to Yandex SpeechKit for speech recognition and is not transferred to DeepSeek or vision providers. The resulting transcript may subsequently be transferred to DeepSeek as a text AI request. For other AI features, depending on their type, the request text, a selected image, a file or an extracted fragment may be transferred. The Operator minimises the amount of data transferred, but complete anonymisation is not guaranteed. The terms are set out in the consents to AI processing and cross-border transfer.

7. Contact

For all questions relating to personal data processing, contact info@corexolife.io.