Privacy Policy

Published: November 24, 2025, Sochi, Russia

1. General Provisions

1.1. This Privacy Policy (hereinafter referred to as the "Policy") defines the procedure for collection, storage, processing, use and protection of personal data of Users of the "Creator" platform (hereinafter referred to as the "Platform"), located at https://app.create-products.com/.

1.2. The personal data operator is Sergei Misakovich Durgalyan, TIN: 232018676341, professional income tax payer (hereinafter referred to as the "Operator").

1.3. This Policy has been developed in accordance with Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" and other regulatory legal acts of the Russian Federation in the field of personal data.

1.4. Registration on the Platform and/or use of the Platform constitutes the User's unconditional consent to this Policy and the conditions for processing personal data specified herein. If the User does not agree with the terms of the Policy, the User must refrain from using the Platform.

2. Key Definitions

2.1. Personal data — any information relating directly or indirectly to a specific or identifiable natural person (personal data subject).

2.2. Processing of personal data — any action (operation) or set of actions with personal data, carried out with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer, anonymization, blocking, deletion, destruction.

2.3. User — a natural or legal person registered on the Platform or using the Platform.

3. Principles of Personal Data Processing

3.1. Personal data is processed on a lawful and fair basis.

3.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes.

3.3. Merging of databases containing personal data processed for incompatible purposes is not permitted.

3.4. Only personal data that meets the purposes of their processing is subject to processing.

3.5. The content and volume of personal data processed corresponds to the stated purposes of processing. Excessive processing of data in relation to the stated purposes is not permitted.

4. Purposes of Collection and Categories of Processed Data

4.1. The Operator collects and processes the User's personal data for the following purposes:

• Registration and identification of the User on the Platform;
• Providing access to the Platform's functionality;
• Payment processing and settlements;
• Communication with the User (notifications, technical support);
• Improving the quality of the Platform and developing new features;
• Compliance with the legislation of the Russian Federation.

4.2. Categories of processed personal data:

• Registration data: email address, password (encrypted), username;
• Profile data: first name, last name (if provided by the User);
• Payment data: information about completed payments (amounts, dates, transaction identifiers). Bank card data is processed and stored exclusively by the payment service Robokassa;
• Usage data: information about User actions on the Platform, created projects and tools used;
• Technical data: IP address, browser type, operating system, date and time of access to the Platform.

4.3. The Operator does not collect or process special categories of personal data (racial affiliation, political views, health status, etc.).

5. Procedure and Conditions for Data Processing

5.1. Personal data is processed with the User's consent, expressed by registering on the Platform or using the Platform.

5.2. The Operator does not transfer Users' personal data to third parties, except in the following cases:

• Transfer to the payment service Robokassa for payment processing;
• Transfer of anonymized project data to AI service providers (Google Gemini, Perplexity) for content generation — without transferring the User's personal data;
• At the request of authorized government bodies in cases provided for by the legislation of the Russian Federation;
• With the explicit consent of the User.

5.3. The Operator takes necessary organizational and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying and distribution.

5.4. Users' personal data is stored on servers located in the Russian Federation.

6. Processing and Storage Periods

6.1. Personal data is processed and stored for the entire duration of the User's account on the Platform.

6.2. After deletion of the User's account, personal data is destroyed within 30 (thirty) calendar days, except for data whose storage is required in accordance with the legislation of the Russian Federation (in particular, data on financial transactions is stored for the periods established by tax legislation).

6.3. Anonymized statistical data on Platform usage may be stored indefinitely.

7. Cookies

7.1. The Platform uses cookies to ensure proper operation, User authorization and service quality improvement. Cookies may contain:

• Session cookies: necessary to maintain User authorization and proper Platform operation. Deleted when the browser is closed;
• Persistent cookies: store User preferences (language, interface settings) and are valid for a set period.

7.2. The User can disable cookies in the browser settings. However, some Platform features may become unavailable.

8. User Rights

8.1. The User has the right to:

• Obtain information about the processing of their personal data;
• Require clarification, blocking or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
• Withdraw consent to the processing of personal data;
• Require deletion of their account and all associated personal data.

8.2. To exercise their rights, the User may contact the Operator at the email address: mail@create-products.com.

8.3. The Operator is obliged to review the User's request and respond within 30 (thirty) calendar days from the date of receipt of the request.

8.4. The User has the right to appeal the actions or inaction of the Operator to the authorized body for the protection of personal data subjects' rights (Roskomnadzor) or in court.

9. Security Measures

9.1. The Operator takes the following measures to ensure the security of personal data:

• Data encryption during transmission (HTTPS/TLS protocol);
• Storing passwords in encrypted form (hashing);
• Restricting access to personal data (only the Operator has access);
• Regular data backup;
• Using secure servers located in the Russian Federation.

9.2. In the event of a personal data breach, the Operator undertakes to notify the authorized body (Roskomnadzor) and affected Users in the manner and within the time limits established by the legislation of the Russian Federation.

10. Final Provisions

10.1. The Operator reserves the right to make changes to this Policy. The current version of the Policy is published at https://create-products.com/en/privacy-policy.html. Continued use of the Platform after changes are made constitutes the User's consent to the updated Policy.

10.2. For any questions related to the processing of personal data, the User may contact the Operator at: mail@create-products.com.

Operator Details

Sergei Misakovich Durgalyan
TIN: 232018676341
City: Sochi, Russia
Email: mail@create-products.com