Privacy Policy

This policy defines the procedure for processing and protecting personal data that the operator receives when using the websites, personal account, photo diary, online store and related Rejuvena and Seplitza services.

The operator is guided by the applicable data protection legislation, including regulations of the jurisdiction where the operator is registered.

• visitors of websites and landing pages
• users registering a Rejuvena personal account
• customers placing orders and making payments
• individuals contacting us via Telegram, email and other messengers
• individuals uploading photos and other materials to the photo diary

• first name, last name, patronymic or nickname of the user
• email, phone number, Telegram username, Telegram user ID and other contacts the user provides
• account data, order history, payment and delivery status, information about purchased products and courses
• delivery address, order comments, recipient data
• photos, facial images and other materials uploaded by the user to the photo diary or for age estimation
• technical data: IP address, cookies, localStorage, user agent, date and time of request, referrer, device and browser information

The user independently determines the scope of information provided to the operator. The operator does not require excessive data and does not use uploaded photos to identify the user.

Purposes of processing:

• registration, authentication and maintenance of the user account
• performance of the contract: sale of goods, provision of access to digital materials, feedback on orders and payments
• maintaining the photo diary, storing and processing user-uploaded images, operating age analysis and progress functions
• handling inquiries via Telegram, email and other communication channels
• sending service notifications related to orders, service access, photo storage and changes in service operation
• ensuring information security, error diagnostics, protection against abuse and technical administration
• fulfilling obligations established by the legislation of the Russian Federation, including accounting, tax and claims management

Legal bases:

• consent of the personal data subject
• conclusion and performance of a contract to which the personal data subject is a party
• necessity to fulfill the operator's obligations under the applicable legislation

The operator is entitled to collect, record, systematize, accumulate, store, clarify, extract, use, transfer as provided by law or contract, anonymize, block, delete and destroy personal data.

The websites use cookies, localStorage and other technical identifiers for authentication, saving settings, routing, correct interface operation, preventing re-authentication, error diagnostics and protection against abuse.

The user may restrict the use of cookies in browser settings, but this may lead to incorrect operation of certain website functions.

When using the photo diary, photos uploaded by the user may be sent to an AI image analysis service(InsightFace model) for the sole purpose of estimating the facial age and tracking progress.

Before the first photo upload, the app asks the user for explicit consent to AI processing. Without consent, photos are not sent to the AI service and age estimation is not performed.

The following information is sent to the AI service: the uploaded photo (or its cropped version). Photos are used only for age calculation, are not used for advertising, are not sold and are not transferred to other third parties. The operator stores photos in the user's personal photo diary and deletes them at the user's request or upon expiration of the storage period.

• hosting providers, data centers and technical support contractors acting on behalf of the operator
• delivery services and logistics partners, if necessary for order fulfillment
• banks, payment and acquiring services chosen by the user during payment
• traffic routing and protection services, including Cloudflare, which process technical connection data
• Telegram, WhatsApp and other messengers, if the user chooses such a communication or notification channel

Transfer of personal data to third parties is carried out only to the extent necessary to achieve the stated purposes, perform the contract, provide the service chosen by the user, or comply with legal requirements.

The operator does not organize regular cross-border transfer of personal data as an independent purpose of processing. However, certain technical connection data may be processed by foreign traffic routing and protection services, including Cloudflare.

If the user independently interacts with the operator through Telegram, WhatsApp and other foreign platforms or provides relevant identifiers for notifications, such services may process and transfer technical data, identifiers and message content according to their own rules.

Personal data is stored no longer than required by the purposes of processing, the validity period of consent, the terms of the contract and the mandatory retention periods established by the legislation of the Russian Federation.

Account data is stored for the duration of the account, order and payment data — within the periods necessary for contract performance, accounting and tax purposes, and photo diary materials — until deletion by the user, expiration of the established storage period or termination of the relevant function.

The operator takes legal, organizational and technical measures to protect personal data, including access control, authentication, logging, backup, network perimeter protection and limiting contractor access on a need-to-know basis.

• obtain information about the fact, grounds, purposes, methods and terms of processing of their personal data;
• demand clarification, blocking or destruction of inaccurate, incomplete, outdated or unlawfully processed data;
• withdraw consent to the processing of personal data;
• appeal the operator's actions to the competent data protection authority or in court.

To withdraw consent, obtain information or submit a request regarding personal data, the user can write to support@rejuvena.seplitza.ru or contact via Telegram support.