Consent to Personal Data Processing

This Consent is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".

1. Personal Data Controller
Individual Entrepreneur Alexander Viktorovich Perminov, Taxpayer Identification Number (INN) 667900947994, Yekaterinburg, Sverdlovsk Region, Russian Federation. Contact: inbox@lunora.mom.

2. Personal Data Subject
An individual who has registered in the Lunora service (Telegram bot @LunoraSleepBot) and has accepted this Consent by starting to use the Service or by explicitly confirming consent in the interface.

3. Categories of Processed Data
3.1. User Data:

• Telegram ID, user's name and username;
• interface language, time zone;
• device data (operating system type, Telegram version, client type);
• application activity history (tabs, buttons, session duration);
• payment data (payment status, date, amount, transaction identifier — excluding card details, which are processed by the payment provider).

3.2. Child Data (Minor):
The User provides data about the child as the child's legal representative. The Service processes:

• child's name (or nickname), date of birth;
• sleep schedule data: bedtime, wake-up time, duration;
• feeding and complementary feeding data (time, amount, type of feeding);
• anthropometric data (weight, height — if entered by the User);
• AI-generated plans and recommendations based on the data provided.

Special categories of data (health-related data) are processed solely to the extent voluntarily provided by the User for the purpose of delivering Service functionality.

4. Purposes of Processing

• providing access to Lunora Service features;
• generating AI sleep plans and recommendations;
• sending Telegram notifications;
• processing payments and managing subscriptions;
• providing user support;
• improving Service quality based on anonymized analytics;
• compliance with the requirements of Russian Federation legislation.

5. Legal Grounds for Processing
consent of the data subject (Article 6, Part 1, Clause 1; Article 10, Part 2, Clause 1 of Federal Law No. 152-FZ);
performance of an agreement to which the data subject is a party (Article 6, Part 1, Clause 5 of Federal Law No. 152-FZ);
legitimate interests of the Controller related to security and Service improvement.

6. Disclosure of Data to Third Parties
Data may be disclosed to:
OpenAI — for generating AI sleep plans (only anonymized sleep parameters, without names or identifiers; in accordance with OpenAI's Privacy Policy);
Telegram — for delivering notifications and operating the bot (in accordance with Telegram's Privacy Policy);
payment providers — for transaction processing to the extent necessary.
No sale, rental, or disclosure of personal data to third parties for marketing purposes is carried out.

7. Data Retention Periods
active account data: for the duration of Service use plus 3 years;
payment data: 5 years (as required by tax legislation);
deleted account data: deleted within 30 days from the request date.

8. Rights of the Data Subject
The User has the right at any time to:

• obtain information about processed data;
• request correction of inaccurate data;
• request deletion of data (right to be forgotten);
• withdraw this Consent, which results in termination of access to the Service;
• submit a complaint to Roskomnadzor.

Requests: inbox@lunora.mom. Response period: 30 days.

9. Security
The Controller implements organizational and technical security measures, including TLS 1.2+ encryption, database access restrictions, and regular backups.

10. Withdrawal of Consent
A request must be sent to inbox@lunora.mom specifying the Telegram ID or account name. Processing will cease within 10 business days, and the data will be deleted within 30 days.