Reference translation. The legally binding version is the Russian text: privacy.html.
This is an English translation provided for convenience. The Russian text above is the binding version, published under Article 18.1 of Russian Federal Law 152-FZ.
This Policy sets out how personal data (hereinafter — PD) is processed and the measures the Operator takes to keep it secure. It has been issued pursuant to Article 18.1 of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
Operator: Evgeny A. Dorokhov, an individual applying the special tax
regime “Tax on Professional Income” (self-employed).
TIN: 272511721775
Postal address for written requests: provided on request sent to the e-mail below
E-mail for requests, enquiries and withdrawal of consent:
[email protected]
The Policy applies to all information the Operator may obtain about users of the Pika service — an app for specialists (coaches, tutors, beauty masters, instructors, studios) and their clients, and a service for booking courts and halls at sports clubs, “Pika Club” — hosted at zhedor.com/app/pika/, including the mobile wrapper apps.
Using the service means the user agrees to this Policy. A user who does not agree must stop using the service.
Personal data, processing of PD, operator, data subject, cross-border transfer, anonymisation, blocking and destruction of PD are used with the meanings established by Article 3 of 152-FZ.
Key allocation of roles. A client's PD (name and, at the specialist's discretion, contacts, age, notes, progress records, balance and payments) is entered into the service by the specialist. In respect of that data the specialist is the operator, while the operator of the Pika service acts as a person processing data on the operator's instruction (Article 6(3) of 152-FZ) — storing and displaying the data on their instruction and for the purposes they set.
The specialist's obligation: to obtain the client's consent — or a legal guardian's consent for a minor — before entering the data into the service, and to ensure the processing is lawful. The operator of the service does not and cannot verify that such consent exists.
If a client sets up their own login to the cabinet, the following is processed in addition: e-mail address and the account identifier of the login provider, the push-notification subscription, and the cabinet access token.
At registration the Operator records and stores: the fact and time each consent box was ticked, the versions of the Policy and of the User Agreement, the interface language, the IP address and the device user-agent. This information is processed solely as proof that consent was given and is not used for any other purpose.
Who this concerns. A person who books a court, a hall or another club resource through the service — on the club's page, in the club directory or in the app — and also a person entered by club staff at the desk on that person's word.
What is processed: name and phone number; when signing in through a social network — also the account identifier and e-mail address; booking records (date, time, court, price, status, payment method, attendance and cancellation marks); the deposit balance at the club and its movements; a bank receipt image, if the person attached one to confirm payment; messages with the club inside the service; request metadata (IP address, browser details) — to prevent abuse.
Phone number history. When the number on a client's card changes — by the person themselves, when two of their cards are merged, when access is restored through a club employee, or in a specialist's cabinet — the previous and the new number, the date and time of the change and the way it was made are stored. The purpose is protection against number substitution: a club employee sees this history on the client's card, and only for the period during which the person is a client of that club. Each record is kept for 12 months from the change and is then deleted automatically.
What the club receives. Booking a court inherently means the club learns who is coming. We therefore pass to the club you book with: your name, phone number and your booking records at that club, including the club's ability to export them to a file for its own records. You give a separate, unticked consent to this before your first booking; without it a booking cannot be made.
The club is an independent controller of what it receives: it decides the purposes and means of processing itself (attendance, contacting you, settlements) and is responsible for that further processing, including retention periods and answering requests. We do not control what the club does with the exported file or with the details at its desk.
The club never receives your e-mail address, your social account identifier, your IP address, or any information about your bookings at other clubs. The club sees only what concerns the club itself.
A club may be located outside the Russian Federation (in the Kingdom of Thailand, in particular). In that case the transfer of the details listed above is a cross-border transfer and is performed in compliance with Article 12 of 152-FZ — see section 7.
Legal bases: the subject's consent (Article 6(1)(1) of 152-FZ) and performance of the services contract to which the subject is a party (Article 6(1)(5)). The fact, time, document versions, language, IP address and user-agent are written to the consent record (section 4.4).
Withdrawal of consent. A request to [email protected] stops the processing on the Operator's side and makes further bookings impossible. Records already passed to a club must be withdrawn from that club: it is an independent operator of them, and the operator of the service cannot delete data from the club's own records.
The Operator does not process special categories of PD (race, ethnicity, political and religious beliefs, health, sex life) or biometric PD. The profile photo is used as an interface element and is not used to identify a person, and is therefore not biometric PD. The specialist is responsible for the lawfulness of entering any information about a client's health (section 4.2).
PD is not used for purposes incompatible with those listed. Data given for registration is never used for marketing e-mail. We do not sell personal data, do not pass it to advertising networks, run no advertising trackers on the service (web analytics runs only with your consent — see 7.1), do not use it for profiling for advertising purposes, and never use it to train machine-learning models.
Who this concerns. A person who signs in with a social network on a specialist's public blog page in order to leave a comment or a reaction.
What we process: your social account identifier, the name and profile picture the network
provides at sign-in, the public @handle you choose, the text of your comments and
reactions, and request metadata (IP address, browser details) — the latter solely to protect the
service from spam and abuse.
Legal basis. Your consent, given via a separate unticked checkbox at sign-in (Article 6(1)(1) of 152-FZ), and the Operator's legitimate interest in protecting the service from automated abuse.
What becomes public. Your name, @handle, profile picture and comment text are
visible to any visitor of the page and may be indexed by search engines. Your e-mail, social
identifier and IP address are never published.
Profile picture. A copy is stored on the Operator's servers in the Russian Federation; public pages do not link to the social network's servers, so the network learns nothing about a reader's visits to the page.
Your rights. In your profile you can remove the picture, change the @handle,
or delete the profile — with all your comments, or leaving them anonymised. Withdrawing consent
equals deleting the profile. The entry in the consent record is kept as proof that the processing
which had already taken place was lawful (see sections 4.4 and 6).
Who this concerns. A participant in a tournament that a club runs in the service.
Who publishes. A club staff member with the right to run tournaments, or the club owner — with the “Publish results” button, and only for a tournament that has been played. The page opens at a link with a random, unguessable address and is not indexed by search engines (noindex). It stays available until the publication is withdrawn and as long as the tournament is marked as played.
What the page shows. The tournament's name, date and venue, the club's name, the standings (place, participant, points scored) and the podium. Scores of individual matches, pairings by round, contact details, identifiers, photos and entry-fee information are not shown.
Name or initials. The full name is shown only if the participant has consented to their name being shown; by default there is no such consent. Without it, initials (no more than two letters) always appear instead of the name — the service does not ask for separate consent to show them.
Legal basis. For the full name — the data subject's consent to dissemination (Article 6(1)(1) and Article 10.1 of 152-FZ). A club staff member records it on the participant's word; the fact of the consent, the time, and the IP address and browser details of the staff member who recorded it are kept in the consent record (section 4.4).
How to have it removed. Ask the club to remove the consent mark — the name will be replaced with initials; or ask the club to withdraw the publication — the page will stop opening. A change reaches readers within a minute: the page is cached for no longer than 60 seconds.
Who this concerns. A specialist — the account owner — who has personally turned on the “Show me in the city catalog” option in the app settings.
How consent is given. With a separate checkbox in the app settings: it is not ticked by default, and without it the specialist is not shown in the catalog. The consent text is shown above the checkbox before it is ticked; when turning it on, the specialist enters their city.
What is published. The name, profile photo, profession, city and a link to the specialist's public blog page or to booking with them — in the service's open list of specialists (zhedor.com) and in the catalogs of the city websites moigorod.ru and jaimuang.com. This information may be indexed by search engines. The phone number, email address, information about students, prices and schedule are never published.
Legal basis. The data subject's consent to the processing of personal data they have permitted for dissemination (Article 6(1)(1) and Article 10.1 of 152-FZ). The fact of consent and of its withdrawal, the time, the version of the consent text, the interface language, the IP address and browser details are kept in the consent record (section 4.4). Consent covers the text under which it was given: if the checkbox text changes, the specialist stops being shown in the catalog until they confirm the new text.
How to have it removed. Untick the checkbox in the app settings: the specialist disappears from the service's list at once, and the city websites remove their card on their next pass over the list — within 24 hours. A demand to stop dissemination can also be sent to [email protected].
Processing is carried out both with and without automation. PD is kept no longer than the purposes of processing require and is destroyed or anonymised once those purposes are achieved, consent is withdrawn, or the subject so demands.
Localisation (Article 18(5) of 152-FZ). Primary recording, systematisation, accumulation, storage, updating and retrieval of Russian citizens' personal data takes place in a PostgreSQL database hosted on a server located in the Russian Federation. No foreign cloud database is used as the primary store.
Retention: active account data is kept for the life of the account. After deletion, data is erased within 30 days, except the consent record and records the law requires us to keep. Accounts inactive for 180 days may be purged after prior notice to the e-mail on file. Web-server logs are kept for up to 12 months.
The Operator does not disclose PD to third parties except where this Policy or the law expressly provides.
The sports club you book a court or a hall with (section 4.5) receives your name, phone number and your bookings at that club — on the club's workplace screen and as an export file for its own records. The basis is the subject's consent, given by a separate tick before the first booking, and performance of the services contract. The club is an independent operator of those details. Where the club is located outside the Russian Federation, this transfer is a cross-border transfer and is performed in compliance with Article 12 of 152-FZ.
Some operations involve services located outside the Russian Federation, which likewise entails a cross-border transfer of PD:
Cross-border transfers are performed in compliance with Article 12 of 152-FZ. The Operator notifies Roskomnadzor of its intent to carry out cross-border transfers of PD.
Two statistics tools are used on the pages of the service, and both run only after you agree:
allow_google_signals, allow_ad_personalization_signals).counter.yadro.ru) — on the informational pages of the service. Page address, referrer, page title and screen resolution are sent. There is no cross-border transfer here. The page address is stripped of its query string and fragment before sending: one-time links and access codes never leave the page.Before consent is given, neither counter is loaded. Consent is given by actively pressing “Accept”. Consent can be withdrawn at any moment: the “Cookie: change your choice” row in the app settings and at the bottom of the informational pages. Withdrawal takes effect immediately, without reloading the page. Advertising pixels and ad-network trackers are not used on the pages of the service.
You may request confirmation of processing and information about it; require that inaccurate, outdated or unnecessary data be corrected, blocked or erased; withdraw your consent at any time; and complain to Roskomnadzor or a court.
Write to [email protected] — we answer within 30 days of receipt. You can delete your account and all associated data from within the App, or by a request to that address. Withdrawing consent means the service features that require the processing of PD can no longer be provided.
If a specialist entered your data into the service (section 4.2), contact them first as the operator of that data; the operator of the service will give them technical assistance in meeting your request and, if the specialist cannot be reached, will consider the request itself.
We use cookies and browser local storage strictly to run the service: session and access token, chosen language and theme, quick-start draft, application cache (service worker) and CSRF protection during social login. Analytics cookies are set by Google Analytics, and only after your consent (see 7.1). No advertising cookies are set. Disabling cookies makes signing in impossible.
All traffic between the app, the server and external services travels over TLS/HTTPS. Access tokens are never placed in a URL, query string or log file. Third-party secrets and tokens are stored outside the public web root with restricted operating-system permissions. Only the operator can reach the server and the database, solely to the extent needed to run the service. Rate limiting and abuse protection are in place. In case of an incident leading to an unlawful transfer of PD we notify Roskomnadzor within the deadlines set by Article 21(3.1) of 152-FZ.
The service is intended for users aged 18 and over. A specialist may run sessions with minor clients; in that case consent for processing the minor's data must be given by their legal guardian, and obtaining it is the specialist's obligation (section 4.2).
The App accesses Google data only if you explicitly connect your Google Account from the in-app Calendar screen. With your consent we request:
openid, email) — to show
which Google account is connected;…/auth/calendar.calendarlist.readonly) —
read-only, so you can tick which calendars the App should display;…/auth/calendar.events.readonly) —
read-only, so the App can display your busy time alongside your Pika sessions. We never modify
or delete events in your own calendars;…/auth/calendar.app.created) —
the App creates, updates or deletes only its own session events there.We do not access Gmail, Drive, Contacts, or any other Google data.
We do not copy your calendar events into our database — they are fetched live from Google each time you open the Calendar screen. The only sensitive item we retain is the Google OAuth refresh token, stored outside the public web root, in a file with restricted operating-system permissions, keyed by a one-way SHA-256 hash of your app token. Disconnecting Google in the App immediately and permanently deletes that token; you may also revoke access at myaccount.google.com/permissions.
Pika's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Google API data is never used for advertising or profiling, and is never used to develop, improve, or train generalized AI/ML models.
The Operator may amend this Policy. A new version takes effect once it is posted at zhedor.com/app/pika/legal/privacy.html, unless the version itself provides otherwise. The “Last updated” date at the top of the document reflects the current version.
Questions about the processing of PD, data-subject requests and withdrawal of consent: [email protected].