Privacy Policy

1. Scope and principles

This Policy applies to data received through the website, request and questionnaire forms, payment and user flows, private result pages and email communications. Personalised services are intended for adults aged 18 or over.

The Operator processes data lawfully, for defined purposes, in a proportionate and accurate manner, limits retention and follows data-minimisation principles.

2. Categories of ordinary personal data

• request data: selected service, internal reference, date, status and adult-age confirmation;
• contact data: name or preferred form of address, email and any additional contact voluntarily provided;
• questionnaire answers and free text about a situation, beliefs, reactions, decisions, recurring patterns, inner contradictions and intended outcome;
• order and payment data: product, price, currency, payment identifier and status, payment or refund dates; the Operator does not receive full card details;
• working materials: drafts, internal statuses, review notes, report versions and report text;
• technical data required for security, sessions and consent evidence, including date and time, IP address and User-Agent in the records intended for those purposes.

3. Special categories and excessive data

METAMORFOZUM is not intended to collect medical diagnoses or treatment information, religious beliefs, political opinions, information about intimate life, racial or ethnic origin, or biometric data. METAMORFOZUM does not deliberately request these categories and asks users not to include them in their answers.

Users should also avoid submitting passport details, card details or personal data about third parties. If unnecessary data is entered voluntarily in free text, the Operator may disregard, delete or de-identify it where technically and legally possible.

4. Purposes

• receiving a request, identifying the order and communicating with the user;
• confirming payment, providing access to the private questionnaire and saving its draft;
• preparing, manually reviewing, publishing and delivering a personalised result;
• handling corrections, enquiries, complaints and refunds;
• performing the contract and meeting accounting, tax and other legal duties;
• protecting the website, preventing abuse and resolving technical failures;
• improving the service using de-identified or aggregated information.

5. Legal grounds

The grounds include the user's separate consent, steps required to enter into and perform a contract, the Operator's legal obligations, and protection of lawful rights and service security to the extent permitted by Russian law.

Consent to personal data processing is recorded separately from acceptance of the Terms of Service and Public Offer.

6. Operations and processing methods

Processing may be automated, non-automated or mixed. It may include collection, recording, organisation, accumulation, storage, correction, retrieval, use, provision to engaged processors where necessary, de-identification, restriction, deletion and destruction.

The Operator does not make decisions producing legal or similarly significant effects on a user solely through automated analysis.

7. Russian infrastructure and localisation

The main METAMORFOZUM information system is hosted on Timeweb infrastructure in the Russian Federation. PostgreSQL is the production data store. Initial recording, organisation, accumulation, storage, correction and retrieval of source user data take place in the Russian database.

Russian hosting does not remove the Operator's responsibility to ensure lawful processing, access control, backups and security.

8. Technical providers

Each provider receives only the data required for its function. The OpenAI request does not include separate name, email or phone fields, Robokassa payment data or identifiers, internal request or order identifiers, IP address, cookies or session identifiers, technical account data, or administrative metadata. Disclosure to public authorities occurs only on a lawful basis.

• Timeweb — hosting the application, PostgreSQL and technical infrastructure in the Russian Federation;
• Robokassa — creating payments, confirming status and processing refunds; email is transmitted only to the extent required for the payment operation;
• OpenAI — an external AI provider used to process minimised textual materials and prepare a draft personalised information-and-analysis report;
• email, domain, backup and information-security providers — within their relevant functions.

9. AI and cross-border transfer

AI is an auxiliary tool for analysis and draft preparation, not a medical, psychotherapeutic or spiritual professional. After source data is first recorded and stored in PostgreSQL on Timeweb infrastructure in the Russian Federation, only the necessary questionnaire answers, corresponding question text, selected-product information, methodology instructions and analytical working text are transmitted to OpenAI. The prepared result is returned to METAMORFOZUM infrastructure in the Russian Federation for storage and manual review.

OpenAI processing involves a cross-border transfer to the United States of America, limited to what is required to prepare the personalised information-and-analysis report. Direct identifiers are excluded when the request is formed under data-minimisation rules; this technical filtering does not amount to absolute anonymisation because the substance of free-text answers may itself relate to the user.

10. Retention and deletion

When the purposes have been met, data is deleted, destroyed or de-identified unless further retention is required by law, contract or legal protection. When sensitive order content is removed, the minimal financial order record is retained without contacts, questionnaire or report text.

• contacts, questionnaires, report-version contents and user-specific order details: 12 months after delivered or cancelled status, followed by deletion or de-identification;
• a minimal order record without contacts, questionnaire or report text, and payment-attempt records: at least 5 years after the relevant reporting year;
• evidence of consents actually given: provisionally 3 years after the relevant processing ends, unless a different period is required by law or for legal protection;
• administrative audit records: 12 months; administrative sessions: until expiry plus 30 days.

11. Safeguards

• closed access to PostgreSQL and administrative areas;
• role separation and minimum technical privileges;
• encrypted connections, session controls and secrets kept outside source code;
• backups, security-event records and restore testing;
• private questionnaire and report links and limited disclosures to providers;
• deletion or de-identification after retention periods expire.

12. User rights

• request information about processing;
• request correction, restriction or deletion where grounds exist;
• withdraw consent and request an end to processing based on that consent;
• complain to the competent authority or apply to a court;
• exercise other rights available under applicable law.

13. Withdrawal and enquiries

Send a request to metamorfozum11@gmail.com and provide the contact used for the order and enough information to locate it. Withdrawal does not affect the lawfulness of processing carried out before it was received.

The Operator ends consent-based processing unless another legal ground applies. Withdrawal before completion of a personalised order may make further performance impossible; contractual consequences are governed by the Offer and applicable law.

14. Related documents

• Consent to Personal Data Processing
• Legal Information and Documents