REGISTER OF PROCESSORS AND RECIPIENTS OF PERSONAL DATA

1.1. The Operator of personal data (within the meaning of Federal Law No. 152-FZ) is Individual Entrepreneur (IP) Silkina Viktoriia Vladimirovna (Силкина Виктория Владимировна), INN (Taxpayer Identification Number) 632103624730, OGRNIP (Primary State Registration Number of an Individual Entrepreneur) 321631200006480 of June 17, 2021.

1.2. Contact for inquiries regarding personal data: support@selfiedoc.online.

2.1. The Operator transfers personal data to third parties only to the extent necessary for the provision of the service, performance of the agreement, acceptance of payment, authorization, communication with the User, analytics subject to consent, ensuring security, compliance with the law or protection of the Operator’s rights.

2.2. The Operator does not sell Users’ personal data to third parties.

2.3. The Operator does not transfer uploaded photographs, final files, payment data or support requests to advertising partners for their own use.

2.4. When transferring data to processors, the Operator applies the principle of minimization: only the data that a specific recipient needs to perform the entrusted function is transferred.

2.5. Background removal (silhouette extraction) is performed on the Operator’s own infrastructure without transferring the image to third parties.

3.1. Beget / hosting provider.

Purpose: hosting of the website, backend, database, file storage and technical infrastructure in the territory of the Russian Federation.

Data: account, sessions, uploaded photographs, generated images, final files, order information, technical logs, IP address, User-Agent, cookie consents, security logs.

Grounds: performance of the agreement with the User, ensuring the operation of the Service, storage of data in the territory of the Russian Federation, protection of the Operator’s rights.

3.2. UnitPay / payment service.

Purpose: acceptance of payment, confirmation of payments, refunds, payment notifications, generation of payment identifiers, generation and sending of fiscal receipts.

Data: amount, plan, payment method (bank card or SBP), payment status, payment identifier, technical payment information, email address for sending the fiscal receipt.

Grounds: performance of the agreement with the User, acceptance of payment, accounting and tax records.

3.3. OpenAI API / automated and neural network image processing service.

Purpose: image processing, generation or enhancement of a photo option, technical execution of an AI request.

Data: the uploaded image or the image selected for processing, the technical processing request, generation parameters and technical request metadata. The phone number, email, payment data, order history and support requests are not transferred.

Specifics: a cross-border transfer of the image and the technical request data is possible.

3.4. Higgsfield / Higgsfield CLI / automated and neural network image processing service.

Purpose: image processing, generation or enhancement of a photo option, technical execution of an AI request.

Data: the uploaded image or the image selected for processing, the technical processing request, generation parameters and technical request metadata. The phone number, email, payment data, order history and support requests are not transferred.

Specifics: a cross-border transfer of the image and the technical request data is possible.

3.5. OpenRouter platform / service for routing and executing AI requests.

Purpose: backup, legacy or internal image processing through AI providers, if the relevant environment is enabled in the Service.

Data: the image, the technical processing request, generation parameters and technical request metadata. The phone number, email, payment data, order history and support requests are not transferred.

Specifics: a cross-border transfer of the image and the technical request data is possible.

3.6. Kie.ai / neural network image generation service.

Purpose: image processing, generation or enhancement of a photo option, technical execution of an AI request.

Data: the uploaded image or the image selected for processing, the technical processing request, generation parameters and technical request metadata. The phone number, email, payment data, order history and support requests are not transferred.

Specifics: a cross-border transfer of the image and the technical request data is possible.

3.7. Yandex.Metrica and Webvisor / analytics.

Purpose: analytics of traffic, interface quality, referral sources, technical errors and the effectiveness of the Service.

Data: IP address, User-Agent, information about the browser, device, page, referral source and actions on the website. Used only after the User consents to analytics cookies.

3.8. VK Pixel / advertising analytics.

Purpose: assessment of the effectiveness of advertising, retargeting and analysis of advertising referrals.

Data: technical information about visits and actions on the website. Uploaded photographs, final files, payment data and support requests are not transferred. Used only after the User consents to marketing cookies.

3.9. Mail service (SMTP) for sending emails.

Purpose: sending links to sign in to the personal account and to recover the password, links to download the result, Order notifications and other service and transactional messages.

Data: email address, text of the service message, technical delivery status.

3.10. Authorization and user account services, including Stack Auth, if the relevant environment is enabled in the Service.

Purpose: registration, authorization, management of sessions and access to the personal account.

Data: email, technical user identifier, sessions, sign-in information and technical authorization logs.

3.11. Talk-Me / online support chat on the Website, if the relevant widget is enabled.

Purpose: receiving and processing User requests via the support chat.

Data: the content of the correspondence, contact details that the User provides in the chat, and technical information about the visit (IP address, User-Agent, page address). Uploaded photographs, final files and payment data are not transferred.

3.12. Technical contractors and support specialists.

Purpose: maintenance, diagnostics, bug fixing, handling of requests, ensuring security and development of the Service.

Data: only the information to which access is necessary to perform a specific task, subject to access and confidentiality restrictions.

3.13. Government authorities, courts, law enforcement agencies, tax authorities and other authorized persons.

Purpose: compliance with the requirements of the legislation of the Russian Federation, judicial acts and lawful requests, and protection of the Operator’s rights.

Data: information to the extent provided for by applicable law or a lawful demand.

4.1. The Operator reviews this register when a new processor is engaged, when the purpose of the transfer changes, when the scope of the data transferred changes or when the applicable legal requirements change.

4.2. The current version of the register is published on the Website.