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Contents

  1. General provisions
  2. What data we process
  3. What we don't store
  4. How a call works
  5. Purposes of processing
  6. Legal bases
  7. Retention periods
  8. Who data is shared with
  9. Cookies and data on your device
  10. Your rights and deletion
  11. Data protection
  12. Contacts
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  3. Privacy policy

Privacy policy

Version of [to be completed]

Courtesy translation. Which language version prevails will be decided by a lawyer: [to be completed]

Draft: sections marked “[to be completed]” are being prepared with a lawyer.

In short. We don't know the client's name, what they look like or how to contact them. We store the name we issued ourselves, a password hash, avatar settings, dialogues and call bookings.

We don't record calls. You can delete your account with a button in the settings.

1General provisions

This policy describes how the Aprosop service (aprosop.ru) processes the data of its users — clients and specialists. The Russian version was prepared in line with Russian Federal Law No. 152-FZ “On Personal Data”.

Operator: name: [to be completed], tax ID [to be completed], registration number [to be completed], address [to be completed]. Full details are on the “Company details” page.

Controller and representative for users in the EU/EEA and the UK (GDPR Art. 27), data protection officer if required. [to be completed]

2What data we process

For clients:

  • Name on the service, e.g. “quiet-whale-4821”. It is generated by the system and not linked to your real name.
  • Password and recovery key, only as a hash: nobody, including us, can learn the password or key from it.
  • Avatar settings: face shape, hairstyle, colours. A set of parameters, not a photo.
  • Dialogues and calls: chat messages (under the retention rules you chose), the time, length and status of calls, and the specialist.
  • Balance: top-ups, charges for calls, refunds.
  • Preferences: interface language and the country you selected (used to show local crisis lines).

For specialists, additionally: login details, application and public profile, qualification documents, payout details. Full list: [to be completed]

Messages in a mental-health context may reveal information about health, which is a special category of data under GDPR Art. 9: the explicit-consent mechanism for users in the EU/EEA and the UK. [to be completed]

3What we don't store

About clients

Real name, email, phone number, date of birth, photo, documents.

About calls

Video, audio, the camera image and the content of the conversation.

4How a call works

The camera recognises your expressions right in your browser. Unless you choose to show your real face, the camera image never leaves your device: only the animated avatar is sent. The voice filter also runs on your device.

Video and audio travel between browsers over an encrypted channel (WebRTC). Our server helps establish the connection but does not record the stream.

Captions and “Text only” mode: speech is recognised on the speaker's device from the original voice, before the filter. The text goes directly to the other person over the same encrypted channel, bypassing our servers, and is not stored anywhere.

An honest limitation. For a direct connection, browsers exchange network addresses, so technically a specialist may see your IP address, and our server sees it with every request, like any website.

5Purposes of processing

Purposes of processing for each category of data. [to be completed]

6Legal bases

Legal bases for processing (Russian law; for EU/EEA and UK users — GDPR Art. 6 and Art. 9 conditions, e.g. explicit consent). [to be completed]

7Retention periods

Retention periods by category of data. [to be completed]

8Who data is shared with

Never for advertising or sale. A specialist sees your name on the service, your avatar and the messages in your dialogue with them. Payment happens on the payment service's side: your card number and name never reach us.

List of processors (hosting, payment service, AI provider for Tisha and others), where they are located, and the safeguards for cross-border transfers (including transfers of EU/UK users' data to Russia). [to be completed]

9Cookies and data on your device

Your browser stores login tokens, the interface language, the country you selected and the theme. More in the cookie policy.

10Your rights and deletion

The account settings have a “Delete account” button. After you confirm with your password, the account and its data are deleted. Data we are required by law to keep (for example, about payments) is kept for the statutory period: [to be completed]

How to exercise your rights (access, rectification, erasure, portability, objection, withdrawal of consent), response times, and the right to complain to a supervisory authority (EU/EEA, UK ICO) or under US state privacy laws. [to be completed]

11Data protection

Organisational and technical security measures. [to be completed]

12Contacts

Send questions about your data to support@aprosop.ru. You don't need to introduce yourself — your name on the service is enough if the question concerns your account.

Other documents

  • Terms of use
  • Public offer
  • Consent to the processing of personal data
  • Cookie policy
  • Refund policy
  • Specialist agreement
  • Company details
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